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RBI Directive on Recurring Card Payments

Further to the circular (issued on 21 Aug 2019) and the press release (issued on 31 March 2021), RBI released a new circular on 31 March 2021, regarding registration of new card mandates. You can find the new RBI circular here.

Guidelines for Issuing Banks (To be complied by 30 Sep 2021)🔗

RBI has issued the following guidelines for issuing banks to authorise mandates and collect recurring payments on credit cards, debit cards and prepaid instruments. RBI has announced this step to make card transactions safer and secured.

  • All mandate registrations must go through Additional Factor of Authentication (AFA). AFA is a process wherein a customer receives an OTP or card PIN during modification or revocation of the mandate and the first transaction.
  • AFA is mandatory for registering mandates on cards. The maximum limit for registering mandates is ₹5,000. You can refer to the RBI circular.
  • At the time of registration, banks should provide customers with the option to choose the communication medium (SMS or email) to which the pre-debit notifications will be sent.
  • Banks should send customers a pre-debit notification at least 24 hours before the actual debit. The notification must contain all the information regarding the upcoming debit. Customers should be provided with an option to opt-out of the particular debit or the mandate.
  • Banks should also send a post-debit notification to the customers. This notification should contain all the information regarding the debit.
  • Banks must provide customers with an online facility through which customers can withdraw from any e-mandate at any point in time. The customers will have to perform the AFA at the time of withdrawal.
  • For all such withdrawn e-mandates, the acquiring banks should ensure that the respective businesses delete all customer payment information.
  • Banks should set up redressal system to address customers grievances. Card networks should also have a dispute resolution mechanism in place.

Note
You do not need to make any integration changes at your end. The circular applies to the issuing banks, and the banks need to implement the changes mentioned above.

Impact on Existing and New Mandates🔗

The impact of the new guidelines is given below:

Existing Mandates

New Mandates

As per the press release, there will be no impact on existing card mandates from 1 April 2021. Recurring payments will continue to be processed on such mandates.

As per the new circular, your customers may not be able to sign up new mandates on cards from 1 April 2021 till issuing banks comply with the guidelines issued in the RBI circular dated 21 August 2019.

Alternative Solution: UPI Autopay🔗

We will soon be enabling UPI Autopay on your Razorpay Dashboard. You can create a registration link that will allow your customers to choose UPI to make recurring payments.

Supporting Banks and UPI Apps🔗

  • Mandates on UPI Autopay can be set up using ICICI, SBI and HDFC accounts on UPI collect flow.

  • Only BHIM and Paytm UPI apps are supported on UPI Autopay.

If you do not want to use UPI Autopay, you can disable it from the Settings tab on the Subscriptions page from your Razorpay Dashboard.

Read More: Learn more about UPI Autopay from our blog and documentation.

MandateHQ: Helping Issuing Banks Comply with the RBI Circular🔗

The RBI has given a 6 months extension (till 30 Sep 2021) to all issuing banks to comply with the guidelines set forth in the circular.

  • Razorpay has partnered with Mastercard to launch MandateHQ - a plug-and-play solution that will allow issuing banks to offer standing instructions on credit cards, debit cards and pre-paid instruments in compliance with the RBI circular.

  • We are working with most of the issuing banks to on-board them on MandateHQ and ensure a smooth transition by 30 Sep 2021. We will keep you posted when banks start going live.

FAQs🔗

Given below are some of the frequently asked questions.

1. Will debits on card mandates registered before 1 April work from 1 April 2021?🔗

Yes, card tokens registered before 1 April will work post 1 April 2021.

2. Can we register new card mandates from 1 April 2021?🔗

As per the new circular released by RBI on 31 March 2021, no new mandate for recurring online transactions shall be registered by stakeholders, unless such mandates are compliant with the circular dated 21 August 2019.

3. How many banks are currently compliant with the RBI circular?🔗

We are working with most of the issuing banks to on-board them on MandateHQ and help them comply with the RBI circular before 30 Sep 2021. We will keep you posted when banks start going live.

4. Will this impact mandates via other methods such as E-mandate, Paper NACH and UPI Autopay?🔗

This change does not impact mandates using UPI Autopay, E-Mandate and PaperNACH. You can continue to register new mandates and charge the existing ones via these methods.

5. Will existing mandates registered through international cards be impacted?🔗

No, the RBI circular is applicable only for issuing banks in India. International card mandates will continue to work.

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