RBI Issues Consolidated Directions on E-Mandates for Recurring Digital Payments
The Reserve Bank of India (“RBI”) has, on April 21, 2026, issued the Digital Payments – E-mandate Framework, 2026 (“Framework”), in exercise of its powers under the Payment and Settlement Systems Act, 2007.
The Framework consolidates and supersedes multiple circulars issued between 2019 and 2024 governing e-mandate-based recurring transactions. It comes into effect immediately and applies to all payment system providers and participants processing recurring transactions through cards, prepaid payment instruments (PPIs), and UPI.
Background
Over the past several years, RBI has progressively regulated recurring digital payments through a series of circulars introducing:
- Additional factor authentication (AFA)
- Pre-debit notifications
- Transaction limits
The present Framework brings these requirements together into a single consolidated set of directions, while incorporating operational clarifications based on industry experience.
Key Features of the Framework
(a) One-time Registration and Customer Control
Customers opting for e-mandates are required to complete a one-time registration, validated through AFA. The Framework provides that:
- Each mandate must specify a validity period
- Customers may modify or withdraw mandates at any time
- Mandates may be fixed or variable, with customer-defined caps in case of variable payments
- Any modification or cancellation requires AFA validation
This ensures that customers retain control over mandates throughout their lifecycle.
(b) Processing of Transactions
- The first transaction under an e-mandate requires AFA
- Subsequent recurring transactions may be processed without AFA, subject to prescribed limits
Where the first transaction is processed along with registration, a single AFA may suffice.
(c) Pre-Transaction Notification
Issuers must send a pre-transaction notification at least 24 hours prior to debit. The notification must include key details such as:
- Merchant name
- Transaction amount
- Date and time of debit
- Mandate reference
- Reason for debit
Customers must also be provided an opt-out facility, which is to be validated through AFA.
An exception has been provided for FASTag and National Common Mobility Card (NCMC) auto-replenishment transactions, where such prior notification is not required.
(d) Post-Transaction Notification
A post-transaction notification is required for every debit, including details of the transaction and information on grievance redressal.
(e) Transaction Limits
The Framework prescribes the following thresholds:
- Up to ₹15,000 per transaction: No AFA require.
A higher threshold is permitted for certain categories:
- Insurance premiums
- Mutual fund subscriptions
- Credit card bill payments
For these, transactions up to ₹1,00,000 per transaction may be processed without AFA.
(f) Customer Protection and Dispute Resolution
- Issuers must establish a grievance redressal mechanism
- RBI’s framework on limiting customer liability for unauthorised transactions applies to recurring payments as well
(g) Additional Operational Clarifications
The Framework further clarifies that:
- No charges may be levied on customers for using e-mandate facilities
- Existing mandates may be mapped to reissued cards
- Acquirers are responsible for ensuring merchant compliance
Practical Implications
The Framework does not introduce a fundamental shift in regulatory approach but provides greater clarity and consolidation. From an operational perspective:
- Banks and issuers should review mandate registration, notification, and opt-out mechanisms
- Payment aggregators and fintechs should ensure alignment of merchant onboarding and compliance processes
- Merchants may benefit from improved reliability of recurring payment flows, subject to compliance with mandate requirements
Conclusion
The Digital Payments – E-mandate Framework, 2026 represents a streamlining of the regulatory regime governing recurring digital payments in India.
By consolidating earlier circulars and reinforcing customer consent and notification requirements, the RBI has sought to balance ease of recurring transactions with customer protection and transparency.
Stakeholders may consider undertaking a review of internal systems and processes to ensure compliance with the Framework.
Copy of Directions is available here.
