The Khyat Institute

The UPI levy arrives at a threshold proposed in 1999

A 0.4% charge above ₹2,000 is not a tax. Who receives it, and what it makes cheaper to attempt, are the questions worth asking.

The corner of an Indian ten-rupee banknote on a dark surface, showing the rupee symbol, the denomination in the multi-language panel, and an engraved rhinoceros.
An Indian ₹10 banknote of the Mahatma Gandhi series, photographed on 11 August 2019. Cash carries no merchant discount rate, and remains unmetered above the ₹2,000 threshold at which the new charge begins.rupixen / Unsplash

Abstract

NPCI's 0.4% merchant discount rate on UPI transactions above ₹2,000 has been defended as infrastructure cost recovery and attacked as a concession to United States pressure. The evidence supports neither framing in full. The charge accrues in proportion to merchant acquiring scale, at a moment when two applications with US parent companies hold roughly four-fifths of UPI volume and the cap intended to address that concentration has been deferred for a sixth year. Its direction matches a published 2026 US trade complaint; its design withholds what that complaint principally sought. It also opens a price gap against a settlement rail that carries no charge. This brief examines who receives the levy, tests the arguments on each side, and notes that its ₹2,000 threshold matches a figure in a proposal, first developed in 1999, to replace India's tax system.

The National Payments Corporation of India announced on 15 September 2026 that a merchant discount rate of 0.4% will apply to specified person-to-merchant transactions on the Unified Payments Interface above ₹2,000, with effect from 15 October 2026.1 Press Information Bureau, “UPI Continues to Remain Free for Peer to Peer Transactions and 96% of Merchant Transactions,” 15 September 2026. https://www.pib.gov.in/PressReleaseDetail.aspx?PRID=2310586&reg=48&lang=1 The charge is capped at ₹300 for transactions of ₹75,000 and above. Person-to-person transfers remain free regardless of value. A Finance Ministry notification of 14 September designates UPI transactions up to ₹2,000, together with RuPay debit cards, as modes on which no bank or system provider may impose any charge, directly or indirectly, on the person making or receiving the payment.2 Ministry of Finance, Department of Financial Services, notification S.O. 5067(E), 14 September 2026, issued under section 10A of the Payment and Settlement Systems Act, 2007. Text reproduced at https://taxguru.in/finance/government-charges-upi-payments-exceeding-rs-2-000.html; reported by LiveLaw, https://www.livelaw.in/top-stories/centre-prohibits-charges-on-upi-transactions-up-to-rs-2000-rupay-debit-card-550015 By the government’s own account, roughly 96% of merchant transactions by number fall below the threshold and remain free.1 The Reserve Bank of India endorsed the framework the same day.3 Reserve Bank of India, post on X, 15 September 2026, reported by Business Standard, 16 September 2026. https://www.business-standard.com/finance/news/rbi-backs-mdr-on-large-value-upi-transactions-says-users-will-pay-no-fee-126091600146_1.html

Merchant classification also changes. Merchants receiving more than ₹1 lakh a month through UPI for three consecutive months migrate from the exempt person-to-person-merchant category into the chargeable person-to-merchant category.4 Department of Financial Services, “FAQs: Merchant Discount Rate (MDR) on Select UPI (P2M) Transactions,” September 2026. https://financialservices.gov.in/sites/default/files/2026-09/FAQs---Merchant-Discount-Rate—MDR—on-Select-UPI—P2M—Transactions_0.pdf A single large payment does not create liability; sustained volume does.

The public argument since has run along a single axis: whether this is a justified cost recovery or a tax by another name. That axis is the least informative one available. A merchant discount rate is definitionally not a tax — none of it reaches the exchequer — and the government is correct to say so. But establishing that a charge is private revenue rather than public revenue settles almost nothing, because the interesting question is which private parties receive it.

The levy accrues in proportion to existing scale

A merchant discount rate is distributed among the participants that process a transaction: the acquiring bank, the payment service provider, and the application that owns the merchant relationship. The Reserve Bank and the Finance Ministry both describe the charge as shared in exactly this way.3 Its incidence therefore tracks merchant acquiring share.

As of May 2026, PhonePe held 46.26% of UPI transaction volume and Google Pay 32.75%, with Paytm third at 7.91%.5 NPCI, UPI ecosystem statistics, May 2026. https://www.npci.org.in/product/ecosystem-statistics/upi The two leaders together account for roughly four-fifths of the rail. PhonePe is majority-owned by Walmart and is preparing a public listing; Google Pay is owned by Google. Whatever the framework’s intent, the arithmetic of proportional distribution means that a levy introduced to sustain the ecosystem will, at prevailing shares, be collected overwhelmingly by two applications with US parent companies.

  1. PhonePemajority-owned by Walmart46.26%

  2. Google Payowned by Google32.75%

  3. Paytm7.91%

Share of UPI transaction volume by application, May 2026, against the 30% cap NPCI set in November 2020 and has deferred to 31 December 2026.NPCI, UPI ecosystem statistics, May 2026.

This matters more in combination with a second fact. On 5 November 2020, NPCI capped any single third-party application at 30% of UPI volume, citing risks to the ecosystem. The compliance deadline has been deferred repeatedly and now stands at 31 December 2026.6 NPCI circular extending the compliance deadline to 31 December 2026, reported by PTI, 1 January 2025: https://theprint.in/economy/npci-extends-market-cap-deadline-for-upi-apps-for-another-two-years-till-2026/2426963/; see also Business Today, 31 December 2024: https://www.businesstoday.in/tech-today/news/story/npci-extends-30-upi-market-share-cap-deadline-on-3rd-party-apps-to-december-2026-459171-2024-12-31 The structural remedy for concentration has been postponed for six years. The revenue mechanism that scales with concentration arrives in five weeks.

We do not claim these two decisions were coordinated. We observe that their combined effect is to monetise a market structure the regulator has said, in its own documents, that it intends to change.

Why the industry wanted this, and what it says about the cost argument

The official rationale is infrastructure sustainability: the rail costs money to run, and someone must fund switching capacity, fraud management and settlement. This is true and insufficient, because it does not explain the timing or the incidence.

NPCI is a not-for-profit company established in 2008 by the Reserve Bank and the Indian Banks’ Association. It is not a commercial entity seeking margin, and the merchant discount rate does not principally flow to it. The cost pressure the framework relieves sits at the application and payment service provider layer, not at the switch.

That layer has operated for six years on a specific model: absorb the cost of payments, and recover it indirectly through lending distribution, insurance, wealth products and commerce. Payments were a customer acquisition channel rather than a business. This model has a structural consequence that is rarely stated plainly. It is available only to firms with a balance sheet, a lending licence, or a parent willing to fund losses indefinitely. A small payment service provider with no credit book has no way to monetise a free rail, and therefore no route to scale. The zero-MDR regime did not produce a level field; it produced a field on which only the capitalised could stand.

Read that way, the introduction of MDR is a demand from the industry rather than a concession by it, and the request is coherent: make payments a business in their own right, so that a firm need not own a lending operation to participate in one.

The difficulty is that a proportional charge introduced into an already concentrated market does not redistribute. It converts existing share into a revenue stream. A new entrant with 0.5% of volume receives 0.5% of a new revenue pool, which is not enough to fund competition against an incumbent receiving 46% of it. The measure makes payments profitable without making them contestable.

What the opposition is arguing, and what the record shows

The legal basis for the charge was laid before the charge itself. Section 10A of the Payment and Settlement Systems Act, 2007 had barred banks and payment providers from charging for payment modes prescribed under the Income-tax Act — a list that included UPI. The Taxation and Other Laws (Amendment) Bill, 2026 replaced that reference with “one or more electronic modes of payment as the central government may, by notification, specify.”7 Taxation and Other Laws (Amendment) Bill, 2026 (Bill No. 150 of 2026). Amendment text quoted in The Wire, 6 August 2026: https://m.thewire.in/article/banking/lok-sabha-passes-bill-allowing-govt-to-permit-banks-others-to-charge-for-upi-transactions; passage by voice vote without discussion reported by ANI in The Tribune, 6 August 2026: https://www.tribuneindia.com/news/business/lok-sabha-passes-taxation-and-other-laws-amendment-bill-without-discussion-amid-oppositon-protests/amp Introduced on 4 August as part of a wider tax measure, the Bill passed the Lok Sabha by voice vote on 6 August, without discussion, amid opposition protests over an unrelated matter.7 That day the Finance Minister, answering criticism, said the NPCI-led steering committee had yet to decide on any merchant discount rate. On 10 August, as Parliament completed passage, she told the Rajya Sabha that no framework had been finalised.8 Nirmala Sitharaman, post on X, 6 August 2026: https://x.com/nsitharaman/status/2085375889668534421; statement in the Rajya Sabha, 10 August 2026, reported by ANI: https://aninews.in/news/business/parliament-clears-taxation-and-other-laws-amendment-bill-sitharaman-says-no-upi-mdr-for-consumers-small-merchants20260810191208/ The notification designating the protected modes followed on 14 September, and NPCI’s framework the next day.

Against this sequence, the Congress has described the measure as a “UPI tax” introduced under United States pressure. Randeep Surjewala called 14 September a day of “digital somersault” and argued the change would benefit American companies.9 Randeep Surjewala, press conference in Bengaluru, 16 September 2026, reported by ANI: https://news.webindia123.com/news/Articles/India/20260916/4499501.html Jairam Ramesh asked: “Why 0.4% MDR? Is it because debit card MDR is also 0.4%?”10 Jairam Ramesh, post on X, 16 September 2026, quoted in full by ANI: https://www.aninews.in/news/national/pm-redefined-nota-as-narendras-ongoing-trump-appeasement-jairam-ramesh-slams-centre-over-upi-charges-us-tariffs20260916111938/ Rahul Gandhi has argued that the cost will reach consumers through prices, and that while the charged transactions are about 5% of the count, they carry roughly 65% of the value.11 Rahul Gandhi, posts on X, 15 and 16 September 2026, reported by Outlook: https://www.outlookindia.com/national/have-a-spine-withdraw-upi-charge-rahul-gandhi-slams-pm-modi and https://www.outlookindia.com/national/upi-fee-row-government-hits-back-at-rahul-gandhi-over-upi-tax A public interest petition has been filed in the Supreme Court. The government denies any foreign influence, has ruled out a rollback, and has said that passing the charge on to consumers would be a criminal offence. It has also pointed out that Congress members of a parliamentary committee, including P. Chidambaram and Manish Tewari, had supported a tiered merchant discount rate.12 Government response, 16 September 2026: https://www.indianeconomicobserver.com/news/imposing-upi-mdr-to-consumers-a-criminal-offence-centre-hits-back-as-opposition-alleges-surrender-to-us-pressure20260916224529/; Supreme Court petition: https://www.theweek.in/news/india/2026/09/16/upi-mdr-fee-govt-refuses-to-back-down-despite-opposition-pressure-matter-reaches-sc.html; parliamentary committee: https://www.outlookindia.com/national/upi-fee-row-government-hits-back-at-rahul-gandhi-over-upi-tax

These arguments differ in quality, and the strongest of them is the one most often dismissed.

The foreign-pressure argument has a documentary basis. On 31 March 2026, the Office of the United States Trade Representative published its National Trade Estimate Report, which named India’s zero-MDR framework for UPI and RuPay as a barrier facing US payment firms. It observed that the zero-charge environment stood in contrast to higher-margin card markets elsewhere, and had pushed Indian fintechs to earn through cross-selling financial products rather than through payments — the same structural feature described above, identified by a foreign government as a commercial grievance.13 Office of the United States Trade Representative, 2026 National Trade Estimate Report on Foreign Trade Barriers, March 2026, India chapter. https://ustr.gov/sites/default/files/files/Press/Releases/2026/National%20Trade%20Estimate%20Report%202026.pdf; quoted by CNBC, 17 September 2026: https://www.cnbc.com/2026/09/17/upi-payments-visa-amazon-phonepe.html On 15 July 2026, after a Section 301 investigation in which Brazil’s electronic payment policies, Pix among them, were one of six grounds cited, the United States imposed a 25% tariff on Brazilian goods.14 USTR, Notice of Action, Section 301 investigation of Brazil, Federal Register, 20 July 2026: https://www.federalregister.gov/documents/2026/07/20/2026-14542/notice-of-action-brazils-acts-policies-and-practices-related-to-digital-trade-and-electronic-payment; Presidential Memorandum of 15 July 2026: https://www.govinfo.gov/content/pkg/FR-2026-07-20/pdf/2026-14654.pdf The Bill amending India’s payments law was introduced in the Lok Sabha three weeks later. The sequence is documented. Causation is not: no public document shows the Indian decision was taken in response, and the government calls the suggestion “patently false.”15 Department of Financial Services, post on X, 17 September 2026, reported by ANI: https://english.punjabkesari.com/business/allegation-about-external-pressure-over-mdr-decision-false-and-misleading-says-department-of-financial-services But an argument resting on a published foreign-government complaint, followed by a policy change in the direction it sought, is not unfalsifiable rhetoric and should not be treated as such.

The domestic and foreign explanations are not alternatives. The levy accrues in proportion to acquiring share, and roughly four-fifths of that share belongs to applications owned by Walmart and Google. Whatever moved the decision, the end of zero-MDR directs a new revenue stream predominantly to US-parented firms. The entrenchment argument and the foreign-interest argument describe the same outcome from two directions.

The design cuts the other way. The US complaint was principally about access: the inability of US networks to participate in UPI, and especially in credit on UPI, on terms equal to RuPay. That access has not been granted. RuPay remains the only credit card network permitted on UPI; credit-linked UPI payments are excluded from the new framework and remain under existing credit-product rules;4 and RuPay debit cards sit among the protected, chargeless modes.2 The Department of Financial Services argues on this basis that the framework protects domestic rails rather than opening them, describing it as a step in protecting India’s sovereignty in electronic payments.15 Ramesh’s rate observation is also only partly accurate. 0.4% matches the debit-card cap that applies to smaller merchants, but larger merchants pay up to 0.9% on debit cards, and on NPCI’s own comparison UPI remains the cheaper rail for them.16 Business Standard, 16 September 2026, citing the NPCI FAQ. https://www.business-standard.com/amp/finance/personal-finance/upi-mdr-explained-how-new-charges-compare-with-debit-credit-cards-126091600354_1.html RuPay debit, meanwhile, carries no charge at all. The direction of the policy matches the US request. Its design withholds the substance of it. Both the opposition and the government are describing something real.

The slippery-slope argument is stronger than the government allows. The present rules do not charge consumers, and to the extent the opposition implies they do, it is wrong. But until August, protection was statutory and covered every UPI transaction; it now covers whatever the government notifies. Lowering the ₹2,000 threshold, or removing a mode from the protected list, requires a notification rather than legislation. The government’s reassurance accurately describes the rules and is silent on the power it took to change them.

The return-to-cash argument does not survive contact with the numbers, except where it does

The most widely circulated objection online is that merchants will abandon UPI and revert to cash. In its general form this is wrong. The charge is 40 basis points, it cannot be passed to the consumer, and it applies only to merchants already processing above ₹1 lakh a month. A merchant at that volume abandoning their dominant payment channel over 0.4% would be trading a large operational cost for a small financial one.

But the general form is not the interesting form. The government has itself acknowledged that margins matter: payments above ₹2,000 in railways, telecommunications, insurance, fuel and agricultural inputs — sectors it describes as essential and thin-margin — carry a flat ₹5 instead of the percentage charge.17 Finance Ministry statement of 15 September 2026, reported by IANS: https://indicanews.com/rbi-says-new-upi-mdr-framework-will-strengthen-digital-payments-ecosystem/ That leaves categories such as jewellery and consumer electronics, where ticket sizes routinely exceed ₹2,000 and margins are also thin, on the full 0.4%. For a business operating on a net margin of, say, two to three percent, a 0.4% charge on gross transaction value is a materially larger share of profit than of revenue. These are the merchants for whom the arithmetic changes behaviour — and what changes is not a wholesale return to cash but selective steering at the point of sale, toward whichever instrument carries no charge.

That is worth stating precisely, because it identifies where the pressure actually lands, and because the instrument carrying no charge already exists.

A charge on one rail is a subsidy to the other

India operates a retail central bank digital currency in pilot. Its transactions attract no merchant discount rate, because settlement in central bank money does not require the interbank chain the charge recovers.

From 15 October, a classified merchant accepting ₹10,000 pays ₹40 on UPI and nothing on the e-rupee. At ₹75,000 and above the gap is ₹300 per transaction. Reporting in Mint indicates officials expect this to spur retail CBDC adoption, particularly for subsidy transfers.18 Mint, 16 September 2026, “Fee on UPI may nudge users towards CBDC.” https://www.livemint.com/industry/banking/mdr-on-upi-transactions-e-rupee-cbdc-rbi/amp-11789489693425.html Former RBI deputy governor R. Gandhi has said publicly that merchants seeking to avoid the cost on larger payments will have the option of CBDC, where there may be no charge.18

That is a stated expectation from a former central banker. It should carry more weight than inference, and it converges with the margin analysis above: the merchants most exposed to the charge are precisely those with the strongest reason to offer a second rail.

The threshold is not a new number

In 1999, Anil Bokil, a mechanical engineer from Latur, began developing a proposal for restructuring Indian taxation, later promoted by ArthaKranti, the Pune-based organisation he founded and registered in 2004.19 ArthaKranti, “Meet Anil Bokil, the man who gave Narendra Modi the idea of demonetisation,” 22 November 2016. http://www.arthakranti.org/news-events/243-meet-anil-bokil-the-man-who-gave-narendra-modi-the-idea-of-demonetisation As reproduced in a 2017 assessment by the National Institute of Public Finance and Policy, its elements were: withdraw high-denomination currency; abolish the existing tax system except customs duties; replace it with a single banking transaction tax of around 2%, deducted at source; and set ₹2,000 as the limit above which cash transactions would cease to be legal, while leaving cash itself untaxed.20 National Institute of Public Finance and Policy, Tax Research Team, “Evaluation of the Arthakranti Proposal,” June 2017. https://nipfp.org.in/media/documents/An_assessment_of_Arthakranti_proposal_ALvnWec_cUeVXeh.pdf21 ArthaKranti, “What was Arthakranti Proposal to PM Narendra Modi?” http://www.arthakranti.org/news-events/159-what-was-arthakranti-proposal-to-pm-narendra-modi

In 2013, shortly after Modi was named the BJP’s prime ministerial candidate, Bokil presented the proposal to him in Ahmedabad.19 The organisation was later widely described as the intellectual source of the 2016 demonetisation.22 The Caravan, November 2016. https://caravanmagazine.in/vantage/arthakranti-member-government-implemented-demonetisation

Set the two schemes side by side. In both, ₹2,000 is the figure above which value moving through the banking system attracts an ad valorem charge. In both, the charge falls at the point of transfer rather than on income.

The threshold coincidence is exact. It is worth stating plainly and worth not overstating — not least because, as the second objection below sets out, the two schemes treat cash in opposite ways.

The counterargument

The case against this reading

Five objections, in descending order of force.

A merchant discount rate is not a tax, and the distinction is not technical. ArthaKranti’s banking transaction tax was government revenue, shared between central, state and local bodies, and existed to fund the state. The MDR is a private fee among payment participants. On the defining characteristic — who receives the money — the instruments are opposites. Any argument treating this as a step toward a transaction tax must explain how private fee revenue becomes public revenue, and no such mechanism has been proposed by anyone.

The two schemes point in opposite directions on cash. In ArthaKranti’s design, ₹2,000 was a ceiling on cash: above it, cash transactions lose legality and the value is forced into the banking channel, where the levy applies. In the 2026 framework, ₹2,000 is a floor for a digital charge, and cash remains free and unmetered. Taken alone, the present arrangement creates a marginal incentive toward cash — the opposite of the ArthaKranti design. The convergence lies in the treatment of bank-routed value, not in the treatment of cash, and it was the treatment of cash that gave ArthaKranti’s proposal its force.

The charge is additive, not substitutive. ArthaKranti’s levy existed to replace income tax and the rest of the tax system. Nothing has been abolished. GST consolidated indirect taxes in 2017 but did not displace income tax, and is a value-added consumption tax rather than a levy at the point of transfer. The feature that made the proposal radical — eliminating the income tax base — has not occurred and is not proposed.

ArthaKranti disputes the claim of influence. After the 2016 demonetisation, Bokil said the government had taken only one part of the five-point plan, and that his organisation was not responsible for how the policy was implemented.23 Business Standard, 22 November 2016, reporting Bokil’s interview with the Economic Times. https://www.business-standard.com/article/economy-policy/not-just-demonetisation-govt-should-completely-abolish-high-value-notes-anil-bokil-116112200197_1.html A reading that treats subsequent policy as execution of that programme asserts what its authors deny.

₹2,000 has independent justifications. It is a salient round number, it approximates the ceiling below which merchant activity is dominated by the small traders the framework is designed to protect, and it was until 2023 the largest note in circulation. Convergence on a round number is weak evidence of common design.

There is also a serious objection to the competition argument above, and the government makes it. A proportional charge may help small payment service providers more than this brief allows: it gives them a revenue line that does not require a lending book, lowering the capital intensity of entry. The Department of Financial Services argues precisely that the charge will enable more domestic companies to operate on UPI.15 If the binding constraint on competition was the need to own a credit business, MDR relaxes it. Whether that effect dominates the entrenchment effect is an empirical question about entrant economics that cannot be settled from public data.

What survives

This brief does not claim that the 2026 framework implements the ArthaKranti proposal. The evidence does not support that, and the objections above are strong.

What survives is narrower. India’s payments architecture has moved, across a decade, toward a structure with three properties: near-universal routing of retail transactions through auditable channels, declining utility of high-denomination cash, and a small ad valorem charge at the point of transfer above a fixed floor. ArthaKranti described that structure and argued for it on grounds of administrative cheapness and evasion resistance. Those arguments do not become wrong because the programme was not adopted wholesale.

The second objection identifies the one place the present structure leaks: by charging bank-routed value while leaving cash free, it pushes marginal value back toward cash. The only instrument that is both digital and free of charge is the e-rupee. If the structure is to hold without that leakage, it resolves through the central bank rail — which is the effect officials are already reported to expect.

An infrastructure that meters every transaction above ₹2,000 and applies a percentage to it is, mechanically, the infrastructure a transaction tax would require. Building it for one purpose commits no one to the other. It does make the other substantially cheaper to attempt, and it habituates the payer to a per-transaction charge, which is the political cost any such levy would otherwise have to pay up front.

Implications

For NPCI and the Reserve Bank, the question is whether a proportional levy should be introduced before, rather than after, the market-share cap that has been deferred since 2020. Introducing revenue into a concentrated market and then attempting to deconcentrate it is a harder sequence than the reverse.

For merchants in thin-margin, high-ticket categories, the question is whether to accept a second settlement rail. The arithmetic favours it sooner than the headline rate suggests.

For the government, the question is whether the ₹2,000 threshold and the 0.4% rate are settled parameters or an opening position. That distinction is unstated, and since August the statute leaves it to notification. The opposition’s slippery-slope argument draws its force from that combination.

Falsification. This brief argues that the framework entrenches concentration and establishes metering infrastructure with latent fiscal potential. If the 30% market-share cap takes effect on 31 December 2026 without further deferral, and if the combined share of the two largest applications falls below 65% by the end of 2027, the entrenchment argument is wrong. If the 0.4% rate is reduced or the framework withdrawn within eight quarters, the durability argument is wrong. We will record either outcome in this document.

Notes

  1. Press Information Bureau, “UPI Continues to Remain Free for Peer to Peer Transactions and 96% of Merchant Transactions,” 15 September 2026. https://www.pib.gov.in/PressReleaseDetail.aspx?PRID=2310586&reg=48&lang=1
  2. Ministry of Finance, Department of Financial Services, notification S.O. 5067(E), 14 September 2026, issued under section 10A of the Payment and Settlement Systems Act, 2007. Text reproduced at https://taxguru.in/finance/government-charges-upi-payments-exceeding-rs-2-000.html; reported by LiveLaw, https://www.livelaw.in/top-stories/centre-prohibits-charges-on-upi-transactions-up-to-rs-2000-rupay-debit-card-550015
  3. Reserve Bank of India, post on X, 15 September 2026, reported by Business Standard, 16 September 2026. https://www.business-standard.com/finance/news/rbi-backs-mdr-on-large-value-upi-transactions-says-users-will-pay-no-fee-126091600146_1.html
  4. Department of Financial Services, “FAQs: Merchant Discount Rate (MDR) on Select UPI (P2M) Transactions,” September 2026. https://financialservices.gov.in/sites/default/files/2026-09/FAQs---Merchant-Discount-Rate—MDR—on-Select-UPI—P2M—Transactions_0.pdf
  5. NPCI, UPI ecosystem statistics, May 2026. https://www.npci.org.in/product/ecosystem-statistics/upi
  6. NPCI circular extending the compliance deadline to 31 December 2026, reported by PTI, 1 January 2025: https://theprint.in/economy/npci-extends-market-cap-deadline-for-upi-apps-for-another-two-years-till-2026/2426963/; see also Business Today, 31 December 2024: https://www.businesstoday.in/tech-today/news/story/npci-extends-30-upi-market-share-cap-deadline-on-3rd-party-apps-to-december-2026-459171-2024-12-31
  7. Taxation and Other Laws (Amendment) Bill, 2026 (Bill No. 150 of 2026). Amendment text quoted in The Wire, 6 August 2026: https://m.thewire.in/article/banking/lok-sabha-passes-bill-allowing-govt-to-permit-banks-others-to-charge-for-upi-transactions; passage by voice vote without discussion reported by ANI in The Tribune, 6 August 2026: https://www.tribuneindia.com/news/business/lok-sabha-passes-taxation-and-other-laws-amendment-bill-without-discussion-amid-oppositon-protests/amp
  8. Nirmala Sitharaman, post on X, 6 August 2026: https://x.com/nsitharaman/status/2085375889668534421; statement in the Rajya Sabha, 10 August 2026, reported by ANI: https://aninews.in/news/business/parliament-clears-taxation-and-other-laws-amendment-bill-sitharaman-says-no-upi-mdr-for-consumers-small-merchants20260810191208/
  9. Randeep Surjewala, press conference in Bengaluru, 16 September 2026, reported by ANI: https://news.webindia123.com/news/Articles/India/20260916/4499501.html
  10. Jairam Ramesh, post on X, 16 September 2026, quoted in full by ANI: https://www.aninews.in/news/national/pm-redefined-nota-as-narendras-ongoing-trump-appeasement-jairam-ramesh-slams-centre-over-upi-charges-us-tariffs20260916111938/
  11. Rahul Gandhi, posts on X, 15 and 16 September 2026, reported by Outlook: https://www.outlookindia.com/national/have-a-spine-withdraw-upi-charge-rahul-gandhi-slams-pm-modi and https://www.outlookindia.com/national/upi-fee-row-government-hits-back-at-rahul-gandhi-over-upi-tax
  12. Government response, 16 September 2026: https://www.indianeconomicobserver.com/news/imposing-upi-mdr-to-consumers-a-criminal-offence-centre-hits-back-as-opposition-alleges-surrender-to-us-pressure20260916224529/; Supreme Court petition: https://www.theweek.in/news/india/2026/09/16/upi-mdr-fee-govt-refuses-to-back-down-despite-opposition-pressure-matter-reaches-sc.html; parliamentary committee: https://www.outlookindia.com/national/upi-fee-row-government-hits-back-at-rahul-gandhi-over-upi-tax
  13. Office of the United States Trade Representative, 2026 National Trade Estimate Report on Foreign Trade Barriers, March 2026, India chapter. https://ustr.gov/sites/default/files/files/Press/Releases/2026/National%20Trade%20Estimate%20Report%202026.pdf; quoted by CNBC, 17 September 2026: https://www.cnbc.com/2026/09/17/upi-payments-visa-amazon-phonepe.html
  14. USTR, Notice of Action, Section 301 investigation of Brazil, Federal Register, 20 July 2026: https://www.federalregister.gov/documents/2026/07/20/2026-14542/notice-of-action-brazils-acts-policies-and-practices-related-to-digital-trade-and-electronic-payment; Presidential Memorandum of 15 July 2026: https://www.govinfo.gov/content/pkg/FR-2026-07-20/pdf/2026-14654.pdf
  15. Department of Financial Services, post on X, 17 September 2026, reported by ANI: https://english.punjabkesari.com/business/allegation-about-external-pressure-over-mdr-decision-false-and-misleading-says-department-of-financial-services
  16. Business Standard, 16 September 2026, citing the NPCI FAQ. https://www.business-standard.com/amp/finance/personal-finance/upi-mdr-explained-how-new-charges-compare-with-debit-credit-cards-126091600354_1.html
  17. Finance Ministry statement of 15 September 2026, reported by IANS: https://indicanews.com/rbi-says-new-upi-mdr-framework-will-strengthen-digital-payments-ecosystem/
  18. Mint, 16 September 2026, “Fee on UPI may nudge users towards CBDC.” https://www.livemint.com/industry/banking/mdr-on-upi-transactions-e-rupee-cbdc-rbi/amp-11789489693425.html
  19. ArthaKranti, “Meet Anil Bokil, the man who gave Narendra Modi the idea of demonetisation,” 22 November 2016. http://www.arthakranti.org/news-events/243-meet-anil-bokil-the-man-who-gave-narendra-modi-the-idea-of-demonetisation
  20. National Institute of Public Finance and Policy, Tax Research Team, “Evaluation of the Arthakranti Proposal,” June 2017. https://nipfp.org.in/media/documents/An_assessment_of_Arthakranti_proposal_ALvnWec_cUeVXeh.pdf
  21. ArthaKranti, “What was Arthakranti Proposal to PM Narendra Modi?” http://www.arthakranti.org/news-events/159-what-was-arthakranti-proposal-to-pm-narendra-modi
  22. The Caravan, November 2016. https://caravanmagazine.in/vantage/arthakranti-member-government-implemented-demonetisation
  23. Business Standard, 22 November 2016, reporting Bokil’s interview with the Economic Times. https://www.business-standard.com/article/economy-policy/not-just-demonetisation-govt-should-completely-abolish-high-value-notes-anil-bokil-116112200197_1.html

Errors are corrected in place, with a dated note, and logged at /corrections.