NPCI's UPI Mandate Validity for General Payments and Consent Management

The National Payments Corporation of India (NPCI), an Indian public sector entity, owned by the Reserve Bank of India, has significantly empowered Indian citizens over the years. In the past decade, NPCI's diverse initiatives and services have revolutionised digital payments for individual and retail users across India.

Among the diverse services, NPCI provides "UPI Autopay," a feature that allows users to automate recurring payments from their bank accounts using UPI. While, this is a helpful method to settle payments there is an area that probably needs attention. 

UPI Mandate Validity

According to a circular NPCI/UPI/OC-123/2021-2022 (archived copy), the merchants are advised to create the recurring payment mandates with a maximum validity of 30 years from the start date, a mandate widely followed by the services. 

We have tried the autopay options of several popular services. The following table shows the UPI mandate duration for some of these, including OTT platforms—

Merchant	Autopay Duration	Autopay Check
Discovery+	10 Years	Image
Gaana	15 Year	Image
JioHotstar	30 Years	Image
Netflix	30 Years	Image
SonyLiv	10 Years	Image
Tata Play	13 Years	Image
The Times of India+	10 Years	Image

Our review of various products and services show a fixed mandate duration of 10–30 years. There is no option for customising this mandate. Groww, an asset management company states— "The AutoPay duration is set to 30 years to ensure a smooth repayment experience." 

We can categorise an auto-payment into two categories—

1. Loans and Obligations (Existing Products): Autopay mandates for ongoing financial obligations such as housing loans, personal loans, and car loans, where a user avails the service first, and gradually makes payments.
2. General and Usage-Based (Flexible Services): Autopay for services where payment is tied to usage. Both the merchant and the user can terminate the service at any point.

Now—

While a 30-year mandate might be justifiable for long-term obligations like loan repayments. For simple services such as OTT subscriptions a forced 10 or 30 year UPI mandate seems excessive. Although users can cancel these subscriptions anytime, there should be an option for customized consent.

Suggestions

We suggest to categorise payments as "Payment First, Service Later" (PFSL) and "Service First, Payment Later" (SFPL). We could also classify them as "Obligation" and "General," or based on the total payment amount.

For PFSL, especially simple subscriptions,  any mandate exceeding 5 years is unnecessary. Importantly, users must have an option to customize the mandate duration for the payments.

This could be implemented with a "minimum" and a "suggested" mandatory duration. For example, if "ServiceA" sets a 10-year mandate with a 2-year minimum, during activation, users should be able to customise the duration to any period between 2 and 10 years.

"I wanted a simple OTT subscription,
and they want a 30 years' promise."

Conclusion

The suggested consent management option will be in alignment with the Data Empowerment and Protection Architecture (DEPA) bill. More importantly this will enable users to make more informed decisions about their subscriptions and payments.