Updated 10 November 2026. A plain-language guide for business owners and product teams, not legal advice. Check the details with your payment aggregator, bank and the RBI website.
Short answer: the RBI's Digital Payments – E-mandate Framework, 2026 puts all rules for recurring card, UPI and wallet (PPI) payments in one place. Customers register a mandate once with additional factor authentication (AFA). After that, recurring debits up to ₹15,000 can run without AFA, every debit needs a notice at least 24 hours before, customers can opt out or cancel at any time, and you cannot charge them a fee for the mandate. If you sell subscriptions, memberships, EMIs or monthly plans online, your checkout and billing system has to support all of this.
What the framework is
The RBI issued the consolidated directions on 21 April 2026 under the Payment and Settlement Systems Act, 2007, and they took effect immediately. They replace eight older circulars on e-mandates issued between 2019 and 2024, including the 2021 framework for recurring online transactions and the 2022 change that raised the no-AFA limit to ₹15,000. A detailed summary is available on TaxGuru, and law firms such as Economic Laws Practice have published their own notes.
The directions apply to payment system providers and participants (banks, card networks, UPI apps, wallet issuers and payment aggregators). Merchants are not regulated directly, but the RBI requires acquirers to make sure the merchants they onboard comply. In practice, your payment aggregator will reject or block flows that do not follow the rules.
The rules at a glance
| Area | What the framework says |
|---|---|
| Registration | One-time registration with AFA plus the issuer's normal checks. Each mandate must carry a validity period. |
| First debit | Needs AFA. It can be combined with registration. |
| Later debits without AFA | Up to ₹15,000 per transaction. Up to ₹1,00,000 for insurance premiums, mutual fund subscriptions and credit card bill payments. |
| Above the limit | AFA is needed for each debit. |
| Amount type | Fixed or variable. Variable mandates have an RBI-set overall cap, and the customer can set a maximum per debit. |
| Pre-debit notice | At least 24 hours before the debit, with merchant name, amount, date and time, mandate reference and reason. |
| Post-debit notice | Merchant name, amount, date and time, transaction and mandate references, reason and grievance redressal details. |
| Opt-out and cancellation | Customer can skip one debit or withdraw the whole mandate at any time, validated with AFA. |
| Charges | No fee can be charged to the customer for the e-mandate facility. |
Who should pay attention
- SaaS and software subscriptions billed monthly or yearly by card or UPI AutoPay.
- Gyms, coaching centres and schools that collect fees automatically. See our school management software page for how fee collection fits into a wider system.
- OTT, news and content apps with auto-renewal.
- Lenders and NBFC partners collecting EMIs through mandates.
- D2C brands running subscribe-and-save plans.
What this means for your product
1. Plan around the ₹15,000 line
If a plan is priced above ₹15,000 per debit, every renewal needs the customer to authenticate again. That causes drop-offs. Many businesses break a large annual fee into monthly debits under the limit, or send a payment link for the yearly renewal instead of relying on AutoPay. Decide this in your pricing, not after launch.
2. Show the mandate details clearly at signup
The customer is agreeing to the mandate's amount type, maximum value and validity. Your checkout page should state the plan amount, frequency, start date and how to cancel, in plain words, before the AFA step.
3. Make your debit schedule match the 24-hour notice
The issuer sends the pre-debit notice, but your system decides when the debit is presented. Your billing engine should present debits on a predictable schedule and keep the reason text short and recognisable (for example "Monthly plan – March 2027"). A vague reason invites disputes.
4. Handle opt-outs and cancellations as normal events
Customers can skip one debit or cancel the mandate from their bank or UPI app. Listen for the aggregator's webhooks, mark the subscription correctly, stop access when the paid period ends and send a friendly message with a manual payment option. Do not keep retrying a cancelled mandate.
5. Don't add a mandate fee
No charge can be levied on customers for using the e-mandate facility. If you were adding a "card autopay fee", remove it.
6. Keep grievance details ready
The post-debit notice must include grievance redressal details, and issuers need a dispute system. Make sure your support email, phone and refund policy are easy to find in the app and on invoices, so customers come to you before they raise a chargeback.
Build checklist for your billing system
- Plan catalogue with amount, frequency and a flag for plans above ₹15,000.
- Mandate record per customer: status, type (fixed or variable), maximum amount, validity end date, aggregator reference.
- Scheduler that presents debits on fixed dates and logs every attempt.
- Webhook handling for success, failure, skip (opt-out) and revoke.
- Dunning flow: reminder, payment link, grace period, then pause.
- Card reissue: the framework allows mandates to be mapped to a reissued card, so check with your aggregator that this is enabled instead of asking customers to sign up again.
- Invoices that match the debit amount and carry GST details. Our GST billing software checklist covers this.
- Reports: active mandates, failed debits, churn after opt-out, mandates expiring in the next 30 days.
Related rules to read with this
The e-mandate framework refers to the RBI's authentication directions and the payment aggregator master direction. Our post on the RBI two-factor authentication rules for digital payments explains the authentication side, and our UPI MDR charges guide covers what merchants may pay per UPI transaction.
Need a subscription billing system?
Nextinera builds SaaS products and payment gateway integrations with recurring billing, mandate tracking and GST invoices built in. Book a free call to talk through your plan structure.