Apple, Sony, Google, Zoom, PayPal and several other tech companies as well as scores of banks have cautioned customers and partners in India to expect a surge in declined transactions as the world’s second-largest internet market’s central bank enforces a new directive for the way recurring payments are processed in the country.
The Reserve Bank of India’s directive, which goes into effect on Friday, requires banks, financial institutions and payment gateways to obtain additional approval for auto-renewables transactions worth over 5,000 Indian rupees ($67) from users by conducting notifications, e-mandates and Additional Factors of Authentication (AFA). The directive impacts all such transactions for debit cards as well as credit cards.
The directive, which was first unveiled in 2019, was scheduled to go into effect in April this year but was extended to September 30 after banks and other players said they were not fully prepared to comply.
India’s central bank was not amused by the way the industry handled its directive, saying in March that “any further delay in ensuring complete adherence to the framework beyond the extended timeline will attract stringent supervisory action.”
The Reserve Bank of India said in the original circular in 2019, that the framework was designed to serve as “a risk mitigant and customer facilitation measure,” adding that the issuer processing such transactions “shall send a pre-transaction notification to the customer, at least 24 hours prior to the actual charge by SMS or email, as per the customer’s preferences.”
Several companies have reminded their customers and in some cases, other business partners, about the new directive.
On Wednesday, Apple reminded developers that due to the new directive, “some transactions that don’t meet these requirements will be declined by banks or card issuers.”
HDFC, the largest private bank in India, has posted the following message on its website: “Please note: Effective 1st Oct 2021, the Bank will NOT approve any Standing Instruction (e-Mandate for processing of recurring payments) given at Merchant Website / App, on HDFC Bank Credit card/Debit Card, unless it is as per RBI compliant process.” Several banks, including HDFC, Axis and Kotak have said this week that they will be complying with the new rule.
In May this year, Google stopped on-boarding new recurring payment customers on its Play Store. The company told developers that free trials and introductory pricing should be removed from the apps until "the ecosystem challenges are addressed." YouTube has moved to support only a prepaid -- pay as you go -- payments acceptance model for its Premium service.
In the same month, Amazon said it was "temporarily" discontinuing new member sign-ups for Amazon Prime free trial until further notice. There hasn't been any change to that notice since.
After making payments simpler, we need to make recurring & subscription payments easy ⚡️
It’s a pain to use any subscription product in India, not all cards work and random rules at banks 😵💫 pic.twitter.com/tBrsoBOopx
— pj (@BeingPractical) September 30, 2021
The directive doesn't impact recurring payments made through UPI, a payments infrastructure built by a coalition of retail banks. Which explains why some firms -- including Netflix -- have added support for auto-pay on UPI in the country.
But its impact is likely to be far-reaching. A fintech founder told TechCrunch that the payments provider they use to advertise on Facebook and Google had informed them that their automatic-payments won't be processed starting later this week, citing the central bank's rule. The founder requested anonymity to discuss what he deemed to be sensitive.
The new rule is the latest in a series of guidelines the Indian central bank has proposed or enforced in recent years. As Pratik Bhakta outlines in a post on The CapTable, the moves illustrate that though the regulator has encouraged the proliferation of fintech startups that are innovating for users, the RBI is closely watching whether any trend is attempting to hurt those consumers.
“Until legislation catches up, regulation has to adapt to ensure that the financial system absorbs digital innovation in a non-disruptive manner,” said RBI Deputy Governor T Rabi Sankar at a conference earlier this week. “We would only be able to reach a thriving and mature payments system if, over time, all stakeholders attach due importance to long-term improvements over short-term gains and internalise mature practices like informed consent and transparency of data usage.”
In emails to PlayStation Plus subscribers on Thursday, Sony said, “From 30 September 2021, you may see your credit and/or debit card payments for PlayStation Plus fail when trying to pay for a subscription on PlayStation Store.”
“This applies to both new subscription purchases and payment of recurring subscription fees. This means that any future PlayStation Plus subscription fees set up to be charged automatically may fail. If that happens, your PlayStation Plus subscription will come to an end.”