Navigating the Regulatory Landscape: A Deep Dive into RBI’s Master Directions on Prepaid Payment Instruments Post Paytm Restrictions

February 7, 2024
Paytm Payments Bank

By Rupin Chopra and Shantam Sharma

Introduction:

In a significant move, the Reserve Bank of India (RBI) has recently imposed strict restrictions[1] on Paytm Payments Bank, raising concerns about regulatory compliance and breaches of norms. Effective from March 2024, these restrictions not only impact Paytm but also bring to the forefront the regulatory framework governing Prepaid Payment Instruments (PPIs) in India. This article aims to explore the Master Directions on PPIs[2] issued by the RBI in 2021, shedding light on the broader context and implications for the digital payment landscape.

The Paytm Saga:

The RBI’s action against Paytm Payments Bank encompasses five key restrictions[3], prohibiting the acceptance of deposits, credit transactions, and top-ups in customer accounts, prepaid instruments, wallets, FASTags, and National Common Mobility Cards after February 29, 2024. While interest, cashbacks, and refunds may still be credited, the accounts will be limited to withdrawals or utilization only. The embargo also extends to various banking facilities, such as bill payments and UPI transactions, where Paytm has established a significant presence.

One of the primary reasons behind these stringent measures was the discovery of hundreds of accounts on Paytm Payments Bank lacking proper identification. These accounts, with insufficient Know-Your-Customer (KYC) processes, were involved in transactions worth crores of rupees, raising concerns about potential money laundering. Notably, over 1,000 users were found to have linked the same Permanent Account Number (PAN) to their accounts. The compliance discrepancies discovered during audits and verification processes further fueled the RBI’s decision.

RBI’s Master Directions on Prepaid Payment Instruments:

This crackdown on Paytm Payments Bank serves as a catalyst for delving into the regulatory measures set by the RBI to govern Prepaid Payment Instruments (PPIs) in India. The RBI exercised its powers under Section 18, read with Section 10(2) of the Payment and Settlement Systems Act, 2007, to issue the Master Directions on Prepaid Payment Instruments in 2021. This regulatory framework aims to provide a structured approach to the authorization, regulation, and supervision of entities issuing and operating PPIs in India.

Understanding PPIs:

PPIs, as defined in the Master Directions, are instruments facilitating the purchase of goods, services, financial services, and remittance facilities against the stored value. The directions categorize PPIs into the following types.

  1. Closed System PPIs[4]:
    • Issued by an entity for the purchase of goods and services solely from that entity.
    • Prohibits cash withdrawal and restricts use for third-party transactions.
    • Exempt from RBI approval and regulation.
  2. Prepaid Payment Instruments [5]:
    Further classified into Small PPIs and Full-KYC PPIs based on the level of customer verification.

    1. Small PPIs:
      • Issued by banks and non-banks with minimal customer details.
      • Limited to the purchase of goods and services without funds transfer or cash withdrawal.
      • Usable at specific merchant locations under contractual agreements.
    2. Full-KYC PPIs:
      • Issued after completing Know Your Customer (KYC) procedures.
      • Enables various transactions, including the purchase of goods, services, funds transfer, and cash withdrawal.

Eligibility Requirements for Banks and Non-Banks[6]:

Banks seeking to issue PPIs must comply with eligibility criteria set by the RBI, including those stipulated by the respective regulatory department. Approval from the RBI is a prerequisite for issuance. Furthermore, non-banks, regulated by any financial sector regulators, must adhere to specific eligibility criteria and obtain authorization from the RBI under the Payment and Settlement Systems Act. To streamline the process, these non-banks are required to apply to the DPSS, CO, RBI, Mumbai, along with a ‘No Objection Certificate’ from their respective regulator, within 30 days of obtaining clearance.

Safeguards Against Money Laundering[7]:

Recognizing the critical need to curb money laundering, the Master Directions incorporate KYC/AML/CFT guidelines issued by the RBI. Entities issuing PPIs are mandated to adhere to the Prevention of Money Laundering Act, 2002, and its rules. To ensure transparency, PPI issuers must maintain transaction logs for a minimum of ten years, subject to scrutiny by the RBI or other designated agencies. Additionally, filing Suspicious Transaction Reports (STRs) with the Financial Intelligence Unit-India (FIU-IND) is obligatory.

Conclusion:

The RBI’s recent actions against Paytm Payments Bank underscore the regulator’s commitment to maintaining the integrity and security of the financial system. Against the backdrop of these restrictions, the Master Directions on Prepaid Payment Instruments play a pivotal role in shaping the regulatory landscape for digital payments in India. By delineating clear categories of PPIs, establishing eligibility criteria for banks, and incorporating robust anti-money laundering safeguards, the RBI seeks to foster a secure and transparent digital payment ecosystem. As the digital payment sector continues to grow, adherence to such regulatory frameworks becomes imperative for ensuring consumer trust, financial stability, and the prevention of illicit activities in the digital financial space.

[1] Available at: https://www.cnbctv18.com/finance/paytm-payments-bank-rbi-crackdown-the-inside-story-18970171.htm

[2] Available at: https://m.rbi.org.in/Scripts/BS_ViewMasDirections.aspx?id=12156

[3] Available at: https://www.thehindubusinessline.com/money-and-banking/rbi-bars-paytm-from-offering-banking-services-effective-march-2024/article67797411.ece#:~:text=to%20this%20podcast.-,Paytm%20Payments%20Bank%20will%20not%20be%20allowed%20to%20accept%20deposits,refunds%20may%20be%20credited%20anytime.

[4] Regulation 2.1 of Master Directions on Prepaid Payment Instruments (PPIs) (Updated as on February 10, 2023)

[5] Regulation 2.8 of Master Directions on Prepaid Payment Instruments (PPIs) (Updated as on February 10, 2023)

[6] Regulations 3 and 4 of of Master Directions on Prepaid Payment Instruments (PPIs) (Updated as on February 10, 2023)

[7] Regulation 6 of of Master Directions on Prepaid Payment Instruments (PPIs) (Updated as on February 10, 2023)

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