RBI’s ‘Payments Vision 2028’ ushers structural re‑ design of ecosystem

The Reserve Bank of India (RBI) recently released ‘Payments Vision 2028’ that marks a shift from scale‑building to structural re‑design of India’s payments ecosystem.

For most of the existing payment operators, the document is neither hostile nor neutral — it is conditionally supportive, while clearly signalling greater regulatory control over networks, data, and economics.

The vision document is constructive toward card payments and creates policy space for several long-standing priorities of the payment sector. At the same time, it signals closer scrutiny of card ecosystem economics, tokenisation frameworks, and cross-border competitive dynamics. The outcome will depend less on the headline document and more on how underlying measures are designed. Early engagement is critical.

It seeks to build an open and interoperable card ecosystem with emphasis on merchant choice, smart tokenisation and orchestration, and transparent pricing. The proposed shared responsibility framework would make both the issuer and beneficiary bank jointly liable for unauthorised digital payment transactions.

The document outlines reforms in the cross-border payments system. The RBI is likely to publish dedicated cross-border payments reports, conduct a comprehensive ecosystem review and streamline cross-border authorisation processes.

Payment operators

The vision document calls for innovation in card payments. This creates policy space for continued development of tokenised payment models, contactless and embedded experiences, stronger authentication and fraud controls and card-linked innovation aligned with security, inclusion, and efficiency objectives.

It supports continued investment in card-led innovation in India and provides a stronger basis for engagement on tokenisation, credential security, and newer card-based use cases.

A more open and interoperable card ecosystem is the principal strategic watchpoint. The vision’s intention to reimagine card payments through a more open and interoperable ecosystem is the most strategically-significant card-related theme in the document.

It signals future focus on merchant and consumer choices, transaction orchestration, tokenisation standards, portability of payment relationships, pricing transparency and pressure on closed or proprietary models.

This could develop constructively if interoperability is implemented in line with global standards and strong security principles. However, if interpreted more aggressively, it could have direct implications for interchange economics, routing economics, and control over network token standards. 

In particular, greater emphasis on pricing transparency could over time create pressure for closer scrutiny of interchange and related economics, while a broader interoperability agenda could create risk if India were to move toward network-agnostic or locally-defined token standards rather than globally-aligned token frameworks.

This is therefore both an opportunity for engagement and a longer-term structural risk that should be monitored closely.

Cross-border payments reform

Cross-border reform is the clearest policy opportunity and a strategic competitive watchpoint. The vision commits to a holistic review of the cross-border payments framework, simplification of regulatory friction, single-window authorisation, where both the Payment and Settlement Systems, Act, and the Foreign Exchange Management Act (FEMA) approvals are required; stronger reporting on cost, speed, transparency, and volumes and alignment with global standards and best
practices.

This directly aligns with several long-standing digital payments priorities in India, including licensing clarity, process simplification, more coherent treatment of international payment flows and better interoperability with global frameworks.

At the same time, this should also be viewed through a competitive lens. RBI’s broader cross-border agenda could support the expansion of UPI-linked bilateral arrangements and account-to-account payment corridors, which may over time place pressure on portions of traditional card-based cross-border flows.

This is therefore the area where the vision offers the most-immediate opportunity to support constructive reform, while also requiring a clear view of where payment operators’ cross-border value-proposition must remain differentiated.

Fraud liability reform

RBI proposes examining a shared responsibility model for unauthorised digital payment transactions rather than maintaining a purely issuer-centric framework. This aligns directionally with a more risk-based approach to fraud accountability across participants. It may create an opening to revisit how responsibility is allocated across issuers, acquirers, merchants, and networks. At the same time, implementation will need careful management to avoid misalignment between RBI requirements and existing scheme-level dispute and chargeback rules. This has potentially significant legal, operational, and commercial implications and warrants early review.

Cyber resilience

The proposed Cyber Key Risk Indicator framework for non-bank payment system operators signals a move toward more continuous, data-driven supervision. RBI’s broader emphasis on analytics and AI-enabled oversight also points to increasing expectations around data quality, transparency, and reporting frequency. However, India may require more granular local reporting, country-specific key risk indicators, more frequent operational and incident disclosures and enhanced governance and supervisory readiness. The Vision also signals possible lighter-entry pathways for smaller or emerging payment providers, broader oversight of critical ecosystem participants and greater regulatory attention to platforms influencing payment flows or acceptance.

These changes may ultimately help level the regulatory playing field, particularly if currently unregulated actors are brought under more formal oversight. However, there is also a risk of temporary asymmetry if newer participants can scale under lighter obligations before full regulation applies.