The Squirrels
Tuesday, 11 August 2026
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Economy

12,000x Growth in 10 Years. Zero Revenue for Banks. India's UPI Miracle Has a Business Model Problem — and the Fix Could Break What It Built.

By Squirrels·

The Number That Explains the Problem

66 crore. That is how many UPI transactions India processes every single day.

Monthly volumes regularly exceed 2,200 crore transactions. Annual transaction value in FY 2025–26 reached ₹314 lakh crore. UPI now accounts for 85% of India's digital payments and nearly half of all real-time payment volumes globally.

And the banks, payment service providers, and fintech companies that process these transactions earn almost nothing from them.

India has been a global outlier — the only major economy running its dominant retail payment system on a zero-cost merchant acceptance model. No Merchant Discount Rate. No transaction fee. A kirana store in Varanasi and a luxury retailer in Bengaluru both accept UPI for the same cost: zero.

This model produced the most spectacular payment infrastructure success story in modern economic history. It may also be unsustainable. And the government has just moved to change it.


What Changed

Following recent legislative amendments, the government has enabled the introduction of Merchant Discount Rate (MDR) on specified digital payments. The current policy direction:

  • Transactions below ₹2,000: Likely to remain free — protecting small merchants and everyday purchases.

  • Transactions above ₹2,000: Could attract MDR — a small percentage fee paid by the merchant to the payment processor.

Since over 95% of UPI transactions are below ₹2,000, the policy is designed to protect the base while monetising the top. The Finance Minister has clarified that MDR, if introduced, would be borne by merchants, not consumers — though, as the data on card payments globally shows, merchant costs have a way of reaching consumers indirectly.

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The Growth That Made This Inevitable

The trajectory tells the story of why zero MDR worked — and why it can't work forever.

Financial Year

Volume (crore transactions)

Value (₹ lakh crore)

FY 2016–17

2

0.07

FY 2017–18

91.5

1.10

FY 2018–19

539

8.77

FY 2019–20

1,252

21.3

FY 2020–21

2,233

41.0

FY 2021–22

4,596

84.2

FY 2022–23

8,371

139.2

FY 2023–24

13,113

~200

FY 2024–25

~18,000–20,000

~275

FY 2025–26

24,162

314

12,000-fold increase in annual transaction volume in 10 years. Over 4,000-fold increase in transaction value. From 2 crore transactions in FY17 to 24,162 crore in FY26.

Zero MDR made this possible. Every kirana store, chai stall, vegetable vendor, and autorickshaw driver could accept UPI because it cost them nothing. The barrier to entry was a smartphone and a QR code — not a merchant agreement, not a POS terminal, not a transaction fee.

But every transaction costs someone something. The servers, the fraud prevention systems, the cybersecurity infrastructure, the settlement mechanisms, the customer support — all of these cost money. Banks and payment providers have been absorbing these costs, subsidised partly by government incentive schemes worth thousands of crores annually. The question is no longer whether this model is admirable. It is whether it is viable at 66 crore transactions per day and growing.

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The Case FOR MDR: Seven Arguments

1. Financial Sustainability

Zero MDR means zero direct revenue from processing UPI. Infrastructure costs — fraud prevention, cybersecurity, servers, settlement — continue to rise with volume. MDR creates a recurring revenue stream to fund the investment that keeps the system running.

2. Relief for Banks

Banks bear real costs: acquiring merchants, issuing accounts, payment switching, fraud monitoring, customer support. A share of MDR can improve returns on these investments and, critically, incentivise banks to expand merchant acquisition — particularly in underserved rural areas where the cost of onboarding a merchant currently exceeds the revenue that merchant generates.

3. Better Economics for Fintechs

PhonePe, Google Pay, and Paytm have built UPI's consumer-facing layer. Their revenue models rely almost entirely on cross-selling — lending, wealth products, advertising, subscriptions. A modest MDR could diversify revenues beyond financial product cross-selling, making UPI itself a viable business rather than a loss-leader for other services.

4. Most Users Are Unaffected

Since 95% of UPI transactions are below ₹2,000, the vast majority of payments — everyday purchases, small-ticket commerce, peer-to-peer transfers — would remain free. The MDR applies only to the 5% of transactions above the threshold, which are disproportionately commercial (B2B payments, high-value retail, professional services).

5. Consumers Don't Pay Directly

The Finance Minister has confirmed: MDR is a merchant-side fee, not a consumer charge. Consumers will not see a transaction fee on their UPI payments.

6. Government Subsidy Burden Reduces

The government has compensated banks for zero-MDR UPI through incentive schemes running into thousands of crores over recent years. MDR on selected transactions could gradually reduce reliance on fiscal support — freeing public money for other priorities.

7. Aligns with Global Practice

Every major digital payment system in the world — Visa, Mastercard, Alipay, WeChat Pay — charges merchants a transaction fee. India's zero-MDR model is the exception, not the rule. MDR brings UPI in line with global payment economics while maintaining lower rates than international card networks.


The Case AGAINST MDR: Nine Arguments

1. It Could Slow the Adoption That Made UPI Great

UPI's explosive growth was driven by zero-cost acceptance. Kirana stores, street vendors, and micro-enterprises adopted QR payments because there was no cost to accepting them. Any MDR — even 0.2–0.3% — could discourage merchants from accepting UPI, particularly in low-margin businesses. Some merchants may revert to cash.

2. Small Merchants Operate on Razor-Thin Margins

A merchant selling vegetables at 5–8% margin cannot absorb even a 0.3% fee on large transactions without either raising prices or losing money. The ₹2,000 threshold protects most transactions — but a vegetable vendor selling ₹3,000 worth of produce to a restaurant is now above the threshold.

3. Consumers Will Pay Indirectly

Despite the government's assurance, merchants have historically responded to payment acceptance fees by increasing prices, imposing minimum transaction amounts, offering discounts for cash, or discouraging digital payments for larger purchases. This pattern is well-documented in card payment markets globally.

4. Financial Inclusion Could Weaken

UPI has brought millions of small merchants, rural businesses, gig workers, and informal-sector enterprises into the formal digital economy. MDR could disproportionately affect these groups — the ones least able to absorb costs and most likely to revert to cash.

5. Cash Becomes Relatively More Attractive

Cash has no explicit merchant acceptance fee. If digital payments become more expensive — even marginally — merchants may prefer cash. Tax compliance could weaken. Digital transaction records could decline. This runs directly counter to the government's formalisation agenda.

6. Banks Already Benefit from UPI Without MDR

Banks gain indirectly from UPI through higher CASA (Current and Savings Account) balances, increased customer engagement, opportunities to cross-sell loans and insurance, and lower cash handling costs. Some economists argue these indirect benefits justify continued zero-MDR service.

7. Government Savings Outweigh MDR Costs

Digital payments reduce currency printing, cash transportation, ATM replenishment, counterfeit currency circulation, and cash management costs. Some analysts argue these savings — which run into tens of thousands of crores — justify continued government support for zero-MDR as a public investment in economic efficiency.

8. UPI Is Public Digital Infrastructure — Not a Private Payment Network

Unlike Visa or Mastercard, UPI was built as part of India's Digital Public Infrastructure (DPI) — alongside Aadhaar, DigiLocker, FASTag, and the Account Aggregator framework. Charging MDR would treat public infrastructure like a private service. Roads don't charge tolls per kilometre for every user. Public infrastructure absorbs costs to maximise access.

9. India's Global Digital Leadership Could Be Compromised

India processes nearly half of the world's real-time digital payments — largely because UPI is free and interoperable. This positions India as the global model for digital payments. Introducing MDR could reduce the attractiveness of India's payment architecture as a template for other countries — diluting a soft-power asset that no advertising budget could replicate.


The Question the Data Raises but Cannot Answer

Both sides are arguing from real data. The sustainability argument is genuine — you cannot run 66 crore daily transactions on zero revenue indefinitely. The inclusion argument is also genuine — you built the world's most successful payment system by making it free, and pricing it changes the equation that produced the success.

The policy question is whether the ₹2,000 threshold correctly identifies the line between inclusion (below) and sustainability (above). The answer depends on a number nobody has published: what is the actual cost per transaction of processing a UPI payment at current scale?

If the cost is ₹0.05 per transaction, the government's incentive scheme can cover it. If it is ₹0.50, it cannot — not at 24,000 crore transactions per year. The sustainability debate is, at its core, a debate about a number that the RBI, NPCI, and banks have not made public.

Until that number is disclosed, both sides are arguing about a threshold without knowing the cost it is supposed to cover.


Frequently Asked Questions

What is MDR on UPI?

Merchant Discount Rate — a small percentage fee paid by the merchant (not the consumer) to the payment processor for each UPI transaction. India has operated UPI on zero MDR since 2020. Recent legislation enables MDR on transactions above ₹2,000.

Will consumers be charged?

Not directly. The Finance Minister has confirmed MDR is merchant-side. However, merchants may indirectly pass costs through higher prices or cash discounts.

How many UPI transactions are below ₹2,000?

Over 95%. This means the vast majority of everyday transactions remain free under the proposed threshold.

Why did UPI grow so fast?

Zero cost to merchants, interoperability across banks, smartphone penetration, QR code simplicity, and government incentives. From 2 crore transactions in FY17 to 24,162 crore in FY26 — a 12,000-fold increase in 10 years.


The Bottom Line

India built the world's most successful digital payment system on a radical premise: make it free and they will come. They came — 66 crore transactions a day, 85% of India's digital payments, half the world's real-time payment volume.

Now the premise is being modified: make it free for most, charge for some, and fund the system from within. The ₹2,000 threshold attempts to protect inclusion while enabling sustainability. Whether it succeeds depends on a number that has not been disclosed — the actual per-transaction cost — and on a behavioural question that cannot be modelled — whether merchants above the threshold accept the fee or revert to cash.

UPI's first decade was about adoption. Its second decade will be about economics. The two are in tension — and the MDR decision is where that tension becomes policy.