Reserve Bank of India (“RBI”) vide its notification on August 21 2019 has permitted the processing of e-mandate on cards for recurring transactions (“Notification”). RBI has put in place various safety measures for card payments including the requirement of additional factor of authentication (AFA), especially for ‘card-not-present’ transactions. With this view in mind RBI earlier in 2011 notified that recurring transactions based on the standing instruction given to the merchant was to be brought within the ambit of AFA.
Keeping abreast with the changing payment needs RBI has permitted e-mandate on cards for recurring transactions with AFA during e-mandate registration, modification and revocation, and also for the first transaction and subsequent successive transactions.
This Notification shall become effective from 1st September 2019, and shall be applicable to all types of cards i.e. debit, credit, pre-paid instruments (PPI) including wallets. Further, the e-mandate arrangement shall be only for recurring transactions and not for a one-time payment. Kindly note that the maximum limit for a transaction under this arrangement is INR2000/- and no charges are levied on the cardholder for availing the e-mandate facility.
CONDITIONS TO BE FULFILLED FOR PROCESSING E-MANDATE ON CARDS FOR RECURRING TRANSACTIONS:
- Registration of card details for e-mandate– The cardholder who wishes to opt for the e-mandating facility shall undertake a one-time registration with AFA validation by the issuer. Further, the registration shall only be complete after all the requisite information is obtained by the issuer. Kindly note that the cardholder at the time of registration is given an option to provide the e-mandate for either a pre-specified value of recurring transactions or a variable value; in case of the latter, the cardholder shall clearly specify the maximum value of the recurring transaction (currently INR2000/- per transaction).
- Processing of the first transaction and subsequent recurring transactions- AFA validation shall be performed for processing the first transaction in the e-mandate based recurring transaction. Kindly note the AFA validation may be combined if the first transaction is being performed along with the registration of e-mandate. Further, any subsequent recurring transaction shall be only performed for those cards which have been successfully registered and for which the first transaction has been authenticated and authorised. Kindly note that the subsequent transitions may be performed without AFA.
- Pre-transaction notification- To mitigate the risk the issuer shall send a pre-transaction notification at least 24 hours to the cardholder. It is at the time of registering for the e-mandate on the card, the cardholder shall be given the option for receiving the notification through SMS, email, etc. In addition, the cardholder is also given a facility to change the mode of receiving the notification. Kindly note that the pre-transaction notification shall inform the cardholder about the name of the merchant, transaction amount, date/time of debit, reference number, and reason for debit. The same information shall be notified for a post-transaction notification. Finally, at the time of a receipt of a pre-transaction notification, the cardholder shall be provided with an option to opt-out of that particular transaction or the e-mandate. Any such opt-out shall require an AFA validation by the issuer.
- Withdrawal of e-mandate- The cardholder shall be given an online facility to withdraw any e-mandate at any point of time by the issuer. However, the exception to this will be a pipeline transaction for which a pre-transaction notification has been communicated to the cardholder and the debit has not been communicated to the cardholder. After an e-mandate is withdrawn the acquirer shall ensure that the merchants on-boarded by them delete all the details including the payment instrument information.
- Dispute resolution and grievance redressal- The issuer shall put in place an appropriate redress system with a clear turnaround time for lodging and resolving the grievances put forward by the cardholder. Further, the card network shall make arrangements to separately identify chargebacks and disputes in respect of e-mandates based recurring payments. Also, it is the responsibility of the acquired to ensure that the merchants fulfil the compliance as laid down in this Notification.