Summary: The Payments Vision 2028 themed “Shaping India’s Payment Frontier” lays out the strategic direction for payments regulation till December 2028. The regulator’s focus is on strengthening accountability among regulated entities, building customer trust, and enhancing the resilience of payment systems. Key proposals include a cyber risk monitoring regime for non-bank PSOs, a Payments Switching Service enabling customers to redirect payments across bank accounts, and interoperability mandates for card networks and TReDS platforms, amongst others.

Given that the Payments Vision 2025 culminated in significant regulatory developments, regulated entities should consider undertaking early impact assessments and engage proactively with the regulator to effectively prepare for the upcoming developments.

The Reserve Bank of India (“RBI”) published the Payments Vision 2028, on March 27, 2025, the eighth in the Payments Vision series, running up to December 2028. Apart from regulated entities such as banks, non-banking financial companies (“NBFCs”) and payment system operators (“PSOs”), it provides guidance to fintechs and payment system support providers/ intermediaries on compliance, technology investment, fraud liability, and market access. 

The Payments Vision 2025 was anchored on the theme “E-Payments for Everyone, Everywhere, Every time (4Es)”. Building on this, the Payments Vision 2028, with the theme “Shaping India’s Payment Frontier”, focuses on deepening trust, reinforcing resilience, and expanding India’s global payments footprint.

Below is a summary of the key proposals and their regulatory impact.

Continued focus: Safe expansion coupled with inclusivity and resilience

The Payments Vision 2025 period produced key regulatory outcomes, including, inter alia, Authentication Mechanisms for Digital Payment Transactions Directions, 2025 (mandating two-factor authentication), and the Master Direction on Regulation of Payment Aggregators, dated September 15, 2025. The Payments Vision 2028 focusses on enhanced safety in digital payments with better user control and inclusivity in existing systems such as Trade Receivables Discounting System (“TReDS”)

What the Vision Brings to the Table

• Safety in Digital Payments: The Payments Vision 2028 moves from reactive incident management to proactive safety architecture. For banks and PSOs, this means expanded fraud liability, mandatory cyber-risk reporting, broader regulatory coverage, and revised cheque security standards.
  • Shared Responsibility Framework: Both the payer’s and the recipient’s bank will share liability for unauthorised transactions. This pushes both sides to invest in fraud detection and respond faster.
  • Cyber Risk Monitoring: A Cyber Key Risk Indicators (“CKRI”) framework will be introduced for non-bank PSOs. The RBI will use it to continuously track, compare, and flag cyber risks across entities.
  • Wider Regulatory Outreach: Moves aimed at bringing centralised payment platforms under the RBI regulation may be initiated; white-label AePS providers may also be regulated.
  • Cheque Security Overhaul: Cheque design and security features will be reviewed to enhance uniformity and fraud prevention. Banks should expect revised standards aimed at further enhancements over the current CTS-2010 standards.

• Cross-Border Payments: The Payments Vision 2028 signals a comprehensive overhaul of cross-border payments infrastructure, aligned with G20 goals. For banks, NBFCs, and PSOs, this means simplified authorisations, enhanced reporting, and a more competitive regulatory environment.
  • Simplified Authorisation: Entities currently require separate authorisation under the Payment and Settlement Systems Act, 2007 (“PSS Act”), and the Foreign Exchange Management Act, 1999 (“FEMA”). A single-window process integrating both may be introduced.
  • RBI Reporting and Review: The RBI will publish periodic reports benchmarking India’s cross-border payments against global standards and will review existing frictions.
  • Payments Database: A centralised, AI-queryable database covering both domestic and cross-border payments data will be built.

• Customer in Control: The Payments Vision 2028 places control of fund flows directly with customers. Banks and PSOs will need to build infrastructure for real-time payment redirection and granular payment-mode controls.
  • Payments Switching Service (“PaSS”): A centralised service will let customers move payment instructions from one bank account to another, making it easier to switch banks, a first step towards inter-operability of bank accounts and account portability.
  • Payment On/ Off Switch: Customers will be able to enable or disable any digital payment mode, including cards, through their bank.

• Re-engineered Innovation: The Payments Vision 2028 retrofits legacy instruments with digital capabilities and standardises entity identification. Banks should prepare for electronic cheque issuance. All regulated entities should anticipate a uniform identifier framework that could reshape KYC and transaction monitoring.
  • Electronic Cheques: The introduction of electronic cheques, combining the benefits of paper instruments with the speed of electronic payments, will be explored.
  • Domestic Legal Entity Identifier (“DLEI”): A single, uniform identifier for non-individual entities involved in transactions will be studied.

• Interoperability and New Entrants: The Payments Vision 2028 pushes for interoperability across card payment systems and TReDS platforms. Siloed, closed-loop infrastructure will no longer be tenable. This may entail re-architecture costs and a shift towards transparent, competitive pricing. Further, the possibility of introducing a new class called Small Payment System Providers (“SPSPs”) will also be explored, which would enable the entry of smaller players into the payments space and foster more competition.
  • Open Card Ecosystem: Developing an interoperable card payments ecosystem will be considered, offering greater choice to cardholders and merchants, smarter tokenisation, and transparent pricing.
  • TReDS Interoperability: The possibility of achieving full interoperability between TReDS platforms will be explored. Additionally, factoring with recourse and discounting of trade receivables for export-oriented MSMEs will also be examined.
  • SPSPs: The recognition of SPSPs operating below prescribed thresholds, without RBI authorisation, may be considered.

Regulatory Action Points

Regulated entities should track the following developments:

#	Regulated Entity	Proposal to Track
1.	Banks	Shared Responsibility Framework; Open card ecosystem; Electronic cheques; PaSS implementation; Payment on/ off switch enablement; DLEI adoption; and Single-window cross-border authorisation.
2.	Payment System Operators	CKRI Framework reporting; TReDS interoperability; DLEI adoption; and Single-window cross-border authorisation.
3.	Card Networks	Open card ecosystem; DLEI adoption; and Single-window cross-border authorisation.
4.	Non-Banking Financial Companies – Factors	TReDS interoperability.

For non-regulated entities such as fintechs, there will be facilities for sandbox testing on a perpetual basis. This may result in better interactions between the regulator and such entities.

Conclusion

The Payments Vision 2028 represents a decisive pivot from enabling digital payment adoption to mandating accountability across the ecosystem. Trust, resilience, and consumer protection (including liability limitation) are no longer aspirational goals; they are the new compliance baseline.

For regulated entities, the message is clear: the regulatory architecture is being redrawn, and its contours would be shaped through consultative engagement going forward. The Vision aligns with the establishment of the Indian Digital Payment Intelligence Corporation as India’s Central Fraud Intelligence Hub, a collaborative fraud-intelligence powerhouse backed by Public Sector Banks, enabling real-time transaction scoring and cross-institution intelligence sharing.

The new Vision document offers potential for entities that have innovation in their DNA. Boards and leadership teams would be well-advised to undertake early impact assessments, re-evaluate technology and compliance budgets, and proactively participate in the RBI’s consultative processes. Entities that treat this Vision as a forward-looking compliance roadmap, rather than a policy document to be revisited upon notification, will be best positioned to navigate the regulatory landscape ahead.

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