By Sandeep Parekh, Managing Partner, Finsec Law Advisors

India’s digital payments revolution has been a story of speed and scale. India today processes over 18 billion United Payments Interface (UPI) transactions a month, accounting for nearly half of the world’s real-time digital payments. While UPI, the crown jewel of the India Stack, has been a core driver of this growth, acceptance infrastructure has been equally crucial in supporting widespread adoption. This includes both offline payment solutions deployed at merchant locations such as QR codes and point-of-sale (POS) terminals and online solutions on e-commerce websites and apps.

Until recently, only online transactions were covered under the Reserve Bank of India (RBI) Guidelines on Regulation of Payment Aggregators and Payme

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