Fintech 2026

INDIA Law and Practice Contributed by: Shilpa Mankar Ahluwalia, Purva Anand and Ansh Jain, Shardul Amarchand Mangaldas & Co

Shardul Amarchand Mangaldas & Co Amarchand Towers, 216 Okhla Phase III Okhla Industrial Estate Phase III New Delhi Delhi 110020 India Tel: +91 11 4060 6060 Email: connect@amsshardul.com Web: www.amsshardul.com

1. Fintech Market 1.1 Evolution of the Fintech Market

• create bilateral linkages between UPI and the pay - ment systems available locally in offshore jurisdic - tions; • power QR-code enabled payments by Indians to merchants abroad; and • extend India’s UPI technology to nations without their own instant payment infrastructure. UPI QR payments are now active in close to eight countries including Singapore, the UAE, Bhutan, France and Sri Lanka. The Reserve Bank of India (RBI) has also collaborated with the Bank for International Settlements and central banks of four ASEAN coun - tries under Project Nexus to enable retail cross-border payments, interlinking domestic payment systems of India with those of Malaysia, Philippines, Singapore and Thailand. The limits for cross-border payments through UPI Global are the same as UPI’s domestic payment limits (ie, typically INR100,000). RBI pilot for tokenisation of certificates of deposit The RBI announced a pilot to tokenise certificates of deposit as part of its wholesale central bank digital currency (CBDC) initiative. This pilot builds on the RBI’s broader conceptualisation of the Unified Mar - kets Interface (UMI), which will have the capability to tokenise financial assets and enable settlements using wholesale CBDC. The initiative aims to facilitate real- time settlement of interbank trades and demonstrates the RBI’s growing comfort with token-based instru - ments in the financial markets. Based on information available in the public domain, the RBI is also explor -

India is the third largest and fastest growing fintech market globally. India’s fintech sector has a combined market capitalisation of about USD120 billion. On the consumer side, Indians are the most open to adopting fintech solutions as evidenced by a fintech adoption rate of about 87%, which is significantly higher than the global average of 64%. India’s invest - ments in digital public infrastructure (DPI) and favour - able demographics are the key drivers behind the growth of the Indian fintech sector. The Past 12 Months Over the past 12 months, several key developments have contributed to significant growth in the fintech sector. UPI Global India’s United Payments Interface (UPI) has enabled seamless, affordable digital payments throughout India, which has been revolutionary for the fintech sector. UPI’s growth has been extraordinary, with the platform handling approximately 21.6 billion transac - tions (valued at INR27.96 lakh crore) in December 2025 alone. Over the last year, NPCI has actively taken UPI off - shore. Through NPCI International Payments Limited (NIPL), NPCI’s dedicated wholly owned subsidiary, NPCI has entered into global collaborations to:

356 CHAMBERS.COM

Powered by