INDIA Law and Practice Contributed by: Shilpa Mankar Ahluwalia, Himanshu Malhotra and Purva Anand, Shardul Amarchand Mangaldas & Co
UPI Global Through NPCI International Payments Limited (NIPL), NPCI’s dedicated wholly-owned subsidi - ary, NPCI has entered into global collaborations to: (i) create bilateral linkages between UPI and the payment systems available locally in offshore jurisdictions; (ii) power QR-code enabled pay - ments by Indians to merchants abroad; and (iii) extend India’s UPI technology to nations with - out their own instant payment infrastructure. The NPCI International Payments NIPL is expected to expand UPI Global to ~40 jurisdictions. The limits for cross-border payments through UPI Global are the same as UPI’s domestic payment limits (ie, typically INR100,000). ULI The Unified Lending Interface (ULI) is a technol - ogy platform developed by a subsidiary of the RBI – the RBI Innovation Hub (RBIH) – to stream - line digital lending by enabling seamless access to authenticated data from multiple sources. ULI simplifies the integration process for lenders, eliminating the need for individual connections with diverse data sources such as government authorities, fintech and techfin players, account aggregators, credit bureaus, and digital identity systems. Dubbed the “UPI of digital lending” , ULI facili - tates frictionless credit delivery, reduces opera - tional costs, and enhances efficiency. Since its pilot launch on 17 August 2023, ULI has facili - tated disbursement of loans worth INR270 bil - lion as of 6 December 2024, with 36 regulated entities (REs) onboarded. Streamlined KYC processes On 6 November 2024, the RBI introduced amendments to the Master Direction - Know Your Customer (KYC) Direction, 2016 (KYC Master Directions). The KYC Master Directions
require REs to allot a unique customer identifi - cation code (UCIC) to each customer. Further, once a customer’s data is uploaded to the Cen - tral KYC Registry (CKYCR), they are allotted a KYC Identifier – a 14-digit unique identification code allocated by the CKYCR. The amendments to the KYC Master Directions include two key changes. First, for undertaking the identity verification of a customer (whether at the first instance of establishing an account- based relationship, or at the update/periodic update stage), the RE must first seek the KYC Identifier from the customer or retrieve it from the CKYCR. They can then proceed to obtain the KYC records from the centralised registry. A customer will not be required to submit the same KYC records or any other additional identifica - tion documents, except in the limited circum - stances prescribed (the information retrieved being incomplete/invalid, any change in cus - tomer’s details, etc). The amendments to the KYC Master Directions have also added the concept of “updates” , encouraging REs to ensure the real-time accu - racy of CDD documentation. Furthermore, any updated KYC information from a customer must be submitted to the CKYCR within seven days of receipt. The CKYCR will subsequently notify all REs that have interacted with the customer regarding such updates and require them to revise their records accordingly. By maintaining updated centralised records and encouraging REs to first utilise the informa - tion from the centralised records before asking customers for further documents, the amend - ments to the KYC Master Directions are making KYC data accessible across REs and reducing duplication/friction in the customer onboarding process.
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