Each of these is a refusal this regime lets a counterparty attempt, paired with the answer to it. Reading them before you write is worth more than any amount of polish on the letter itself.
"You must cancel with the merchant, we cannot help"
high likelihoodThe bank refers the customer back to the subscription provider.
What answers it
The RBI framework requires the issuer to provide a facility for the cardholder to view, modify and withdraw e-mandates. A bank that refuses is not following the circular. Ask for that refusal in writing and take it to the RBI Ombudsman — it is a clean, well-defined complaint.
RBI circular CO.DPSS.POLC.No.S-518/02.14.003/2021-22 (16 September 2021) — Processing of recurring transactions: pre-transaction notification, the cardholder's right to opt out of a particular transaction or of the mandate, and the additional-factor-of-authentication requirement above the exemption limit
"You authorised the recurring payment when you subscribed"
high likelihoodThe merchant relies on the original mandate registration.
What answers it
The framework expressly provides that the cardholder may withdraw the mandate at any time, and that each pre-debit notification must offer an opt-out. Authority once given is not irrevocable, and a debit after withdrawal is unauthorised.
RBI circular CO.DPSS.POLC.No.S-518/02.14.003/2021-22 (16 September 2021) — Processing of recurring transactions: pre-transaction notification, the cardholder's right to opt out of a particular transaction or of the mandate, and the additional-factor-of-authentication requirement above the exemption limit
"Notifications are not required for small amounts"
medium likelihoodThe issuer or merchant says the debit was below the authentication limit so no notice was due.
What answers it
The exemption limit governs whether a fresh additional factor of authentication is needed. It does not remove the pre-debit notification requirement, which applies to recurring debits generally and must be sent at least 24 hours in advance with an opt-out option.
RBI circular CO.DPSS.POLC.No.S-518/02.14.003/2021-22 (16 September 2021) — Processing of recurring transactions: pre-transaction notification, the cardholder's right to opt out of a particular transaction or of the mandate, and the additional-factor-of-authentication requirement above the exemption limit