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India — RBI e-mandate framework for recurring payments

NationalINDerived or secondary source

India

Rule id
subscription.in-rbi-emandate
Version
1.0.0
In force from
October 1, 2021
Last read against its sources
August 5, 2026
Countries bound
India

In plain language

What this regime says.

India is the one place where you can cancel a subscription without the merchant. The RBI e-mandate framework requires your card issuer to let you view, modify and withdraw any recurring mandate, and requires a notification at least 24 hours before every recurring debit with an option to opt out. Once you revoke the mandate, any further debit is an unauthorised transaction with a 10-working-day reversal obligation.

Who is covered

Cardholders and account holders in India with a recurring mandate registered on a card, prepaid instrument or UPI.

What you get

The mandate revoked at the bank rather than the merchant; reversal of any debit taken afterwards within ten working days; and a deficiency-in-service claim against the merchant through the Consumer Commission.

Where claims go wrong

  • Fighting the merchant's cancellation flow when the bank can kill the mandate outright.
  • Not screenshotting the revocation confirmation, which is what makes later debits unauthorised.
  • Missing the three-working-day window for zero liability on the debits that did go through.
The official claim route

Authority

Every citation,
with its pinpoint.

A claim that cites “EU law” gets filed. A claim that cites Article 7(1)(c) gets answered. These are the exact coordinates this entry rests on.
  1. RBI circular DPSS.CO.PD.No.447/02.14.003/2019-20 (21 August 2019) — Processing of e-mandate on cards for recurring transactionsReserve Bank of India, Department of Payment and Settlement SystemsOne-time registration with additional factor of authentication; pre-debit notification at least 24 hours before the debit; facility to withdraw the mandate at any time
  2. RBI circular CO.DPSS.POLC.No.S-518/02.14.003/2021-22 (16 September 2021)Reserve Bank of India, Department of Payment and Settlement SystemsProcessing 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
  3. Reserve Bank — Integrated Ombudsman Scheme, 2021Reserve Bank – Integrated Ombudsman Scheme, 2021
  4. Consumer Protection Act, 2019Consumer Protection Act, 2019 (India)Deficiency in service and unfair trade practice; complaints filed online through the e-Daakhil portal

Sources

Where a figure is indexed, converted or published by a regulator rather than fixed in the instrument, the provenance is recorded separately. Anything marked as a modelled estimate is exactly that — a model, not a statutory number.

What it imposes

Clocks, defences and the ladder.

A rule module builds these while it evaluates, because a limitation period depends on which forum is open to you. What follows is the structure this regime produces — deliberately with no dates and no figures, because those belong to your facts rather than to the law.

The clocks it starts

  • Report the unauthorised debit to the bank (3 working days for zero liability)Under the RBI limited-liability circular of 6 July 2017, notifying within three working days of the bank's communication gives you zero liability. Between four and seven working days the liability is capped by the circular's table; beyond that the bank's Board-approved policy governs.Reserve Bank — Integrated Ombudsman Scheme, 2021Notice period
  • Bank must credit the amount (10 working days) and resolve (90 days)The bank must credit the disputed amount within ten working days of notification, irrespective of the investigation, and must resolve the complaint within 90 days or compensate you as if it had been decided in your favour. (Period: 90 days. We need the start date to work out your exact deadline.)Reserve Bank — Integrated Ombudsman Scheme, 2021Response due
  • Consumer Commission complaint (2 years)Fatal if missedA complaint under the Consumer Protection Act, 2019 must ordinarily be filed within two years of the cause of action, though the Commission may condone delay for sufficient cause.Consumer Protection Act, 2019 — Deficiency in service and unfair trade practice; complaints filed online through the e-Daakhil portalLimitation period

What it entitles you to, beyond money

  • Revoke the e-mandate through your issuerYour card issuer must give you a facility to view, modify and withdraw e-mandates. Use it, take a screenshot of the confirmation, and note the reference. That screenshot is what makes every later debit unauthorised.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
  • Use the 24-hour pre-debit notification to opt outEvery recurring debit must be preceded by a notification at least 24 hours in advance with an opt-out option, for that transaction or for the mandate. If you never received those notifications, that is an issuer failure worth raising in its own right.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
  • Deficiency in service under the Consumer Protection Act, 2019Against the merchant, a refusal to cancel is a deficiency in service and an unfair trade practice. Complaints are filed online through e-Daakhil, cost very little, and do not require an advocate.Deficiency in service and unfair trade practice; complaints filed online through the e-Daakhil portal

What the other side will say

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 likelihood

The 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 likelihood

The 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 likelihood

The 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

Where to take it next

  1. Revoke the e-mandate in your bank's app, then write to the merchantDo the bank step first — it is the one that actually stops the money. Then write to the merchant demanding a refund of anything already taken, and keep both records.Claim directtypically 3 days
  2. Report the post-cancellation debits to the bank as unauthorisedUse the bank's 24x7 reporting channel, obtain the complaint reference and timestamp, and confirm in writing. Demand the credit within ten working days and state that the burden of proving your liability rests on the bank.Claim directtypically 10 days
  3. RBI Ombudsman via the CMS portalFree and online at cms.rbi.org.in once the bank has had 30 days or has rejected the complaint. Failure to provide the mandate-management facility, or to send the 24-hour pre-debit notification, is squarely within the Ombudsman's jurisdiction.Ombudsmantypically 90 daysofficial page
  4. Consumer Commission through e-DaakhilFor the merchant's conduct. The District Commission handles claims up to ₹50 lakh, filing is online and inexpensive, and no advocate is required.Courttypically 270 daysofficial page

Documents

What this regime can produce.

Every one of these is a document you send yourself, in your own name. Duesday never writes to anybody on your behalf and is never anyone’s agent.

The same claim type elsewhere

EU Consumer Rights Directive — withdrawal, order-button and inertia-selling rulesEUSupranational30 countriesDirective 2011/83/EU (Consumer Rights Directive)Confidence: highNorway — Angrerettloven right of withdrawalNONationalNorwayLov om opplysningsplikt og angrerett (angrerettloven), LOV-2014-06-20-27Confidence: highRussia — Consumer Rights Protection Law arts. 26.1 and 32RUNationalRussiaЗакон РФ от 07.02.1992 № 2300-1 «О защите прав потребителей», ст. 32Confidence: mediumSwitzerland — Code of Obligations right of revocation (and the online gap)CHNationalSwitzerlandSwiss Code of Obligations, arts. 40a–40fConfidence: mediumTürkiye — Law 6502 distance contracts and the Subscription Contracts RegulationTRNationalTürkiyeTüketicinin Korunması Hakkında Kanun No. 6502, arts. 48 and 52Confidence: mediumUK Consumer Contracts Regulations 2013 (and the not-yet-commenced DMCCA subscription regime)GBNationalUnited KingdomConsumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013 (SI 2013/3134)Confidence: highCalifornia Automatic Renewal Law (Bus. & Prof. Code §§ 17600-17606, as amended by AB 2863)US-CASub-nationalUnited StatesCalifornia Business and Professions Code §§ 17600-17606Confidence: highCanada — provincial consumer protection acts and the federal Competition ActCANationalCanadaLoi sur la protection du consommateur, RLRQ c. P-40.1 (Quebec)Confidence: medium

Other rights in the same countries

India — DGCA Civil Aviation Requirements, Section 3 Series M Part IVINNationalIndiaDGCA CAR Section 3, Series M, Part IV, Paras 1.2, 1.3 and 1.7Confidence: highIndia — India PostINNationalIndiaPost Office Act 2023 and the Department of Posts rules and compensation scheduleConfidence: lowIndia — IRCTC Ticket Deposit Receipt (TDR) refunds for cancelled and substantially delayed trainsINNationalIndiaRailway Passengers (Cancellation of Tickets and Refund of Fare) RulesConfidence: lowIndia — RBI limited liability for unauthorised electronic banking transactionsINNationalIndiaRBI/2017-18/15 — Customer Protection: Limiting Liability of Customers in Unauthorised Electronic Banking Transactions (6 July 2017)Confidence: highIndia — representative consumer complaints and s.245 Companies Act class actionsINNationalIndiaConsumer Protection Act 2019, s.35(1)(c) and s.2(5)Confidence: lowIndia — security deposit (Model Tenancy Act 2021 where adopted, otherwise State Rent Acts)INNationalIndiaModel Tenancy Act, 2021Confidence: lowIndia — the Clinical Establishments Act rate-display duty and the consumer forum routeINNationalIndiaClinical Establishments (Registration and Regulation) Act, 2010Confidence: lowIndia — unclaimed deposits (RBI DEA Fund and UDGAM) and unpaid dividends and shares (IEPF)INNationalIndiaBanking Regulation Act 1949, s. 26AConfidence: medium

Does this one reach your facts?

The engine runs every regime that could apply at once and reconciles them, rather than making you guess which page to read.

Not a law firm. Not legal advice. You send it yourself. This page describes a law; it is not advice about your situation and no outcome is promised.