UPI Meta: Can Convenience Coexist with Competition?

Home / Columns UPI Meta: Can Convenience Coexist with Competition? X Legal experts examine whether NPCI's proposed UPI Meta framework complies with the Competition Law. UPI Meta promises faster payments by letting users choose a default UPI app. But could that make it harder for smaller payment apps to compete? Every Unified Payments Interface (UPI) payment today begins with a choice. Merchants offer a common UPI payment option, while customers choose whether to pay through PhonePe, Google Pay, Paytm or another Third-Party Application Provider (TPAP). This model has helped UPI become the world's largest real-time retail payment system. Now, National Payments Corporation of India (NPCI) wants to make payments even simpler. Under the proposed UPI Meta protocol, users would set a preferred UPI app just once, allowing merchants to invoke it automatically for future payments. The objective is to reduce checkout friction and make payments faster. The proposal, however, has met resistance from within the fintech ecosystem. Seven companies - Paytm, BharatPe, CRED, Navi, Kiwi, FamPay and Super.money - have urged NPCI to reconsider the framework, arguing that persistent default settings could reduce consumer choice and strengthen the market position of already dominant players. The concern is not merely about technology but about market structure . With PhonePe and Google Pay accounting for roughly 80% of UPI transactions, according to media reports, critics fear default settings could further entrench their dominance. India is hardly the first jurisdiction to confront the competitive implications of default settings. In the European Commission's Android case , Google was found to have reinforced its market dominance through pre-installation and default status, while Microsoft's Browser Choice commitments recognised that preserving competition required active user choice. Both cases reflected a well-established behavioural reality : users seldom change defaults. Competition law therefore increasingly scrutinises interface design, not merely contractual restrictions, as a source of market power. UPI Meta, however, is different. NPCI is neither prescribing a default application nor favouring any TPAP; users would choose their own. The real legal question is whether the operator of India's digital public infrastructure owes a heightened duty of competitive neutrality when redesigning how millions of users access payment services. That question formed the basis of LawBeat's discussions with Suhail Nathani, Managing Partner at Economic Laws Practice , and Ram Kumar Poornachandran, Senior Partner at AZB & Partners . While both agree that preserving competition remains central to the legal analysis, they approach NPCI's obligations from markedly different starting points. For Nathani, competitive neutrality is inherent to any payment infrastructure built around consumer welfare. He argues that NPCI's responsibility arises not merely because it facilitates UPI transactions but because it operates critical payment infrastructure under the Reserve Bank of India's oversight. NPCI's governance structure, RBI's supervisory powers under the Payment and Settlement Systems Act , 2007, and even its own decision to introduce a 30% TPAP market share cap reflect an institutional commitment to preventing excessive concentration in the UPI ecosystem. Poornachandran, however, begins a step earlier. Before any duty of competitive neutrality can arise, he says, the Competition Commission of India would first have to determine whether NPCI qualifies as an "enterprise" under Section 2(h) of the Competition Act , 2002. That question, he notes, remains untested . If NPCI is treated as an enterprise performing economic functions rather than purely regulatory ones, and if it is found to occupy a dominant position in an essential payment network, Section 4 of the Competition Act would impose a special responsibility not to distort competition, Poornachandran says. The