Competition Law Challenges In India’s Digital Payment Ecosystem: Dominance, Interoperability, And Regulatory Overlaps
- IJLLR Journal
- May 9
- 1 min read
Abhinav Chaudhary, LL.M. (CB&IL), Amity University, Noida
ABSTRACT
India has not just become a global leader in digital transactions through its Unified Payments Interface (UPI) as its primary network; India has also advocated for a digital economy that is plausible for developing or underdeveloped countries. UPI has processed 15 billion transactions in a month in 2026. UPI has also advanced the challenges of financial inclusion by overcoming the traditional banking hurdles that plagued the Global South. The rapid scaling of UPI in India has brought commensurate competition law challenges. Monopolization concerns in the UPI ecosystem (PhonePe, Google Pay, and Paytm), despite being horizontally integrated, aren’t its only challenges. The Competition Commission of India (CCI), the Reserve Bank of India (RBI), and the Digital Competition Bill (DCB), to name a few, have brought a plethora of regulatory weirdness to the UPI system, especially with the disjointed nature of UPI interoperability. This paper uses a doctrinal approach (as a lens) and combines regulation, comparative frameworks, the United States, and the European Union, to enforce a set of competition-law and jurisprudential framework regulation guidelines. The paper identifies regulatory black holes for network, data, and inter-regulatory effects. The paper also advocates for further regulation of the digital payment ecosystem in India, in addition to the enforcement of competition law, by setting a minimal threshold of systemic relevance for intermediary digital payment frameworks to Mandate inter and intra data ecosystem sharing.
Keywords: Competition Law; Digital Payments; UPI; Market Dominance; Interoperability; FinTech Regulation; Big Tech Platforms; Regulatory Overlaps.
