ARCHIVES
VOL. 12, ISSUE 2 (2026)
Competition law challenges in India’s digital payment ecosystem: Dominance, interoperability, and regulatory overlaps competition law
Authors
Abhinav Chaudhary
Abstract
India’s digital payment landscape, largely
propelled by the Unified Payments Interface (UPI), has witnessed remarkable
expansion, processing over 15 billion transactions per month as of early 2026
and significantly advancing financial inclusion. However, this rapid growth has
also given rise to critical competition law concerns, including the market
dominance of a few major players such as Phone Pe, Google Pay, and Pay tm;
persistent challenges in achieving full interoperability despite UPI’s design;
and substantial regulatory overlaps involving the Competition Commission of
India (CCI), the Reserve Bank of India (RBI), and emerging frameworks such as
the Digital Competition Bill (DCB). This research paper adopts a doctrinal
approach, integrating theoretical perspectives, an extensive literature review,
comparative regulatory analysis of the EU and the US, detailed case studies,
and judicial interpretations to examine these issues. It identifies key
enforcement gaps related to network effects, data concentration, and
inter-regulatory conflicts. The study aims to propose a robust and coherent
regulatory framework that balances the promotion of competition with the
preservation of innovation. Key recommendations include the introduction of
ex-ante obligations for systemically significant digital intermediaries
(SSDEs), mandatory data-sharing mechanisms, enhanced coordination among
regulatory authorities, and structural reforms of the National Payments
Corporation of India. Drawing on international best practices, the paper
advocates for proactive regulatory intervention to prevent the entrenchment of
oligopolistic market structures and to ensure the long-term sustainability of
India’s digital payments ecosystem.
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Pages:228-232
How to cite this article:
Abhinav Chaudhary "Competition law challenges in India’s digital payment ecosystem: Dominance, interoperability, and regulatory overlaps competition law". International Journal of Law, Vol 12, Issue 2, 2026, Pages 228-232
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