On October 13, 2026, NPCI’s UPI and Services Steering Committee deferred the merchant discount rate on select UPI payments. Citing the festive season, it said the MDR will be implemented “immediately post Diwali at a date to be notified separately.” The fee structure itself didn’t change. Since mid-September we’ve written about this policy as a festive-season merchant-behaviour question, and in our first piece we described October 15 as a natural before-and-after boundary inside the season. That boundary is gone. What replaces it is arguably a better research opportunity, but only for brands that act before the new date is announced.

What Changed and What Didn’t

Reports on October 8 said the steering committee was weighing a deferral to January 1, 2027 and a much wider small-merchant exemption of up to Rs 40 Lakh in annual turnover. NPCI’s actual decision is shorter than the January date, and the statement quoted in coverage doesn’t mention the wider exemption, so brands shouldn’t assume it is settled. The exact start date is still to be notified, and whether the exemption threshold is widened has not been confirmed.

What the Trader Pressure Did and Didn’t Achieve

Earlier this month, we wrote about the October 2 “No UPI Day” protest splitting along merchant lines after a meeting with the Finance Minister. The asks that came out of that meeting included a deferral until after the festive season, exclusion of merchant-to-merchant payments, and a higher small-merchant threshold. A deferral has now happened, tied to Diwali. The other two asks have no confirmation. NPCI cited the festive season as its reason, and we can’t say how much the trader campaign contributed. What we can say is that the policy’s final shape was moving until two days before launch, which is what the earlier post cautioned about.

Why the Post-Diwali Start Matters for Research

The original comparison, a payment-cost regime changing mid-season, no longer exists. In its place, the MDR will start shortly after Diwali on November 8, during what coverage describes as a busy festive and wedding period. That changes two things.

• October and early November are now a clean baseline. Payment mix, average ticket size, and basket composition recorded now reflect behaviour with no MDR in force. Once the date is notified, every brand and channel partner that didn’t capture this baseline will be comparing the new regime against memory.
• The before-and-after will happen during peak shopping, not before it. Any change in payment behaviour will be mixed with seasonal demand, wedding purchases, and year-end buying, so a comparison needs to be designed with that in mind rather than read off the raw numbers.

Two Forecasts, Neither of Them Observed

Public estimates of the MDR’s impact currently disagree. A Local survey estimated that UPI transaction volumes could fall 4% and value 10% as consumers shift to cards, cash, and bank transfers if merchants pass the cost on. The RBI Governor has said a small MDR on select payments is unlikely to materially affect volumes. These aren’t observed outcomes: one is a stated-intention survey estimate that depends on a pass-through assumption, and the other is a policy view. Neither tells a brand what its own merchants will do, and the deferral means there is still no real behaviour to read.

What to Do Before the Date Is Announced

• Capture a payment baseline now, split by ticket size above and below Rs. 2,000, since the fee only applies above that line.
• Record merchant acceptance practices today. How prominently QR codes are displayed, whether any cash incentives exist, and whether larger purchases are split are all easier to compare against a documented starting point.
• Segment merchants by size and by how they were treated under the exemption, so the post-notification read isn’t blended across very different merchants.
• Watch the notification closely. The start date and any change to the small-merchant threshold determine which of your channel partners are affected, and neither is final until NPCI notifies it.
• Keep consumer-side tracking alongside merchant research. The rules bar a customer surcharge, so any consumer-facing change is likely to show up as friction, steering toward other payment methods, or price revisions, not an explicit fee.

The Bigger Point

A last-minute deferral can look like the end of a story. For research, it’s closer to a reset: the behaviour change that was going to be observed mid-season will now be observed after it, with a baseline that is available now and won’t be later. The brands that benefit are the ones that treat the next few weeks as the pre-period of a study, not a pause.

If you want merchant-side or channel research on payment behaviour before and after the MDR starts, talk to our research team at Maction. Or email us at info@maction.com