Beginning on October 15, 2026, person-to-merchant (P2M) UPI transactions above Rs 2,000 will be subject to a Merchant Discount Rate (MDR) of 0.4%, while transactions surpassing Rs 75,000 will have a maximum MDR of Rs 300 per transaction. 

This implies that P2M payments up to Rs 2,000 and person-to-person (P2P) transactions would stay outside the MDR charges, according to the National Payments Corporation of India (NPCI). 

A fixed MDR per transaction would apply for transactions above Rs 2,000 for certain merchant categories, including railways, telecom services, insurance, and fuel, among others.

But suppose you have a merchant bill to pay of Rs 6,000; can you simply split the transaction into three Rs 2,000 payments to avoid the Merchant Discount Rate (MDR) charge of Rs 24?

Here’s what customers need to know.

Can a customer legally/technically split a Rs 6,000 UPI bill into three Rs 2,000 payments to dodge the MDR?

The charge that merchants pay banks and payment processors to accept digital transactions is known as the MDR. This fee, which is just a small percentage of the transaction value, has historically covered network, processing, and service fees.

Technically, since the interchange fee on Prepaid Payment Instruments (PPI) merchant transactions applies only to payments above Rs 2,000, splitting a Rs 6,000 bill into three transactions of Rs 2,000 prevents the fee from triggering. 

Therefore, three separate payments of Rs 2,000 each would fall within the zero-MDR threshold, whereas a single Rs 6,000 payment to an eligible merchant would attract MDR of 0.4%, i.e., Rs 24 at the merchant level.

However, this should not be understood as creating a legal entitlement to split every larger purchase merely to circumvent MDR.

“Currently, there is no official daily cap on such splits under National Payments Corporation of India guidelines. However, normal bank-to-bank UPI transfers remain completely free of charges. This splitting strategy is only relevant when using pre-funded wallets or cards at merchants who are subject to these merchant fees,” said Adhil Shetty, CEO, BankBazaar. 

While there is no official daily cap on splitting transactions, doing so repeatedly carries practical risks. 

Automated monitoring systems used by private and public sector banks continuously track transaction patterns for security. Making multiple identical payments in rapid succession to the same merchant can trigger automated fraud-prevention algorithms. 

“This may result in temporary transaction blocks or suspension of UPI services. Additionally, most bank accounts have a standard daily transaction count limit, meaning a consumer could exhaust their allowed daily transfers very quickly,” according to Shetty.

Splitting does not reduce merchant costs; it increases administrative burdens. 

Reconciling three separate transactions of Rs 2,000 instead of one Rs 6,000 payment triples the accounting work. 

“Each entry must be tracked, verified, and settled individually. This raises overhead costs for the business and adds unnecessary processing load to bank servers and payment gateways,” added Shetty.

UPI supports multiple transactions against a commercial purchase, subject to the merchant’s payment acceptance policies and the operational parameters of participating banks and applications. 

“Under the proposed framework, MDR applicability is assessed with reference to the value of an individual eligible UPI transaction. Accordingly, separate transactions of Rs 2,000 each would be evaluated independently. However, merchants may choose whether to permit payment fragmentation based on operational, reconciliation, customer experience, or risk-management considerations,” said Dharmender Jhamb, Partner, Grant Thornton Bharat.

At present, the framework does not explicitly prohibit a customer from making multiple smaller UPI payments towards a single purchase. 

The MDR construct is transaction-centric rather than invoice-centric, meaning that each eligible UPI transaction is assessed on its own merits. 

“Nevertheless, merchants remain entitled to determine the payment methods and settlement processes they are willing to support, including whether multiple transactions may be accepted against a single bill,” according to Jhamb. 

There is also an important consumer perspective: MDR is not payable by the customer in the first place. It is a merchant-side payment acceptance cost. Therefore, ordinarily, there should be no financial reason for a customer to split a Rs 6,000 payment merely to “save” MDR unless the merchants push on to the consumer to either split the transaction or pay the MDR.

Who is ultimately responsible for the MDR, and what should a customer do if a merchant tries to pass it on?

As per the NPCI and Ministry of Finance guidelines, UPI transactions are completely free for consumers. 

Merchants are strictly prohibited from passing any merchant discount rate or transaction charges onto customers. 

If a merchant asks for an extra fee, the consumer should refuse to pay. Customers can report such non-compliant merchants directly through their UPI application or acquiring bank. 

If unresolved, they can escalate the complaint to the digital ombudsman or the National Consumer Helpline for a swift resolution.

“The detailed operational framework for the dedicated small merchant fund will be finalised in consultation with the Reserve Bank of India (RBI) within the next three months,” said NPCI on 15th Sept. 2026.

“That said, there is an important distinction between a customer splitting a payment for genuine reasons—for example, because of a bank limit, use of different accounts or payment convenience—and a merchant systematically structuring invoices or directing customers to fragment payments solely to defeat MDR,” said Prabhat Ranjan, Senior Director, Nexdigm.

The latter could potentially undermine the commercial intent of the framework and may therefore become an area for subsequent NPCI or acquiring-bank guidance.

The safer principle is that the commercial transaction should drive the payment arrangement, rather than the MDR threshold driving the structuring of the commercial transaction.

Can multiple UPI payments on one bill bypass MDR?

A merchant can prescribe reasonable operational conditions for accepting payment—for example, requiring a single payment against a single invoice or declining multiple successive QR payments for the same purchase, subject of course to its contractual arrangements with the acquiring bank/payment aggregator and applicable consumer-protection requirements.

The proposed MDR framework is structured around the value of individual UPI merchant transactions rather than the aggregate value of the underlying purchase. 

As currently outlined, MDR applicability is triggered at the transaction level. The framework does not presently characterize customer-initiated payment splitting as non-compliant behaviour.

The MDR framework is transaction-based and does not presently distinguish between a single payment and multiple payments used to settle the same commercial transaction. 

MDR applicability is determined with reference to each individual eligible UPI transaction. 

“The fact that UPI permits multiple transactions does not necessarily give a customer a right to insist that a merchant accept an invoice through several smaller payments. Merchants may also have legitimate accounting, reconciliation, refund and fraud-control reasons for insisting on one payment against one invoice,” stated Ranjan.

However, what a merchant should not do is convert MDR into a customer surcharge. The Government has expressly clarified that MDR is a cost within the merchant-payment ecosystem and is not a charge on the customer; banks have also been advised to ensure that merchants do not pass MDR on to consumers.

“Therefore, a merchant may reasonably say, “This invoice must be settled through one transaction,” but charging the customer an additional amount described as the UPI MDR would be a materially different proposition,” according to Ranjan.

Consequently, the framework does not currently provide any specific restriction on payment splitting, nor does it prescribe any separate treatment for transactions that form part of a larger purchase. Any future guidance on this aspect would be subject to regulatory or network-level clarification.

The broader take-away

The Rs 2,000 threshold currently operates at the transaction level, so splitting may be technically possible. But that should not be confused with a recognised MDR-avoidance mechanism. If repeated transaction-splitting becomes widespread, this is precisely the kind of behaviour for which the ecosystem may eventually introduce aggregation rules or other anti-circumvention controls.

Disclaimer: This article is for informational purposes only and should not be construed as investment, financial, tax, or legal advice. Any illustrations, examples, or return projections used in this article are for explanatory purposes only and do not guarantee actual investment outcomes. The views and opinions expressed by experts quoted in this article are their own and should not be considered investment recommendations. Readers should consult a qualified professional before making any financial decisions. 

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