On 09 April 2026, the Reserve Bank of India released the “Discussion Paper, Exploring safeguards in digital payments to curb frauds” (hereafter “Discussion Paper”).
The Discussion Paper emphasizes the prevalence of social engineering fraud which continue to successfully cheat unsuspecting users out of money, despite there being system-level controls. The Discussion Paper focuses on making the digital payment landscape safer especially for those who may be more vulnerable to these ploys. It proposes four very specific interventions that seek to introduce positive friction in the payment value chain, allowing remitters some time to reconsider their payment decisions and hopefully breaking their ‘hot state’ of decision making.
In this response, we present our comments to the paper. We divide our comments into three sections.
Section I: Offers a principle-level framework to reconceptualise fraud as a complex adaptive system (CAS) This reframing renders important lessons for the type of policy interventions that may be more effective than others in curbing fraud despite their resilient, ever-evolving nature.
Section II: Unpacks each intervention proposed in the Discussion Paper. We discuss why each intervention may not work.
Section III: Concludes with a ‘model’ mechanism that may bring enduring progress in dealing with fraud in the Unified Payments Interface (UPI) but also other aspects of the economy.
Read the full response here
