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Indian online merchants cannot store credit card information from 2022

rbi.org.in

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Re: Indian online merchants cannot store credit card information from 2022

#51

Is the RBI deliberately trying to handicap credit cards in India? The decision to make recurring payments impossible, followed by having to enter card information every time I do an online transaction is making for a very frustrating experience. The justification for these decisions is always "consumer interest" but how is making consumers jump through hoops to do transact online in consumer interest? I wish the indu…

Yes this is stupid and it has caused me a lot of trouble since this all started. I am now seriously thinking of leaving this country and going to NZ or Canada (something which I did not want to do because of my parents). Doing business in India is so frickin hard, especially after GST. I have to spend so much time on accounting nowadays and it's getting harder and harder every day (even though all the ads say otherwi…

Please understand the context behind the rules before ranting.

PayPal restrictions exist because india doesn't have free capital account convertibility and forex providers need to implement regulatory mechanisms to comply with forex regulations. The regulations on forex haven't changed in many years. It's paypal who isn't bothered to comply with mechanisms implemented and hence removed those features as they felt customers like you aren't worth it to them.

Most developing countries have capital controls like India for financial stability reasons and removing it for the sake of small segment of entrepreneurs feeling difficulty to process some payments or can't manage the accounting is not in the interest of the state or it's people.

Stripe thinks you are worth it to them and are providing that service. Find better service providers. Talk to a bank.

As far as GST is concerned, every country has tax accounting. Some other countries like in Europe have it way worse on the paperwork. Have you ever dealt with pre-GST service tax or VAT paperwork? Accounting is a universal thing and it's the reality of doing business.If you think just by jumping one country to the other you can avoid taxes or paperwork you need to rethink your approach to business. Most countries who don't have taxes or tax paperwork are just tax havens living off someone else's money. Will you go to NZ/Canada and not do their tax paperwork?

If it's getting harder, maybe your size is large enough to hire an accountant to do that work for you.

If you have so many customers overseas maybe you better incorporate a foreign subsidiary or an IFSC subsidiary to manage USD transactions.

These rules won't be changed for you - there are larger socio economic reasons for the rules.

Re: Indian online merchants cannot store credit card information from 2022

#52

Something I learned in college - not all countries have the same laws as the US where it's easy to dispute a charge and the burden of proof is with the merchant. If India is one of those places where the burden of proof is on the customer, and it's difficult to dispute charges, it makes sense to tokenize things.

Yes. On forums and online IM groups you'd find plenty of people suggesting "raise a chargeback" without realising it means nothing in India. It's just a gesture. Merchant can just deny the charge back and that's it, your credit card provider is done you are charged.

Re: Indian online merchants cannot store credit card information from 2022

#53

I'm interested to know what level of "cannot store" the info is implemented? Or is it mediated by a 3rd party company / algorithm that sanitizes the data but to a certain amount that some association can still be done? For example, can the customer's credit card be anonymized but still tracked to know that the same credit card is used on 2 different transactions, for example? E.g. if I wanted to give the customer onl…

For card-linked offer constructs you can infer the issuer based on first 4 digits (bin number) and actually store last 4 digits and name on card.

Re: Indian online merchants cannot store credit card information from 2022

#54

Is the RBI deliberately trying to handicap credit cards in India? The decision to make recurring payments impossible, followed by having to enter card information every time I do an online transaction is making for a very frustrating experience. The justification for these decisions is always "consumer interest" but how is making consumers jump through hoops to do transact online in consumer interest? I wish the indu…

Yes this is stupid and it has caused me a lot of trouble since this all started. I am now seriously thinking of leaving this country and going to NZ or Canada (something which I did not want to do because of my parents). Doing business in India is so frickin hard, especially after GST. I have to spend so much time on accounting nowadays and it's getting harder and harder every day (even though all the ads say otherwi…

> Doing business in India is so frickin hard, especially after GST.

How has GST made things worse? I had paid Service Tax for 10 years prior to GST, and that was a far worse experience.

a) Prior to GST these was an enormous amount of tax fraud. GST makes that way harder, on account of people being able to track and claim input credits. Many (not all) people who were complaining did so because they were suddenly unable to dodge taxes. This forced them to disclose all sales, which affected income tax as well.

b) Everything is now visible on the portal. Who you paid, what they deposited etc.

c) Initially, there were many more compliance requirements. Now it's simpler, with quarterly filing if you qualify.

Re: Indian online merchants cannot store credit card information from 2022

#55
Disclosure: I work for a fintech in India, specialized in card payment.

It seems here people see this rule as "merchants can't store card numbers any more". This is actually a lot more than that, this is the new rule: you cannot store card numbers for recurring payment. Even if you are PCI-DSS compliant. Even if you are audited by the RBI. Even if you're sponsored by a bank. The only way to store a Visa number is to use the Visa tokenization service.

Now if you know a bit of the card payment industry, you will know that you need the card number just to process the payment, the refund, etc. So you still have to store the card number. And you can. You just can't use it for recurring payment any more.

My personal take: Giving full control to Visa and Mastercard over their card numbers for recurring payment seems to be a nice transfer of power to these two giants. But the time scale has been very short (a few months only). So practically, most recurring card payments will stop working or be illegal in two weeks. This is will more or less break existing subscriptions working with cards.

India (the RBI at least) has been in a campaign for independence in the payment infrastructure. American Express[0], Diners[1], Mastercard[2] have been banned in India. Diners' ban has been lifted now, but still. Rupay is a failure with a market share of 0.34%[3] (in comparison UPI is at 37.73%), in spite of having ZERO MDR on debit transactions[4].

This change is not for the sake of security. You can have the best firewalls, cutting-edge HSM, security team and pass 12 audits a year. You will be allowed to save these card numbers but you won't be able to authorized to use it for recurring payments. This is just a move against cards, and to promote UPI instead. By making recurring card payment a hindrance, more people will transition to UPI.

[0] https://www.americanexpress.com/en-in/company/notice/rbi-imp... [1] https://www.reuters.com/article/india-banking-american-expre... [2] https://westfaironline.com/138440/mastercard-banned-from-new... [3] https://www.npci.org.in/PDF/npci/statics/RETAIL-PAYMENTS-STA... [4] https://economictimes.indiatimes.com/opinion/et-editorial/st...

Re: Indian online merchants cannot store credit card information from 2022

#56

Earlier quoted context omitted.

To use card tokens for any kind of payment, you need to integrate with some kind of card data vault, which this rule seems to also prohibit. It seems to be instructing the card brands to issue unique tokens for ever cardholder + merchant pair. No idea how that would work…

> To use card tokens for any kind of payment, you need to integrate with some kind of card data vault, which this rule seems to also prohibit. Why would you need that? The rule says nobody can store "actual card data". If you're using the token for a new payment, you don't retrieve the card number, you use the token directly. > It seems to be instructing the card brands to issue unique tokens for ever cardholder + me…

That number needs to be mapped to the PAN, and somebody has to have stored that PAN somewhere in order for it to be used to process payment. This rule says nobody other than the issuer and the card brands are allowed to store the PAN.

Re: Indian online merchants cannot store credit card information from 2022

#57
post #30
post #19

This is actually a good thing. Think of it like Apple's email masking service - Merchants can only store a tokenized version of your credit card instead of the real card details. I say this is a good thing after having worked with many E-Commerce shops in India as a consultant. Most of them barely know a thing about security, let alone about PCI DSS compliance. I have worked with shops that stored the entire credit c…

That's a weird generalization. Yes there are terrible, insecure e-commerce sites in India, the same as there are in the USA and everywhere else on the planet. India is also the top 7-8 e-commerce market in the world. Large local apps in the space have valuations in the tens of billions of dollars, and all major global players like Amazon and Walmart are involved in the country as well. These $100B in annual sales are…

> That's a weird generalization. Yes there are terrible, insecure e-commerce sites in India, the same as there are in the USA and everywhere else on the planet.

I don't have the experience to know if this is actually the case, but it seems completely plausible that different countries have different regulations (or enforcement thereof) such that US companies have to care about PCI more than Indian companies.

> These $100B in annual sales aren't processed by script kiddies, it's a very large and mature industry.

Those are less connected than you think; loads of companies run obscenely large monetary transactions and essential business processes with horrifying hacked-up systems (50k LoC files, 20-year-old Perl scripts that nobody understands, Solaris 2.x desktop in the maintenance closet...); utility and good code are less correlated than we wish.

Re: Indian online merchants cannot store credit card information from 2022

#58
post #30

Earlier quoted context omitted.

That's a weird generalization. Yes there are terrible, insecure e-commerce sites in India, the same as there are in the USA and everywhere else on the planet. India is also the top 7-8 e-commerce market in the world. Large local apps in the space have valuations in the tens of billions of dollars, and all major global players like Amazon and Walmart are involved in the country as well. These $100B in annual sales are…

Yes, but large valuations don't correlate with better security practices.. Obviously the person above isn't talking about Amazon or Walmart when referring to "script kiddies". Of the nearly 45-50 contract jobs I've seen, a lot of them use pirated WP or Magento plugins, and plain text storage of sensitive content.

Again, generalization. What you're talking about mostly refers to small time sites with maybe not more than few dozen orders a day. Typical ecommerce businesses (usually the kind with at least 100s or 1000s of orders a day) write their own code rather than using WP plugins.

As far as PCI DSS goes, there are multiple levels. Even at the tier 2 Indian ecom company I used to work at, we did not store any card info, it was just submitted in an iframe rendered by the payment gateway. And even then we were subjected to annual/semi-annual security audits (this was in addition to quarterly external security audits we ordered ourselves apart from typical OWASP top 10 checks performed by QAs in weekly sprints).

Re: Indian online merchants cannot store credit card information from 2022

#59
I see the US Model as "Optimistic". Let the transactions through and fight back fraud with a strong chargeback mechanism.

Whereas the Indian Model is "Pessimistic". Put in as much checks as possible to reduce the rate of fraud before the transaction has even completed.

Thoughts?

Re: Indian online merchants cannot store credit card information from 2022

#60
post #55

Disclosure: I work for a fintech in India, specialized in card payment. It seems here people see this rule as "merchants can't store card numbers any more". This is actually a lot more than that, this is the new rule: you cannot store card numbers for recurring payment. Even if you are PCI-DSS compliant. Even if you are audited by the RBI. Even if you're sponsored by a bank. The only way to store a Visa number is to…

I don't agree with your interpretation on this being a stealth tactic but even if this was one it's just the state institutions acting in the interest of their mandate. This might not be beneficial to you employer or Visa or MasterCard or few high flying credit card users of the super rich class but it is in the interest of the people.

If they think it's time to move beyond cards due to the strategic overdependence on foreign service providers like Visa who can disrupt the Indian financial system at the behest of their US govt or other interests it's the right thing to discourage them directly or indirectly.

Think in the interest of the people. WTO commitments are not worth the paper they are written on. State should do the right thing to benefit the people as a whole not worry about inconvenience to a few people or few middle men or foreign companies.

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