The Localisation Bind
Under the RBI’s data localisation norms, payment system providers must store end-to-end payment transaction data in India to enable regulatory access. For global platforms operating across multiple jurisdictions and payment rails, this can conflict with existing data architectures. The requirements also often intersect with FEMA and anti-money laundering obligations, creating additional compliance considerations.
Our Framework
Ikigai Law works through the letter and intent of the RBI’s data localisation rules, drawing on experience advising on this framework since it was first introduced. We map a platform’s end-to-end data flows and assess what data can be stored, by whom, and where. This produces a compliance strategy that meets the localisation mandate without giving up more operational efficiency than necessary, typically distilled into a practical playbook for the client’s India-facing teams.
Applying It in Practice
We have used this framework for platforms with different architectures. One was a global remittance platform whose data processing was centralised in the UK. Another was a global merchant payments platform connecting merchants to more than 200 local payment methods across card, UPI and cross-border rails. In both cases, the client retained its global processing model where permissible while meeting RBI’s localisation requirements, gaining the regulatory clarity and reduced compliance costs needed to scale in a tightly regulated market. The Ikigai Law team on this matter comprised of Aparajita Srivastava, Astha Srivastava, Sreenidhi Srinivasan and Siddharth Chamarty.
“As payment ecosystems become increasingly global, regulatory compliance needs to be built into technology architecture from the outset. A compliance-by-design approach enables platforms to address localisation requirements early, establish clarity on data flows and responsibilities across jurisdictions, and scale without requiring costly structural changes later.”
— Sreenidhi Srinivasan, Partner (Data)
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