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How the layers fit together
“Financial infrastructure” here means systems that help people and institutions pay, share financial information with consent, and settle financial-market transactions. India’s initiatives address different parts of that work, so they are not direct alternatives to one another.
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| Layer | Primary function | Main users | Status in the cited official material |
|---|---|---|---|
| UPI | Payment interface | People, businesses and participating payment providers | Operating payment system |
| Account Aggregator (AA) | Consent-based financial-data exchange | Individuals and participating financial institutions | Operating framework |
| Retail e₹ | Digital central-bank money for retail use | Public, through participating providers | RBI pilot |
| Wholesale e₹ | Central-bank-money settlement for selected financial-market uses | Regulated financial institutions | RBI pilot use cases |
The distinction matters: a payment interface moves payment instructions, an e₹ wallet holds a digital form of rupee, an AA facilitates permitted data sharing, and wholesale CBDC experiments concern settlement between financial institutions.
UPI and the digital rupee do different jobs
The RBI describes the digital rupee, or e₹, as a digital form of the rupee and says it is a central-bank liability and legal tender. It is held in an e₹ wallet. UPI, by contrast, is a means of payment. In the RBI’s words, “e₹ is a digital form of ₹ whereas UPI is a means of payment.” See the RBI’s digital rupee FAQ, updated 1 October 2026, and its 2023–24 Annual Report.
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Can an e₹ wallet use a UPI QR code?
Yes. The RBI says an e₹ wallet can scan a UPI QR code, but that does not make the payment an e₹-to-e₹ transfer. A payment made through a UPI QR follows UPI settlement timelines; a payment between e₹ wallets using a CBDC QR settles between those wallets. The QR is a way to initiate payment, not proof that both payment routes use the same settlement mechanism.
What is live for retail e₹?
The RBI FAQ describes retail issuance, distribution and usage as a live pilot through participating banks and non-banks. It includes person-to-person and merchant transactions. The same FAQ lists 19 banks offering retail CBDC wallets as of its 1 October 2026 update; that is a dated list of providers, not a claim that every bank or customer can access the pilot.
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The RBI also describes programmable CBDC for funds restricted by conditions such as purpose, expiry, location or merchant category. Offline functionality is being explored; the FAQ does not establish universal offline availability. In its 2024–25 Annual Report, the RBI said e₹ had been used as a payment channel for around 88,000 beneficiaries under Odisha’s Subhadra Yojana. That is a specific programme use, not a measure of general retail adoption.
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A tokenised asset is a financial instrument represented in tokenised form. In the RBI materials, tokenisation appears in defined wholesale CBDC pilot use cases; it should not be read as a synonym for cryptocurrency or as evidence that the public can broadly buy tokenised securities through a new marketplace.
Wholesale e₹ use cases named by the RBI
- Secondary-market settlement of government securities.
- Interbank lending and borrowing in the call-money market.
- Tokenised issuance and settlement of certificates of deposit and corporate bonds.
These are pilot use cases, not confirmation of a mature, open market or widespread commercial adoption of tokenised deposits or bonds. The RBI’s stated rationale is that central-bank money can act as a settlement anchor for tokenised financial markets.
What the RBI is exploring
The RBI’s 2024–25 Annual Report names offline use, programmability, cross-border transactions and asset tokenisation among CBDC pilot directions. It says bilateral cross-border pilots were being actively explored. Its FAQ also describes a CAT Sandbox intended to foster innovation across retail, wholesale, cross-border and asset-tokenisation domains. These statements indicate areas of experimentation, not a final design or general availability.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Account Aggregator is the data-sharing layer
Account Aggregators are regulated entities that enable financial information to be transferred between participating institutions based on a person’s instruction and explicit consent. Registration is voluntary. AA is neither a payment instrument nor a tokenised security: it addresses how financial data can be shared with permission.
The Department of Financial Services describes the AA framework as having 179 Financial Information Providers and 989 Financial Information Users, with more than 2.88 billion enabled accounts and 284.6 million linked accounts as of 31 March 2026. These are framework reach measures, not transaction totals or counts of unique institutions using every capability. An earlier Ministry of Finance release dated 2 September 2025 reported more than 2.2 billion enabled accounts and 112.34 million users who had linked accounts; the figures use different snapshots and measures.
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The Ministry of Finance frames AA as a data-exchange layer that complements Aadhaar identity and UPI payments. In practical terms, identity, payment and data-sharing infrastructure can support connected financial services, but they remain separate systems with distinct permissions and functions.
Is India’s next-generation financial infrastructure already built?
India has built significant components, but the evidence supports a picture of connected layers at different stages—not a completed, unified system. UPI and AA are operating frameworks; retail and wholesale e₹ remain pilots, and tokenised-market applications remain bounded to specified experiments and use cases.
The RBI’s FAQ, updated 1 October 2026, does not provide a complete nationwide retail e₹ rollout timetable. The official sources cited here also do not establish a final broad tokenised-asset market design or full commercial deployment of tokenised certificates of deposit and corporate bonds. The RBI’s earlier CBDC Concept Note is useful for understanding design choices such as account-based and token-based forms, but it is foundational context rather than proof of the final architecture.
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