We rely on consumers using one or more of our services, and are thus vulnerable to changes in
consumer preferences and behaviour that could adversely affect our profitability and financial
condition.

As we rely on consumers using one or more of our services, our business may be affected by
rapidly-changing consumer preferences. Our results of operations depend on our ability to attract
customers by anticipating, gauging and responding to such changes in consumer preferences. We may be
increasingly dependent on consumer preferences, as we intend to pivot from “payment-as-a-service” to
“payment-as-a-convenience”, focus on customer acquisition, and cross-sell VAS to our customers. See
“Our Business — Our Strategies — Pivot from Payments-as-a-Service to Payments-as-a-Convenience
through our Ongo Card and Ecosystem” on page 160. In ascertaining consumer preferences, we may rely
on information furnished to us by or on behalf of merchants, partners and customers. We cannot assure
you that we would be able to receive updated and accurate information, and be able to interpret it
appropriately. If we are unable to anticipate, gauge and respond to changing consumer preferences, or if
we are unable to adapt our services to such changes in a timely manner, we may lose or fail to attract
customers, who may prefer our competitors. This may adversely affect our business, financial condition,
results of operations and cash flows.

The industries in which we operate are highly regulated by the Reserve Bank of India and other
government agencies. Implementation of new regulations or changes to existing laws and regulations
regarding our services could have an adverse effect on our business, results of operations, cash flows
and financial condition.

Our business of supply, installation and maintenance of ATMs is highly dependent on the regulatory
policies framed by the RBI from time to time. The RBI, pursuant to a circular dated June 12, 2009,
permitted banks to open off-site ATMs without RBI approval subject to certain conditions. Any
restrictive change in this policy could adversely affect the industry in which we operate and our
operations. Under certain of our contracts, we are responsible for the ATM site identification and
deployment, installation, ownership and management services for the ATM on behalf of the customer
banks. In the event that the RBI either restricts the banks from utilising the assistance of third parties for
the installation and maintenance of ATMs, or restricts the number of ATMs which can be set up by the
banks, our business, results of operations, cash flows and financial condition could be adversely affected.

In addition, various other aspects of our business, such as our electronic payments infrastructure and
usage of such networks by our banking, retail and petroleum customers, are highly regulated by the RBI
and other government agencies. In December 2017, the RBI rationalized and capped the fees that we are
able to charge merchants for debit card and QR code transactions. Further, pursuant to a circular from the
RBI dated August 10, 2021 which will take effect on October 1, 2021, a penalty of % 10,000 per ATM
will be levied on the relevant bank in the event of a cash-out situation of more than 10 hours in a month
at such ATM, and banks must issue system-generated statements in respect of downtime of ATMs on a
monthly basis. Our Company’s outsourcing and managed services businesses involve maintenance and
management of ATMs, while SVIL provides cash management services including cash replenishment,
cash pick-up, cash-in-transit, cash vaulting and cash processing. If a cash-out situation at an ATM is
caused by us, the relevant bank may seek to recover damages from us, including the recovery of any
penalty paid to the RBI.

Our subsidiary, ITSL, also obtained a PPI authorization from the RBI on May 30, 2014 to issue and
operate semi-closed pre-paid payment instruments as part of its digital payments operations until May 31,
2019. In a letter dated May 21, 2021, the RBI renewed ITSL’s authorisation on a perpetual basis. Under
the applicable RBI regulations, the holder of such authorization is required to comply with various
conditions, including ongoing compliance and reporting requirements. Further, the Gol, pursuant to a
notification dated January 28, 2020, has mandated that all RuPay debit card transactions be free of
charge, and we are therefore no longer able to charge fees on such transactions. We are also required by a
Gol circular dated December 16, 2016 and subsequent notifications by public OMCs to provide a 0.75%
cashless discount to debit card holders on their fuel transactions, which we then require the OMCs to
reimburse. If we are unable to claim such reimbursements in full, our profit margins may be affected.

We may not be able to comply with the relevant regulatory requirements, and the RBI and other
government agencies may impose certain penalties including suspension, revocation or termination of the
relevant approvals in the event of a default by us in complying with such terms and conditions. For
example, on June 30, 2014, we were granted a certificate of registration by the RBI to set up, own and
operate white label ATMs. As part of the conditions of such registration, our Company was required to

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