Definition
Digital Public Infrastructure (DPI) refers to a set of open, interoperable, and population-scale digital systems, typically developed or mandated by the state, that function as shared foundational infrastructure for the delivery of public and private services on non-discriminatory terms. DPI is distinguished from proprietary platform ecosystems by its open standards, public interest orientation, and universal accessibility.
In competition law, DPI functions as a structural countervailing mechanism against platform monopolisation by lowering barriers to entry, reducing switching costs, and constraining the ability of dominant private entities to leverage infrastructure control into market power in adjacent markets.
Origin
The term “Digital Public Infrastructure” gained prominence during the late 2010s and early 2020s through the work of international organisations, governments, and policy institutions. In 2023, during India’s G20 presidency, member states arrived at a global consensus on the definition and principles of DPI.1 That same year, the United Nations also identified DPI as a high-impact initiative for achieving the Sustainable Development Goals.2
In India, the concept is significantly influenced by the India Stack initiative, which describes itself as “a collection of open APIs and digital public goods” designed to enable identity verification, payments, and data exchange at a population scale.
Legal and Institutional Framework
OECD’s Approach to DPI
The Organisation for Economic Co-operation and Development (OECD) conceptualises DPI within the broader framework of digital government transformation. The OECD views DPI as a critical component of the “Government as a Platform” model, wherein governments provide reusable digital building blocks that enable both public and private actors to develop innovative services.3
The OECD identifies several core benefits of DPI, including efficiency, interoperability, scalability, resilience, innovation, and improved user experience. It further highlights the importance of human-centred design, robust data governance, privacy-by-design, cybersecurity safeguards, and multi-stakeholder collaboration in the development and deployment of DPI systems.
Quad Principles on DPI
The Quad Principles on Digital Public Infrastructure provide a shared normative framework for the development and deployment of DPI among the United States, Australia, India, and Japan. The Quad defines DPI as a set of shared digital systems that are secure, reliable, interoperable, and jointly leveraged by public and private actors to improve service delivery, promote inclusion, foster innovation, and support economic development.4
Significantly, the Quad framework recognises that DPI must be governed by an appropriate legal framework and regulations that ensure fair competition and protection of fundamental rights. While DPI enhances access to services and economic opportunities, safeguards are needed to prevent surveillance, exclusion, and abuse of power.
Core Principles of DPI
The G20, Quad, and OECD have converged on a common set of principles governing DPI design and deployment:
Inclusivity – DPI must reduce economic, social, geographic, and technological barriers to participation and encourage universal access.
Interoperability – DPI shall promote the use of open standards and common protocols that enable seamless interaction across platforms, services, and jurisdictions.
Modularity and Scalability – DPI must be designed in a modular architecture that accommodates system changes and growth without necessitating wholesale redesign of existing infrastructure.
Privacy, Data Protection and Cybersecurity – DPI must incorporate essential technologies and security elements designed to protect individual privacy and data protection in the system core design.
Governance for Public Benefit, Trust, and Transparency – DPI systems must be governed in a manner that ensures safety, security, and accountability, fosters public trust, and promotes fair competition in the digital marketplace.
Notwithstanding these recognised principles, there is no comprehensive codified legal framework presently governing DPI either in India or internationally. Instead, India’s DPI ecosystem is regulated through a fragmented framework: digital identity infrastructure is governed by the Aadhaar (Targeted Delivery of Financial and Other Subsidies, Benefits and Services) Act, 2016, while issues relating to personal data processing and digital governance are addressed through the Digital Personal Data Protection Act, 2023, and the Information Technology Act, 2000.
Illustrations of DPI
The following illustrations demonstrate the transformative role of DPI in strengthening digital governance, financial inclusion, and public service delivery in India:
Unified Payments Interface (UPI)
UPI has made retail payments completely digital. It allows for real-time, interoperable, and secure transactions between customers and merchants, with no delays involved. It facilitated 21.70 billion transactions with a value of more than ₹28.33 lakh crore in January 2026, showcasing its extensive role in daily business transactions across India.5
DigiLocker
Launched in 2015, it was a secure digital document wallet for citizens. It enables consent-controlled access to, storage, and sharing of authenticated electronic documents. There are currently 67.63 crore DigiLocker users as of 5 March 2026. As of March 2026, over 950 crore documents have been issued via the platform, establishing it as a key part of public administration in India.
UMANG (Unified Mobile Application for New Age Governance)
UMANG is a unified single-window mobile and web application launched in 2017 to access services of central, state, and local government bodies. Citizens can avail various services on UMANG, and it saw 10.25 crore user registrations and 723.36 crore transactions. The portal is an important channel of communication between citizens and the government, offering access to over 2,400 services.
Role of DPI in Competition Law
DPI as an Ex-ante Competition Tool
It reflects a change in the traditional competition law paradigm in terms of principles of interoperability, openness, and accessibility in the establishment of digital markets. DPI is an ex-ante mechanism that aims to solve structural barriers before the concentration of the market, rather than intervening remedially after dominance has been established. When digital infrastructure becomes a common resource rather than a proprietary asset, market actors are no longer compelled to rely on dominant platforms, enabling broader participation, greater innovation, and enhanced consumer welfare.
Reducing Entry Barriers and Enhancing Market Contestability
DPI significantly reduces infrastructure-related entry barriers. Systems such as Aadhaar, UPI, and DigiLocker provide foundational digital services that startups and small businesses can leverage without investing in substantial infrastructure costs, enabling them to compete with established firms. The availability of common digital infrastructure shifts competition towards innovation and service quality.
Interoperability and Market Openness
Interoperability is a defining feature of DPI’s competitive function. UPI’s architecture, for instance, enables transactions across different payment applications through a common network, fostering an open ecosystem and preserving consumer choice. Similarly, the Open Network for Digital Commerce (ONDC) enables buyers and sellers to interact across interoperable platforms, preventing the lock-in effects that characterise closed, proprietary marketplace models.6 By ensuring seamless interaction between market participants, DPI structurally limits the scope for leveraging platform control into adjacent market dominance.
Need for a Codified Legal Framework Governing DPI
While India’s existing regulatory framework – comprising the Aadhaar Act, 2016, the Digital Personal Data Protection Act, 2023, and the Information Technology Act, 2000 – provides a partial legal foundation for DPI governance, its fragmented and sectoral nature leaves critical regulatory gaps unaddressed. The institutional frameworks articulated by the G20, OECD, and Quad collectively highlight the need for a governance framework capable of addressing evolving concerns relating to market concentration, privacy, security, and interoperability.
Without adequate governance mechanisms, DPI risks generating new forms of market concentration, wherein a limited number of entities exercise disproportionate control over digital identity systems, payment rails, or data-sharing infrastructure – precisely the concentrations that DPI was designed to prevent.
A codified legal framework for DPI would establish clear rules relating to access, governance, data protection, accountability, and fair competition, while providing enforceable safeguards against exclusion, misuse of data, and abuse of market power. Such a framework would enhance public trust, ensure regulatory certainty for market participants, and preserve the public-interest objectives that underpin DPI systems.
Codification would further align India’s DPI governance with evolving international standards, supporting cross-border interoperability and investor confidence in India’s digital infrastructure.
Press Information Bureau, Government of India, Report of India’s G20 Task Force on Digital Public Infrastructure Released (July 15, 2024), https://www.pib.gov.in/PressReleaseIframePage.aspx?PRID=2033389®=3&lang=2 (last visited June 5, 2026).↩︎
United Nations Development Programme, Digital Public Infrastructure, https://www.undp.org/digital/digital-public-infrastructure (last visited June 5, 2026).↩︎
OECD, Digital Public Infrastructure for Digital Governments (2024), https://www.oecd.org/en/publications/digital-public-infrastructure-for-digital-governments_ff525dc8-en.html (last visited June 5, 2026).↩︎
Ministry of External Affairs, Government of India, Quad Principles for Development and Deployment of Digital Public Infrastructure, https://www.mea.gov.in/bilateral-documents?dtl/38329/Quad_Principles_for_Development_and_Deployment_of_Digital_Public_Infrastructure (last visited June 5, 2026).↩︎
Press Information Bureau, Government of India, India’s Digital Public Infrastructure (Mar. 2025), https://static.pib.gov.in/WriteReadData/specificdocs/documents/2026/mar/doc202636812701.pdf (last visited June 5, 2026).↩︎
Open Network for Digital Commerce, About ONDC, https://www.ondc.org/about-ondc/ (last visited June 5, 2026).↩︎
