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Payment Aggregator License (RBI PA) – Expertvuw
NBFC & Fintech Services

Handling Merchant Payments? You Need RBI's PA Authorization, Not Just a Payment Gateway Integration

Last updated: 2 October 2026

RBI’s tightened framework forced every non-bank Payment Aggregator to seek fresh authorization by December 2025 or wind down by February 2026 — the bar for capital, escrow discipline, and governance is now firmly set. Our team structures your PA application to clear it.

Overview

Why Handling Merchant Funds Puts You in a Different Regulatory Category

Any non-bank entity that collects payments from customers and settles them to merchants — rather than just providing the payment technology — needs RBI’s Payment Aggregator authorization under the Payment and Settlement Systems Act, 2007. RBI tightened this framework substantially: existing non-bank PAs had to file for fresh authorization by December 31, 2025 or wind down operations by February 28, 2026, and every applicant now needs a minimum ₹15 crore net worth at application, rising to ₹25 crore within three years and maintained permanently thereafter.

Whether you’re a payment gateway startup, an e-commerce marketplace settling seller payouts, or a subscription billing platform, if you touch merchant funds, this authorization applies to you — not the lighter-touch Payment Gateway category available to pure technology providers. This page is for founders building a platform that collects and settles merchant payments and need the PA authorization structured correctly, from net worth certification through to escrow account setup. Our team reviews your net worth position, business model, and escrow arrangement before the application goes to RBI’s Department of Payment and Settlement Systems.

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What This Service Covers

1

PA vs. PG classification — confirming whether your business model actually requires PA authorization or fits the lighter-touch Payment Gateway category.

2

Net worth certification and structuring against the ₹15 crore application threshold and ₹25 crore three-year requirement.

3

Escrow account structuring with a scheduled commercial bank, built to RBI's fund-segregation and settlement-timeline requirements.

4

Business plan, governance, and risk management framework preparation in RBI's expected format.

5

Full application filing with RBI's Department of Payment and Settlement Systems (DPSS) and direct handling of every query.

6

Post-authorization compliance setup — KYC/AML, PCI-DSS readiness where applicable, and data localization compliance.

Eligibility & key criteria

₹15 Cr

Minimum net worth required at the time of application

₹25 Cr

Net worth required by the end of the third financial year, maintained permanently thereafter

Companies Act, 2013

Applicant must be incorporated in India as a company

Escrow with scheduled bank

Mandatory for all merchant fund flows, ring-fenced from the PA's own funds

4–6 mo

Typical timeline from application to RBI authorization

PSS Act, 2007 + PA Directions

PSS Act, 2007 and the RBI (Regulation of Payment Aggregators) Directions, 2025 (15 Sep 2025), covering PA-O, PA-P and PA-CB

Why It's Complex

Three Reasons Payment Aggregator Applications Stall

RBI returns or queries applications that are incomplete or inconsistent. Here’s what actually causes it.

PA vs. PG misclassification

Many platforms assume they're a lighter-touch Payment Gateway because they don't build the payment rails themselves, when RBI's actual test is whether you handle and settle merchant funds. Get this wrong and you're operating without required authorization altogether, not just under a different compliance regime.

The net worth requirement is phased, and easy to under-plan for

₹15 crore gets you in the door, but the ₹25 crore requirement three years later — maintained permanently after that — needs to be part of your capital planning from day one, not addressed only as the deadline approaches.

Escrow structure and settlement discipline get built loosely

RBI's framework requires merchant funds to be ring-fenced in an escrow account with a scheduled commercial bank and settled within defined timelines, not treated as working capital float. Platforms that build this as an afterthought face costly re-engineering mid-application when RBI reviews the actual fund-flow mechanics.

PA Vs PG

Do You Need a PA License, or Just a Payment Gateway?

Not every payments platform needs full PA authorization — it depends on whether you actually touch the funds.

Payment Aggregator (PA)

Needed if your platform collects funds from customers and settles them to merchants — e-commerce marketplaces, subscription billing platforms, and most payment checkout products fall here.

Payment Gateway (PG)

Sufficient if you only provide the technology layer connecting a merchant to their own payment processing arrangement, without touching or holding the funds yourself.

Cross-border variant (PA-CB)

A related but distinct authorization if your platform facilitates cross-border payment collection or settlement. See our Payment Aggregator — Cross Border (PA-CB) service.

Documents Required

What you'll need to hand us

Company & Governance Documents

Technical & Promoter Documents

Our Process

From Classification to RBI Authorization

1

PA vs. PG classification & eligibility

We confirm whether your business model actually requires PA authorization, and assess your current net worth position against the phased thresholds

2

Net worth structuring & gap analysis

A full review of your net worth certification and supporting documentation against RBI's requirements.

3

Escrow setup & framework preparation

Escrow account coordination with a scheduled commercial bank, alongside business plan, governance, and risk management framework preparation.

4

Application filing

Full application filed with RBI's Department of Payment and Settlement Systems (DPSS).

5

RBI query handling

Direct response to every RBI query during the review period.

6

Compliance setup begins

KYC/AML processes, PCI-DSS readiness where applicable, and data localization compliance confirmed and operationalized.

POST-AUTHORIZATION

What's Due Once You're an Authorized Payment Aggregator

Authorization is the starting point — the net worth, escrow, and compliance obligations continue for as long as you operate.

Ongoing net worth maintenance — the ₹25 crore threshold, once reached, monitored continuously and never allowed to lapse.

Escrow and settlement compliance — fund segregation and timely settlement discipline maintained on every transaction.

Merchant KYC obligations — full KYC for larger merchants, PAN verification for smaller ones.

PCI-DSS certification maintenance, if transaction volume crosses the applicable threshold, plus ongoing data localization compliance.

Eligibility & key criteria

Our team replies during business hours.






    FAQs

    Frequently Asked Questions

    Who needs a Payment Aggregator license from RBI?

    Any non-bank entity that collects payments from customers and settles them to merchants needs RBI’s Payment Aggregator authorization under the Payment and Settlement Systems Act, 2007 — this includes e-commerce marketplaces, subscription billing platforms, and most payment checkout products. Operating without this authorization when your business model requires it is not permitted under the Act.

    A Payment Aggregator collects and holds merchant funds before settling them, and requires RBI authorization. A Payment Gateway only provides the technology layer connecting a merchant to their own payment processing arrangement, without touching or holding funds, and falls under a lighter-regulated category that doesn’t require the same authorization.

    Non-bank Payment Aggregators need a minimum net worth of ₹15 crore at the time of application, rising to ₹25 crore by the end of the third financial year from authorization, and this ₹25 crore threshold must be maintained permanently thereafter. Net worth is calculated in line with the Companies Act and applicable accounting standards, and must be certified by a statutory auditor.

    Non-bank Payment Aggregators that did not apply for fresh authorization by December 31, 2025 were required to cease their PA business operations by February 28, 2026. This deadline reflected RBI’s tightened 2025 framework, which replaced the earlier, more permissive regime for existing payment aggregators.

    There is no fixed timeline — RBI’s review can take several months from application to authorisation, and it can extend further if RBI raises queries on net worth documentation, the escrow arrangement, or the governance framework. Building in this timeline, and the phased net worth requirement, from the earliest stages of fundraising and product planning avoids a scramble closer to launch.

    Who Handles This

    About Expertvuw

    CS Chetna Shoor, Company Secretary and Director, Expertvuw

    CS Chetna Shoor

    ACS – Director, Expertvuw Management Pvt Ltd

    NBFC and fintech work is handled by Expertvuw’s team. Certificates and audits required by RBI or by law are issued by independent Chartered Accountants or other practising professionals, and representation before RBI or other authorities is made by authorised professionals or advocates.

    Expertvuw Management Pvt Ltd