
Since September 2025, domestic and cross-border payment aggregation are governed by a single RBI master direction. This guide explains the PA-O, PA-P and PA-CB categories, who needs authorisation, the net worth requirements and the rules specific to cross-border flows.
On 15 September 2025 the Reserve Bank of India issued the Reserve Bank of India (Regulation of Payment Aggregators) Directions, 2025 (RBI/DPSS/2025-26/141). It brings the earlier payment aggregator circulars of March 2020, March 2021 and October 2023 into a single master direction and repeals them. Authorisations granted under the earlier circulars continue under the new direction.
The direction recognises three categories of payment aggregator (PA):
So the question is less “PA or PA-CB” as two separate regimes, and more which categories of PA business an entity will carry on under the same framework.
The direction defines a payment aggregator as an entity that facilitates aggregation of payments made by customers to merchants through one or more payment channels and subsequently settles the collected funds to those merchants. The defining feature is handling of funds.
A payment gateway, by contrast, provides the technology infrastructure to route and process a payment transaction without any involvement in handling funds. Payment gateways do not need authorisation, although the direction encourages them to follow its baseline technology recommendations.
The direction also provides that a PA business shall not carry out marketplace business.
In practical terms:
The earlier position, under which PA-CB was regulated by a separate October 2023 circular, has been folded into the 2025 direction. Expertvuw’s pages on RBI payment aggregator authorisation and PA-Cross Border set out the application stages for each.
For a non-bank, the main eligibility points in the direction are:
The same net worth thresholds apply whichever category is sought; the direction does not set a separate figure for PA-CB. The statutory auditor’s certificate is issued by an independent chartered accountant.
Non-bank applicants apply to the Reserve Bank’s Department of Payment and Settlement Systems through the RBI’s online portal. Where the applicant is regulated by another financial sector regulator, a no-objection certificate from that regulator is required and the application must be made within 45 days of obtaining it.
The application is generally supported by:
After authorisation, any takeover, acquisition of control or change in management of a non-bank PA must follow the Reserve Bank’s circular of 4 July 2022 on change in control of non-bank payment system operators.
Cross-border aggregation carries additional conditions:
All PAs, domestic and cross-border, must carry out merchant due diligence, check the Central KYC Records Registry where applicable, register with FIU-IND and monitor merchant transactions on an ongoing basis. Settlement to merchants follows the timelines set out in the direction.
PA authorisation allows an entity to collect and settle payments for merchants. It does not allow the entity to issue prepaid payment instruments such as wallets or prepaid cards, which need a separate authorisation. On 22 April 2026 the Reserve Bank released a draft Master Direction on Prepaid Payment Instruments for public comments, so entities planning a PPI business should check the current framework before applying. Expertvuw’s PPI licence page explains that route.
The direction set out a transition for entities already in the business. Existing authorised PAs and pending applicants carrying on PA-P business had to inform the Reserve Bank by 31 December 2025, entities carrying on only PA-P business had to apply for authorisation by the same date, and entities that did not apply were required to wind up that business by 28 February 2026. New merchant onboarding from 1 January 2026 follows the prescribed due diligence requirements.
Expertvuw’s team can help you assess which PA categories apply to your business and prepare the application, with certification and audit work handled by independent licensed professionals.
Services connected to this topic.
View service
View service
View service
Share your query and our team will reply on WhatsApp within business hours.
No. Under the 2025 direction, a non-bank applicant needs a net worth of ₹15 crore when it applies and ₹25 crore by the end of the third financial year, whichever PA category it seeks.
No. A bank does not require authorisation to carry on PA business. Banks acting as acquiring banks for non-bank PAs have separate obligations under the direction.
Yes. The maximum value per PA-CB transaction is ₹25 lakh, and inward and outward funds must be kept in separate collection accounts with AD Category-I banks.
ACS – Director, Expertvuw Management Pvt Ltd
Advisory and company secretarial work is handled by Expertvuw’s team. Audits, certifications and representation that the law reserves for Chartered Accountants, advocates or other licensed professionals are provided by independent professionals engaged for your case.