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RBI brought cross-border payment facilitation under direct regulation in 2023, replacing the old OPGSP and collection-agent arrangements entirely, and later folded it into the unified 2025 Payment Aggregator framework. CS Chetna Shoor structures your PA-CB category, net worth, and collection account setup correctly.
Any non-bank entity facilitating cross-border payment collection or settlement for the import or export of goods and services is classified as a Payment Aggregator – Cross Border (PA-CB), and needs RBI authorization under a framework RBI introduced on October 31, 2023, later consolidated into its unified 2025 Payment Aggregator Directions. This replaced the older Online Payment Gateway Service Provider (OPGSP) arrangement, where non-banks only needed a standing arrangement with an Authorised Dealer (AD) bank — that workaround is no longer a compliant substitute for direct RBI authorization.
PA-CB activity is classified into three categories — export-only, import-only, and export-and-import — each carrying its own collection account requirements, and every cross-border transaction processed is capped at ₹25 lakh per unit of goods or services. This page is for platforms facilitating cross-border payment collection for importers or exporters who need the PA-CB category classification, net worth structuring, and collection account setup done correctly. Chetna reviews your transaction flows and structures the application before it goes to RBI’s Department of Payment and Settlement Systems.
Maximum value per unit of goods/services for any single cross-border transaction processed by a PA-CB
Net worth at application, rising within three years and maintained permanently
Export-only, import-only, or export-and-import PA-CB, each with its own account requirements
A precondition non-bank PA-CBs must complete before RBI authorization
Inward and Outward Collection Accounts required with an AD Category-I bank
Legal basis, now consolidated into RBI's unified Payment Aggregator framework
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Many platforms built their cross-border flows around the older OPGSP arrangement with an AD bank, which has been effectively replaced by direct PA-CB authorization. Continuing to operate on that old model without PA-CB authorization is a compliance gap now, not a legitimate alternative structure.
Collection account requirements differ for import-only, export-only, and combined PA-CBs — Inward Collection Accounts and Outward Collection Accounts serve different purposes and must be kept distinct. Platforms that build a single generic account structure without mapping it to their actual transaction categories face rework during RBI's review.
Non-bank PA-CBs must complete FIU-IND registration before RBI will grant authorization. Treating FIU-IND registration as something to handle "at some point" rather than upfront can stall the PA-CB application itself, since it's a prerequisite RBI checks for.
Cross-border payment facilitation and domestic payment aggregation are related but distinct authorizations — it’s worth knowing which one, or both, your business actually needs.
Needed if you facilitate cross-border payment collection or settlement for the import or export of goods and services.
Needed separately if you also handle domestic merchant payment collection and settlement — see our Payment Aggregator License (RBI PA) service. The two authorizations and their collection accounts must be kept distinct even if held by the same entity.
The pre-2023 model, now effectively superseded by PA-CB authorization for both new and continuing non-bank operators facilitating cross-border transactions.
We confirm whether your business is export-only, import-only, or export-and-import, and assess your current net worth position.
Net worth structuring alongside FIU-IND registration coordination, if not already completed — a precondition for authorization.
Inward/Outward Collection Account setup with an AD Category-I bank, alongside business plan and KYC/AML policy preparation.
Full application filed with RBI's Department of Payment and Settlement Systems (DPSS).
Direct response to every RBI query during the review period.
Transaction limit monitoring and the ongoing due diligence framework operationalized.
PA-CB authorization comes with the same permanent obligations as domestic PA authorization, plus cross-border-specific monitoring.
Ongoing net worth maintenance toward and beyond the ₹25 crore threshold.
Per-unit transaction limit monitoring, keeping every processed transaction within the ₹25 lakh cap.
Enhanced buyer due diligence for larger import transactions, as required under RBI's framework.
Continued FIU-IND reporting alongside RBI compliance. See FIU-IND Registration for NBFCs and NBFC Annual RBI Compliance.
CS Chetna Shoor’s team replies within 4 hours on WhatsApp.
A Payment Aggregator – Cross Border (PA-CB) is any non-bank entity that facilitates cross-border payment collection or settlement for the import or export of goods and services. RBI brought this activity under direct regulation in October 2023, requiring authorization for entities that previously operated through OPGSP or collection-agent arrangements with AD banks.
The Online Payment Gateway Service Provider (OPGSP) model, where non-banks facilitated cross-border transactions through a standing arrangement with an AD bank without direct RBI authorization, has been effectively replaced by the PA-CB framework. Entities continuing to operate on the old OPGSP model without seeking PA-CB authorization are operating outside the current regulatory framework.
RBI caps the maximum value per unit of goods or services processed by a PA-CB at ₹25 lakh for both import and export transactions. This limit applies per unit of the underlying transaction, not as an aggregate cap on total volume.
Yes, if your platform handles both domestic merchant payment collection and cross-border import/export payment facilitation — these are two distinct authorizations under RBI’s framework, each with its own collection account requirements that must be kept separate even within the same entity.
RBI requires non-bank PA-CBs to be registered with FIU-IND under the Prevention of Money Laundering Act as a precondition for receiving PA-CB authorization. This means FIU-IND registration needs to be completed early in the process, not treated as a separate task to address after RBI authorization is secured.
Qualified Company Secretary · ICSI Member · Founder, Expertvuw Management Pvt Ltd
Chetna has guided NBFC promoters through RBI’s COR process end to end, with particular focus on structuring the Net Owned Fund and business plan so the application survives first-round RBI scrutiny rather than coming back with a query.