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Home / NBFC & Fintech / Payment Aggregator License (RBI PA)
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. CS Chetna Shoor structures your PA application to clear it.
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. Chetna reviews your net worth position, business model, and escrow arrangement before the application goes to RBI’s Department of Payment and Settlement Systems.
Minimum net worth required at the time of application
Net worth required by the end of the third financial year, maintained permanently thereafter
Applicant must be incorporated in India as a company
Mandatory for all merchant fund flows, ring-fenced from the PA's own funds
Typical timeline from application to RBI authorization
Legal basis, most recently tightened under RBI's 2025 framework
RBI rejects over 40% of NBFC applications on the first attempt. Here’s what actually causes it.
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.
₹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.
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.
Not every payments platform needs full PA authorization — it depends on whether you actually touch the funds.
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.
Sufficient if you only provide the technology layer connecting a merchant to their own payment processing arrangement, without touching or holding the funds yourself.
A related but distinct authorization if your platform facilitates cross-border payment collection or settlement. See our Payment Aggregator — Cross Border (PA-CB) service.
We confirm whether your business model actually requires PA authorization, and assess your current net worth position against the phased thresholds
A full review of your net worth certification and supporting documentation against RBI's requirements.
Escrow account coordination with a scheduled commercial bank, alongside business plan, governance, and risk management framework preparation.
Full application filed with RBI's Department of Payment and Settlement Systems (DPSS).
Direct response to every RBI query during the review period.
KYC/AML processes, PCI-DSS readiness where applicable, and data localization compliance confirmed and operationalized.
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.
CS Chetna Shoor’s team replies within 4 hours on WhatsApp.
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.
Typical timelines run 4 to 6 months from application to authorization, though this can extend 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.
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.