Payment Aggregator Licence (RBI)
A non-bank company that collects payments from customers and settles them to merchants needs RBI authorisation as a payment aggregator. You need a net worth of ₹15 crore when you apply and ₹25 crore by the end of the third financial year. We prepare the application, the net-worth papers and the policies, and file it on RBI’s PRAVAAH portal.
What it is
A payment aggregator (PA) sits between the customer and the merchant. It collects the customer’s payment by card, UPI, net banking or wallet, holds it briefly, then settles it to the merchant. Do this for other businesses and RBI treats you as running a payment system.
The rules are in the Reserve Bank of India (Regulation of Payment Aggregators) Directions, 2025 (RBI/DPSS/2025-26/141, dated 15 September 2025), issued under the Payment and Settlement Systems Act, 2007. Section 4 of that Act bars anyone other than RBI from running a payment system without authorisation. Banks are exempt; non-bank companies apply on PRAVAAH.
The Directions recognise three kinds of PA. A PA-Online (PA-O) handles payments where the card or phone and the acceptance device are apart, such as app or website checkout. A PA-Physical (PA-P) handles face-to-face payments at a POS terminal or QR, which most people call an offline payment aggregator. A PA-Cross Border (PA-CB) handles inward or outward payments for current account transactions such as export and import of goods and services.
Who it applies to
You run checkout for online merchants
You onboard merchants, collect their customers’ money and settle it later. A pure technology gateway that never touches the funds is not a PA. Neither is a SaaS company collecting only its own subscription fees.
You put POS or QR devices in shops
Picture a Faridabad company that places QR soundboxes at kirana stores and settles their collections each day. That is a PA-P, and it needs the same authorisation as an online PA.
You move money across borders
Helping Indian exporters get paid from abroad, or Indian buyers pay overseas sellers, makes you a PA-CB. Each transaction is capped at ₹25 lakh.
Why it matters
Operating without it is a crime
Running a payment system without RBI authorisation is a criminal offence under the PSS Act. There is no grace period for new players.
Banks ask for it first
In practice, no bank will run a PA escrow for you without it. Large merchants check it before they sign.
It fixes how money moves
The Directions decide how the escrow works, which credits and debits are allowed, how you verify merchants and what you report to RBI.
PA-O, PA-P and PA-CB compared
| PA-Online (PA-O) | PA-Physical (PA-P) | PA-Cross Border (PA-CB) | |
|---|---|---|---|
| Typical business | Website and app checkout | POS terminals, QR at counters | Export and import collections |
| Net worth | ₹15 crore to apply, ₹25 crore by end of third FY | ₹15 crore to apply, ₹25 crore by end of third FY | ₹15 crore to apply, ₹25 crore by end of third FY |
| Special limit | None in the Directions | None in the Directions | ₹25 lakh per transaction |
One company can hold authorisation for more than one category. Say an online PA in Gurugram now wants to sell POS terminals too: it must tell RBI before it starts.
Documents required
Company documents
- Certificate of incorporation under the Companies Act, 2013
- MoA with payment aggregation in the objects clause
- Audited financial statements
- Shareholding pattern and FDI details, if any
Net worth and promoters
- Statutory auditor’s certificate of net worth in RBI’s format
- Fit-and-proper declarations of directors and promoters
- Profiles, PAN and KYC of directors and key managers
- NOC from your existing regulator, if you are already regulated
Policies and systems
- Board-approved merchant onboarding and KYC policy
- Grievance redressal and refund policy
- Information security and cyber security policy
- Business plan, escrow bank details and settlement model
How it works
Test the company and the capital
We review your objects clause, shareholding and audited net worth certificate. Here is the catch: compulsorily convertible preference shares count, but deferred tax assets come off. Short of ₹15 crore? We plan the fresh capital and raise the authorised capital first.
Write the policies your team will use
We draft the merchant KYC, grievance and security policies and the fit-and-proper declarations. Starting from scratch? We first set up a private limited company with the right objects clause.
File the application on PRAVAAH
We file the application on RBI’s PRAVAAH portal with every annexure. If you are already regulated by RBI or another regulator, the application goes in within 45 days of getting that regulator’s NOC.
Answer RBI’s queries quickly
RBI examines the promoters, the capital and the systems. We draft the replies and follow up until the file closes.
Open the escrow and start reporting
Once authorised, collections go into an escrow account with a scheduled commercial bank. We set up a calendar for every return.
Timelines
Reach ₹25 crore by the third year
₹15 crore when you apply. ₹25 crore by the end of the third financial year. After that, the minimum must hold at all times.
Report every month and quarter
Transaction statistics by the 7th of the next month. Monthly cyber security incident reports. An auditor’s escrow certificate by the 15th of the month after each quarter.
File the net-worth certificate by 30 September
Each year an audited net-worth certificate is due by 30 September, along with external IS audit and cyber security audit reports.
What happens if you operate without it
You face prosecution
Section 26 of the PSS Act provides imprisonment of up to ten years, a fine of up to ₹1 crore, or both, with a further fine of up to ₹1 lakh for each day the offence continues.
Late offline PAs had to shut
Existing offline PAs had to apply by 31 December 2025. Those that did not had to inform their banks and wind up by 28 February 2026.
Your settlements stop
No authorisation, no escrow account. Settlements stop and merchants leave.
Frequently asked questions
What is the net worth requirement for a payment aggregator licence?
You need a net worth of ₹15 crore when you apply and ₹25 crore by the end of the third financial year after that. The applicable minimum must then be kept on an ongoing basis. Net worth follows RBI’s January 2015 circular: compulsorily convertible preference shares count, and deferred tax assets are deducted. A statutory auditor certifies the figure in RBI’s format. We plan the capital so it holds up at every check.
Do offline payment aggregators need RBI authorisation?
Yes. The 2025 Directions bring physical, or offline, payment aggregators (PA-P) under the same authorisation as online ones. Existing PA-P entities had to apply by 31 December 2025, and those that did not apply had to wind up by 28 February 2026. A new offline PA applies like any other non-bank PA, with ₹15 crore net worth. If you run POS or QR collections for shops, we can assess your status quickly.
Does a bank need a payment aggregator licence?
No. The Directions say a bank does not require authorisation to carry on PA business. Authorisation is needed only by non-bank companies, which must be incorporated in India under the Companies Act, 2013. If you are a non-bank fintech partnering with a bank, we can tell you which side of the line your model falls.
Where is the application filed?
The application is filed online on RBI’s PRAVAAH portal, with the auditor’s net-worth certificate, director declarations, policies and company documents. An entity already regulated by RBI or another financial regulator first gets that regulator’s no-objection certificate and applies within 45 days of it. We prepare the full set so the file is complete at the first go.
Is a payment gateway the same as a payment aggregator?
No. A payment aggregator handles the money: it collects from customers and settles to merchants. A payment gateway only provides the technology that routes the transaction and does not handle funds. Only the aggregator needs RBI authorisation under the 2025 Directions. If you do both, the PA side needs the licence. We map your actual fund flow first.
Can a payment aggregator run a marketplace too?
No. The Directions say a PA shall not carry out marketplace business. An e-commerce marketplace that wants to offer PA services has to separate the PA business into a different entity, which then applies for authorisation on its own. That company must meet the net worth and governance rules on its own. We plan the structure with you before you file.
What is the transaction limit for cross-border payment aggregators?
For PA-CB, the maximum value per transaction is ₹25 lakh. PA-CB entities handle only current account transactions, such as payments for exports and imports of goods and services. FDI in the PA company follows the consolidated FDI policy and FEMA rules. We check your corridors and products against these rules before you apply.
How must merchant money be kept?
In a separate escrow account with a scheduled commercial bank in India. Only the credits and debits the Directions permit can pass through it, and never cash-on-delivery transactions. Settlement timelines are set in the PA–merchant agreement, which must be fair and transparent. A quarterly auditor’s certificate confirms the balances, and we can set up that routine for you.
What merchant KYC does a payment aggregator do?
A PA does customer due diligence on every merchant under RBI’s KYC directions and pulls the merchant’s KYC record from CKYCR. It also checks that merchants meet security standards such as PCI-DSS and do not store customers’ card details on their servers. Merchants onboarded up to 31 December 2025 had one year from the date of the Directions to be brought in line. We draft an onboarding policy your operations team can actually follow.
What it costs
Our fee plus the government fee that applies to your case, quoted before you commit. Tell us the situation and we will price it exactly.
The real cost is capital: ₹15 crore of net worth to apply and ₹25 crore by the end of the third financial year, plus the yearly IS and cyber security audits.
Ready to begin?
Share your fund flow and your latest audited net worth, and we will tell you exactly what your payment aggregator application needs.