PRAVAAH filing support through the RBI Online Portal. Escrow coordination. PCI-DSS readiness. Ongoing compliance assistance. Listed amounts are IncorpX professional charges for end-to-end assistance. Government / statutory fees are charged separately at actuals.
PA vs PG applicability review
Net worth documentation support
PCI-DSS readiness coordination
Escrow documentation guidance
PRAVAAH filing support
Post-authorization compliance assistance
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Get Expert Assistance for Payment Aggregator Authorization?
Assistance with eligibility review, PRAVAAH filing, escrow coordination, and RBI query responses for the PA application process
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Payment Aggregator Authorization Process
We assist with each stage of the application process, from applicability review to post-authorization compliance planning.
RBI authorization is required for a Payment Aggregator (PA), not for a pure Payment Gateway (PG). A PA handles merchant funds through an escrow structure, while a PG remains a technology provider that routes payment information without separately receiving an RBI license.
The governing framework comes from the RBI's Guidelines on Regulation of Payment Aggregators and Payment Gateways issued in March 2020, read with the Payment and Settlement Systems (PSS) Act, 2007. Existing non-bank PAs were required to apply by September 2021, and current applications are routed through the RBI Online Portal (rbi.org.in) using PRAVAAH for RBI and DPSS review.
Non-bank entities that collect customer payments, pool them, and settle merchant funds generally need PA authorization from RBI. Technology-only PGs remain outside the separate authorization requirement, though they still need to meet applicable security and operational standards.
IncorpX provides assistance for businesses preparing a PA application, including applicability review, documentation, escrow coordination, PCI-DSS readiness planning, and support during RBI query resolution.
What is a Payment Aggregator (PA) vs Payment Gateway (PG)?
The RBI's PA/PG Guidelines 2020 create a clear distinction between Payment Aggregators (PAs) and Payment Gateways (PGs) based on whether the entity handles funds or only provides technology. Understanding this distinction is critical because it determines whether RBI authorization is required.
A Payment Aggregator is an entity that collects customer payments, pools merchant funds in an escrow structure, and settles them to merchants. Since PAs handle funds, they require RBI authorization.
A Payment Gateway is a technology service provider that provides the infrastructure for routing payment information between merchants, customers, and acquiring banks. PGs do not handle, pool, or settle funds, so they do not require separate RBI authorization when they remain technology-only providers, but they must comply with applicable technology and security standards.
Parameter
Payment Aggregator (PA)
Payment Gateway (PG)
Fund Handling
Yes - collects, pools, and settles funds
No - only routes payment data
RBI Authorization
Mandatory under PA/PG Guidelines
Not required
Net Worth Requirement
₹15 crore (₹25 crore by revised deadline)
No specific requirement
Escrow Account
Mandatory with scheduled bank
Not applicable
PCI-DSS Compliance
Mandatory (Level 1)
Mandatory (baseline)
Merchant Onboarding
PA performs KYC and due diligence
Merchant contracts with acquiring bank
Settlement
PA settles to merchants from escrow (T+1)
Bank settles directly to merchant
Revenue Model
MDR (Merchant Discount Rate) commission
Technology/API usage fees
Examples
Razorpay, PayU, CCAvenue, Cashfree, Instamojo
Pure API routing providers, bank payment page providers
Critical Distinction!
If money flows through your platform, even temporarily, you are generally a Payment Aggregator and need RBI authorization. Many businesses that describe themselves as payment gateways are actually performing PA functions because they control merchant fund flows.
Types of Payment Aggregator Authorization:
Payment Aggregators can be categorized based on their operational model, target market, and the type of transactions they process. Understanding the correct category helps in building the right business plan and compliance framework for the RBI application.
PA Category
Description & Use Cases
Key Requirements
Online Payment Aggregator
Facilitates payments for e-commerce, digital services, SaaS, and online businesses. Processes card, net banking, UPI, and wallet payments via API integration.
PCI-DSS Level 1, data localization, tokenization, real-time fraud monitoring
Offline Payment Aggregator
Facilitates in-person payments through POS terminals, QR codes, and tap-to-pay solutions for retail merchants, restaurants, and service providers.
PCI-DSS, secure application controls, and key management for physical devices
E-commerce / Marketplace PA
Facilitates payments on marketplace platforms where multiple sellers operate (e.g., Amazon-like platforms). Collects from buyers, splits and settles to individual sellers.
Facilitates international payment processing - enabling Indian merchants to accept payments from overseas customers or Indian customers to pay overseas merchants.
FEMA compliance, AD bank tie-up, OPGSP framework, separate cross-border reporting
Recurring / Subscription PA
Specializes in recurring payments for subscription businesses, EMIs, insurance premiums, and SIP payments using e-mandate and standing instructions.
RBI e-mandate framework compliance, AFA (Additional Factor of Authentication) for recurring debits
Important Note!
Regardless of the category, non-bank Payment Aggregators need the same RBI authorization. The categorization mainly helps structure the business plan, technology architecture, and compliance controls for the application.
Eligibility & Requirements for Payment Aggregator License:
RBI has prescribed stringent eligibility criteria for entities seeking PA authorization under the PA/PG Guidelines 2020. Both financial and operational requirements must be met before applying:
Company incorporated in India under the Companies Act, 2013 with payment aggregation services in MOA
Minimum net worth of ₹15 crore at the time of application (non-bank entities)
Net worth must reach ₹25 crore by 31 March 2025
Robust technology infrastructure with PCI-DSS Level 1 compliance
Security audit by a CERT-In empaneled auditor confirming technology and security readiness
Escrow arrangement with a scheduled commercial bank for merchant fund protection
Directors and key management personnel must satisfy RBI's "fit and proper" criteria
Comprehensive KYC/AML/CFT compliance framework for merchant onboarding and transaction monitoring
Data localization - all payment data must be stored exclusively within India
Grievance redressal mechanism with designated nodal officer under PSS Act
No bank-promoted entity restriction - bank-promoted PAs follow a separate regulatory regime
Audited financial statements and a documented regulatory compliance record
Net Worth Requirements & Timeline for Payment Aggregators:
The net worth requirement is one of the core eligibility criteria for PA authorization. RBI prescribed a phased framework under which applicants must show ₹15 crore at application and ₹25 crore by 31 March 2025:
Milestone
Net Worth Requirement
Details
At Time of Application
₹15 crore
Minimum net worth expected for submitting the application to RBI
By 31 March 2025
₹25 crore
Threshold expected for continued eligibility under the RBI framework
Net Worth Calculation Methodology:
Net Worth = Paid-up equity capital + Free reserves − Accumulated losses − Deferred revenue expenditure − Intangible assets
Audited Certificate: A Tax Professional must certify the net worth as per audited financial statements. The Expert certificate must follow the prescribed format and be submitted along with the application.
Source of Funds: RBI scrutinizes the source of capital to ensure it is from legitimate sources. Promoters must provide detailed documentation of fund sources.
Ongoing Compliance: PAs must maintain the prescribed net worth at all times. Quarterly net worth certificates must be submitted to RBI.
Capital Planning Advisory
Meeting the ₹15 crore to ₹25 crore net worth requirement is a significant commitment. IncorpX can assist with capital planning documentation, supporting papers, and readiness review for the applicant's funding structure.
Step-by-Step Process for Payment Aggregator License from RBI:
Preparing a Payment Aggregator application with RBI usually involves a multi-stage process that can span 6 to 18 months. IncorpX can assist with document preparation, readiness review, and regulatory responses. Here is the typical process:
Step 1: Confirm whether the model is PA or PG
Review whether the business model will handle merchant funds as a Payment Aggregator or remain a technology-only Payment Gateway. Only the PA model requires RBI authorization.
Step 2: Review eligibility and net worth
Check company structure, object clause, governance, and the minimum net worth requirement of ₹15 crore at application with the path to ₹25 crore by 31 March 2025. Support this with audited financials and a statutory auditor certificate.
Step 3: Prepare technology and PCI-DSS readiness
Document the payment stack, card-data security controls, tokenization, fraud monitoring, data localization, incident response procedures, and disaster recovery measures relevant to the applicant's payment environment.
Step 4: Finalize escrow and policy documents
Coordinate escrow arrangements with a scheduled commercial bank and compile the business plan, financial documents, merchant onboarding framework, security policies, and supporting compliance documents.
Step 5: Submit through the RBI Online Portal
Prepare the application set and submit it through the RBI Online Portal (rbi.org.in) using PRAVAAH for RBI and DPSS review.
Step 6: Respond to RBI and DPSS queries
Address clarifications, additional document requests, and in-principle conditions raised during the regulatory review of the application.
Step 7: Complete final readiness actions
Finish the required audit, escrow, policy, and operational readiness actions before RBI considers final authorization under the Payment and Settlement Systems Act, 2007.
Assistance with PRAVAAH filing, document review, and RBI query responses.
Complete Document Checklist for PA License Application:
Thorough documentation is critical for RBI DPSS approval. Incomplete applications are a primary cause of delays and rejections. Here's the comprehensive checklist for a Payment Aggregator License application:
Category
Document
Purpose
Company Documents
Certificate of Incorporation (COI)
Proves company is incorporated under Companies Act, 2013
Memorandum of Association (MOA) & Articles of Association (AOA)
Confirms payment aggregation services in objects clause
PAN Card, GST Certificate, Board Resolution
Company identity, tax registration, and authorization for application
Financial Documents
Audited Financial Statements (last 3 years)
Financial position, governance, and eligibility assessment
Net Worth Certificate from Tax Professional
Confirms minimum ₹15 crore net worth with calculation methodology
Business Plan
Detailed Business Plan with Revenue Projections
Business viability, target market, and growth strategy assessment
Product Structure & Transaction Flow Diagrams
Demonstrates understanding of payment flows and fund handling
Technology & Security
Technology Architecture Document
Platform design, scalability, and infrastructure details
PCI-DSS Level 1 Compliance Certificate (from QSA)
Mandatory card data security certification
Security Audit Report (CERT-In empaneled auditor)
Vulnerability assessment, penetration testing, and security posture
Escrow
Escrow Arrangement Letter from Scheduled Bank
Confirms escrow account for merchant fund protection
Policies & Compliance
KYC/AML/CFT Policy
Merchant and customer identification and anti-money laundering framework
Information Security Policy
Data protection, access control, and incident response procedures
Merchant Onboarding & Due Diligence Framework
Process for vetting, onboarding, and monitoring merchants
Grievance Redressal Policy
Three-tier complaint resolution mechanism under PSS Act
Director Documents
Directors' Fit & Proper Declarations
RBI fit and proper criteria compliance for all directors
PAN, Aadhaar, DIN, CIBIL Reports of Directors
Identity verification and creditworthiness of key personnel
Technology & Security Requirements for Payment Aggregators:
RBI's PA/PG Guidelines mandate robust technology and security infrastructure for all Payment Aggregators. These requirements are non-negotiable and are thoroughly verified during the authorization process:
1. PCI-DSS Level 1
Mandatory Payment Card Industry Data Security Standard Level 1 compliance through annual QSA audit. Includes network security, encryption, access controls, and vulnerability management.
2. Secure application controls
Payment applications should be built and maintained with secure development, restricted data storage, vulnerability management, and application security controls aligned with current card-data security expectations.
3. Data Localization
All payment data (end-to-end transaction details, cardholder data, payment credentials) must be stored exclusively within India as per RBI's April 2018 circular.
4. Tokenization
Card-on-file data must be replaced with unique tokens. PAs are prohibited from storing actual card numbers. Tokenization through card networks (Visa, Mastercard, RuPay) is mandatory.
5. Two-Factor Authentication
Additional Factor of Authentication (AFA) mandatory for all domestic card transactions. Includes OTP, biometric, or PIN-based second factor as per RBI norms.
6. CERT-In Security Audit
Annual comprehensive security audit by a CERT-In empaneled auditor. Includes vulnerability assessment, penetration testing, application security testing, and configuration review.
7. End-to-End Encryption
256-bit SSL/TLS encryption for all data in transit. AES-256 encryption for data at rest. Secure key management with HSM (Hardware Security Module) for cryptographic keys.
8. Fraud Monitoring
Real-time transaction monitoring and fraud detection system with rule-based and ML-based alerts. Velocity checks, geolocation verification, device fingerprinting, and behavioral analytics.
9. Disaster Recovery
Active DR site with defined RPO (Recovery Point Objective) and RTO (Recovery Time Objective). Business continuity plan with regular DR drills and failover testing.
10. Vulnerability Assessment
Quarterly network vulnerability scans by an Approved Scanning Vendor (ASV). Semi-annual penetration testing. Prompt remediation of identified vulnerabilities.
Escrow & Settlement Framework for Payment Aggregators:
The escrow mechanism is a cornerstone of the PA/PG regulatory framework, designed to protect merchant and customer funds. RBI has prescribed detailed requirements for how Payment Aggregators must handle funds:
Requirement
Details
Escrow Account
Mandatory account with a scheduled commercial bank. All collected payments must be routed through this account.
Settlement Timeline
Merchant settlements should follow the timelines prescribed by RBI and the documented settlement arrangement with the partner bank.
Fund Utilization
PA must not utilize escrow funds for its own business purposes. Funds belong to merchants and customers.
Escrow Balance
The escrow balance must always be equal to or greater than the total unsettled merchant payments.
Nodal Account
Collection and settlement flows may involve additional bank-side arrangements, but merchant funds should ultimately move through the RBI-compliant escrow structure.
Interest on Escrow
Interest earned on escrow funds must be handled as per RBI norms and the escrow agreement terms.
Refund Processing
Refunds to customers must be processed from the escrow account within the timelines prescribed by RBI and card network rules.
Audit & Reconciliation
Periodic reconciliation, audit support, and reporting should be maintained in the manner prescribed by RBI and the escrow arrangement.
Why Escrow Matters: The escrow mechanism helps segregate merchant funds from the PA's operating money and supports settlement, reconciliation, and supervisory oversight under the RBI framework.
Benefits of Obtaining a Payment Aggregator License:
RBI authorization can support a compliant PA operating model in India. Key practical benefits include:
Legal Authorization
Operate as an authorized Payment Aggregator within the RBI framework and reduce the regulatory risk associated with unauthorized operations.
Merchant & Partner Trust
Authorization can support merchant, bank, and counterparty confidence when the business is building a regulated payments model.
Market Opportunity
Authorization can help a business participate in India's digital payments ecosystem across online, offline, and selected cross-border use cases, subject to applicable rules.
Investor Confidence
A documented regulatory pathway can improve internal readiness for investors, lenders, and strategic partners reviewing the payments business model.
Card Network Access
Authorization can support discussions with banks, networks, merchants, and partners, subject to commercial arrangements and scheme rules.
Cross-Border Expansion
Depending on the model, authorization may support compliant expansion into cross-border payment flows, subject to FEMA rules, bank arrangements, and any additional RBI conditions.
Assistance with eligibility review, documentation, and PRAVAAH filing support.
Related Regulatory Services:
If you're building a comprehensive fintech or payments business, you may also need these complementary registrations and licenses:
Why Businesses Seek IncorpX Assistance for Payment Aggregator Applications?
Structured assistance: Support from eligibility review to application readiness and post-authorization planning.
Transparent pricing: Professional assistance package starting at ₹99,999. Listed amounts are IncorpX professional charges for end-to-end assistance. Government / statutory fees are charged separately at actuals.
Submission readiness: Pre-filing review to reduce avoidable documentation gaps and query rounds.
Payments-focused team: Assistance from professionals working on regulatory documentation, compliance, and process coordination.
Technology advisory: Guidance on architecture documentation, PCI-DSS readiness, tokenization, and CERT-In audit coordination.
Compliance planning: Support for reporting, escrow documentation, and merchant onboarding controls after authorization.
Frequently Asked Questions About Payment Gateway License in India (2026)
These FAQs address common questions about Payment Aggregator authorization, Payment Gateway classification, eligibility, costs, escrow, technology controls, and ongoing RBI compliance in India.
The answers are intended for applicants that need clarity on the PA authorization process, pricing for professional assistance, and the difference between PA and PG models.
A Payment Aggregator (PA) authorization is RBI approval for a non-bank entity that collects customer payments, pools them in an escrow account, and settles them to merchants. The framework was introduced through the RBI's Guidelines on Regulation of Payment Aggregators and Payment Gateways issued in March 2020, read with the Payment and Settlement Systems (PSS) Act, 2007.
A Payment Aggregator (PA) handles merchant funds and therefore needs RBI authorization. A Payment Gateway (PG) provides the technology layer for routing payment information and does not receive a separate RBI license when it does not handle funds. PGs must still follow applicable technology, security, and data protection requirements.
Any non-bank entity that handles or pools merchant funds while facilitating customer payments generally needs RBI authorization as a Payment Aggregator. Existing non-bank PAs operating before the March 2020 framework were required to apply by September 2021, while new applicants should obtain authorization before commencing PA operations.
Non-bank PA applicants must demonstrate a minimum net worth of ₹15 crore at the time of application and reach ₹25 crore by 31 March 2025. Net worth is typically supported through audited financials and a certificate from the applicant's statutory auditor.
The RBI review cycle for a PA application typically takes 6 to 18 months, depending on documentation quality, technology readiness, RBI queries, and completion of post in-principle conditions.
IncorpX professional charges for PA application assistance start at ₹99,999. Listed amounts are IncorpX professional charges for end-to-end assistance. Government / statutory fees are charged separately at actuals. Other project costs can include capital planning, technology infrastructure, PCI-DSS work, security audits, and bank escrow documentation.
Yes. An existing company incorporated in India can apply if it meets RBI's eligibility conditions on net worth, governance, technology, and compliance. The company's Memorandum of Association (MOA) should support the proposed payment aggregation activity.
An escrow account is a designated bank account maintained with a scheduled commercial bank for merchant funds collected by the PA. RBI requires this structure so merchant money remains segregated from the applicant's own operating funds and is settled in accordance with the applicable regulatory framework.
PCI-DSS is the card data security standard relevant to businesses that store, process, or transmit cardholder data. Payment Aggregators should implement the applicable PCI-DSS controls, supporting audits, and remediation measures required for their card-processing environment.
Yes. RBI's payment data storage framework requires payment system data to be stored in systems located in India, subject to the applicable RBI directions for cross-border processing and reporting.
Operating as a Payment Aggregator without RBI authorization can lead to regulatory directions to stop operations and action under the Payment and Settlement Systems Act, 2007. It can also affect relationships with banks, card networks, merchants, and counterparties.
Yes. A Payment Gateway that only provides the technology interface and does not handle merchant funds does not require separate RBI authorization. If the business model changes and the entity starts handling funds, it may need PA authorization.
A PA authorization covers collection and settlement of merchant payments in transit. A PPI authorization relates to stored-value instruments such as prepaid wallets or cards. They are different regulatory approvals with different business models and compliance obligations.
The Department of Payment and Settlement Systems (DPSS) is the RBI department that reviews PA applications and compliance matters. Applications are now routed through the RBI Online Portal (rbi.org.in) using PRAVAAH, after which RBI and DPSS examine the submission.
Tokenization replaces actual card details with a unique reference token. Payment Aggregators that support saved-card or recurring card use cases should align with RBI and card-network tokenization requirements so sensitive card data is not stored in an impermissible manner.
Authorized PAs may need to submit periodic reports, reconciliation data, audit outputs, incident notifications, and other compliance information as specified by RBI from time to time.
Yes. An NBFC can apply if it separately satisfies the eligibility conditions for Payment Aggregator authorization. An NBFC registration does not automatically permit PA activity.
Merchant onboarding generally includes KYC and business verification, risk assessment, review of the merchant's website or app, settlement account validation, and ongoing monitoring as required by RBI and the PA's internal controls.
Cross-border payment aggregation may be permitted subject to RBI conditions, FEMA rules, bank arrangements, and any additional approvals or reporting requirements relevant to the applicant's model.
A PA should maintain a documented grievance redressal framework, publish the relevant contact or nodal details required by regulation, and track complaint handling in line with RBI expectations.
Yes. IncorpX provides assistance with eligibility review, documentation, application preparation, PRAVAAH filing support, escrow coordination, PCI-DSS readiness planning, and responses to RBI queries. Professional charges for this assistance start at ₹99,999. Listed amounts are IncorpX professional charges for end-to-end assistance. Government / statutory fees are charged separately at actuals.
The team was very responsive and helpful. I received daily updates from the WhatsApp group, and their guidance made everything much simpler to comprehend. If you want a simple and hassle-free way to launch your business, I would highly recommend them!
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Simon Job
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I recently used IncorpX to register my limited liability partnership, and I had an amazing experience! There were no hidden fees, and the team was helpful, quick to respond, and open. They provided thorough explanations of each step, and their services are reasonably priced without sacrificing quality. The entire process was made simple by IncorpX's professionalism, attention to detail, and sincere support. Strongly advised!
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The experience was flawless; the team completed each task with care and always responded quickly. Throughout the process, I never felt stuck. We would especially like to thank Saksham and Sriram for making everything run so smoothly! The IncorpX team offers extremely competitive pricing; anyone just starting out should definitely get in touch with them.
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Mohammed Affan
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I'm really grateful to the wonderful team at IncorpX for helping bring my co-founder's and my dream to life. The whole process was super smooth - fast service, great support, and no hassles at all. I'd highly recommend IncorpX to any new entrepreneur or founder looking to register their company. Excited to continue working with them in the long run. Thank you, IncorpX!
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One of the best agency I have ever experienced. Team members are very friendly as if we know each other from before and came communicate and share easily. My work has been done in a very short period and I am so happy. Thank you so much.
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Ayyappa Swamy
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Highly recommend... IncorpX services regarding incorporation of our company and roc filing and all are very impressive.. the team IncorpX is polite and friendly. Our Lands Time pvt ltd has incorporated through IncorpX... And thanks to IncorpX team..
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Trouble free service, Rendering good co-operation for company incorporation. Trust worthy team to have better knowledge.
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Pravesh Kudesia
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IncorpX is providing best service... And user experience! Thank You IncorpX Team
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I recently got my Private Limited Company incorporated through IncorpX, and the experience was seamless! The team was professional, supportive, and quick to respond throughout the process. Highly recommend IncorpX for a smooth and stress-free company registration experience.
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Dia
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I'd been planning to register my Private Limited Company for months but didn't know where to start - until I found IncorpX. The team guided me step by step, explained everything clearly, and completed the registration smoothly within the promised timeline. Their pricing was transparent with no hidden charges. Highly recommend IncorpX to anyone starting a business!
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