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16 Sep 2025

RBI’s Final Payment Rules Out: What Do New Capital Norms and Cross-Border Limits Mean for Aggregators?

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Fresh regulations by RBI in 2025 create stricter capital rules, new categories and tighter cross-border checks for digital payment aggregators.

How much trust should one place in the companies that handle billions in online payments every day? This question gained sharp focus when the Reserve Bank of India (RBI) announced its final RBI norms for payment gateways in January 2025. 

The move has reshaped the space for non-bank entities that process payments between merchants and customers.

The Fresh Rules In RBI Payment Aggregator Guidelines 2025

The RBI issued the RBI payment aggregator guidelines 2025 under the Regulation of Payment Aggregators Directions, 2025. The official report was released in January 2025 and became effective at once. These rules require non-bank payment aggregators to show strong financial health before receiving authorisation.

According to the new framework, they must have a minimum net worth of ₹15 crore at the time of applying for authorisation. Within three financial years, the requirement rises to ₹25 crore. Non-banks must apply before 31 December 2025. If they fail, they will have to close operations by 28 February 2026.

Banks do not need to apply separately since they are already regulated under banking law. This difference sets the stage for a divided industry where smaller non-banks may struggle while large banks continue without extra hurdles.

The staged capital requirements are explained below.
 

Requirement

Who Must Comply

Timeline

Value

Net worth at application

Non-bank PAs

When applying

₹15 crore

Net worth increase

Non-bank PAs

Within 3 financial years

₹25 crore

Deadline to apply

Non-bank PAs

31 Dec 2025

Mandatory

Closure if not compliant

Non-bank PAs

28 Feb 2026

Exit business


This table makes it clear that financial strength is now the ticket to survival. Smaller fintechs may face pressure to raise funds or merge with larger players.

RBI Expands Payment Aggregator Framework with New Categories

A payment aggregator is a company that collects payments on behalf of merchants and transfers them to bank accounts. These can be online players, physical point-of-sale companies or firms handling cross-border trade. The RBI has now split them into three categories.
 

Category

Short Form

Scope

Example

Online Aggregator

PA-O

Internet-based merchant payments

E-commerce platforms

Physical Aggregator

PA-P

In-person transactions

Retail stores

Cross-Border Aggregator

PA-CB

Inward and outward global flows

Export services


The addition of PA-CB or cross-border aggregator is the most striking. Earlier, the framework only covered domestic online transactions. With international payments now included, the RBI cross-border payment transaction rules have been tightened.

This covers reporting of all overseas inflows and outflows, strict merchant checks through Know Your Customer (KYC) rules, and limits on transaction size. 

The RBI has not yet published exact per-transaction caps in its January 2025 report, but media sources have confirmed that caps will apply depending on the merchant risk category.

Tracing RBI’s Payment Regulation Journey (2020–2025)

The move to regulate aggregators fits into RBI’s broader track record of tightening payment rules over the last five years. In 2020, draft guidelines were floated for online players. In 2023, prepaid wallet norms were revised, adding escrow requirements and reporting obligations.

This current direction connects strongly with earlier actions. A Loansjagat report titled “Paytm Receives RBI’s In-Principle Approval for Online Payment Aggregator Licence” highlighted how the regulator has been gradually extending its oversight across the payments ecosystem. That development showed the RBI’s intention to tighten compliance and consumer protection in the payments space.

The similarity lies in RBI’s focus on consumer protection and fund security. Both wallets in 2023 and aggregators in 2025 are asked to maintain escrow accounts and grievance policies.

The latest rules expand the coverage to merchants who operate across borders. This is a natural extension of earlier measures and shows that RBI is moving in a step-by-step fashion, tightening one segment after another.

Past Reactions Of Banks And Government

The reaction pattern has also remained steady. In 2020, when RBI first issued draft norms for aggregators, banks welcomed them since they were already regulated. Non-banks voiced concern about the cost. In 2023, fintech wallet firms said that higher capital norms were unfair to smaller players. Government officials supported RBI by citing financial security.

The January 2025 report is being received in a similar way. Banks are unaffected since they do not need new licences. Non-banks again face the heavy lift of raising capital. Government has backed the RBI, saying India must protect the integrity of its digital payment network as transaction volumes expand.

The governance side is equally tough. The report asks boards of payment aggregators to approve consumer grievance policies, track refunds, and ensure promoter eligibility through “fit and proper” norms.
 

Governance Area

New Requirement

Objective

Result

Escrow Account

All aggregators must maintain

Safer flow of merchant funds

Transparency

Grievance Policy

Board approval required

Stronger consumer protection

Faster refunds

Promoter Norms

Fit and proper criteria

Healthy ownership

Stability


This focus on governance shows that RBI is not only tightening financial rules but also setting behavioural standards.

A Closer Look At The Cross-Border Impact

Cross-border flows have always worried the central bank. Fraud, money laundering and unauthorised remittances often travel through weak payment pipes. The creation of PA-CB is designed to plug these gaps. Reporting, due diligence and caps will restrict misuse.
 

Element

PA-CB Rule

Impact

Reporting

Mandatory disclosure of inflows and outflows

Better tracking

Due Diligence

Strict KYC for merchants

Lower fraud risk

Transaction Caps

RBI to notify limits

Safer money movement


The cross-border framework connects with India’s global trade push. As more small firms export digital services, reliable channels become necessary. The RBI norms now give them legitimacy while screening out unsafe operators.

Conclusion

The RBI regulations for digital payment aggregators issued in January 2025 have changed the landscape of Indian payments. The capital requirements for payment aggregators ensure that only strong firms remain in business. The introduction of RBI cross-border payment transaction rules expands oversight to international trade. 

The categories of PA-O, PA-P and PA-CB under the final RBI norms for payment gateways show that regulation has reached a more refined stage.

By comparing past moves and reactions, one can see the same cycle repeat. Smaller players fear costs, banks remain comfortable, and the government supports RBI for safety reasons. What is new this time is the clear focus on cross-border risk. The market will now see fewer but stronger aggregators who can meet the tables of rules and serve merchants with more reliability.
 

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