Compliance & Regulation

RBI Payment Aggregator Guidelines: A Guide for Startups

Who counts as a payment aggregator under RBI's 2025 directions, what authorisation requires, and how marketplaces and platforms can collect and split payments without a licence.

Purushottam Kumar Suman
Purushottam Kumar Suman
Founder & CEO, Drema AI
8 min read
Payment terminal and card

If your platform collects money from customers and passes it on to sellers, service providers or other third parties, you may be acting as a payment aggregator. RBI regulates that activity, and in September 2025 it issued a consolidated Master Direction on Regulation of Payment Aggregators. For most startups the right answer is not to become one, but you need to understand the rules to design payments correctly.

01

What a payment aggregator is

A payment aggregator, or PA, enables merchants to accept payments without setting up their own payment integration. It receives funds from customers, pools them and settles to merchants after a time. A payment gateway, by contrast, provides only technology to route transactions and never handles funds. The 2025 directions recognise three kinds of PA.

PA-OnlineAggregation for online and e-commerce transactions
PA-PhysicalAggregation for face-to-face, proximity payments, brought under regulation in 2025
PA-Cross BorderAggregation for import and export payments, inward and outward
02

What authorisation requires

Banks do not need separate authorisation for PA business. Non-bank entities do, and the bar is high.

Net worth₹15 crore at the time of application and ₹25 crore by the end of the third financial year after authorisation
Escrow accountMerchant funds kept in an escrow account with a scheduled commercial bank, used only for permitted credits and debits
Merchant due diligenceKYC of merchants in line with RBI's KYC rules, with ongoing monitoring
GovernanceFit and proper promoters and directors, board-approved policies
SecurityInformation security standards, audits and incident reporting
Dispute and grievance handlingA dispute resolution mechanism and nodal officer
CertificationAuditor certificates on escrow balances and compliance at set intervals
₹15 crore
Net worth at application
₹25 crore
By end of third financial year
Escrow
Merchant funds held separately
03

Does your marketplace need a PA licence?

Marketplaces were the reason these rules were first written. RBI's position since 2020 has been that an e-commerce marketplace collecting money for sellers is doing PA business, and should either separate that activity and get authorised, or use an authorised PA. Selling your own goods or services and collecting your own revenue is not aggregation.

The question is simple: whose money sits in your bank account, and for how long?

You sell your own productNot a PA. Use any payment gateway or aggregator as a merchant
You collect for third-party sellersPA activity. Use an authorised PA's marketplace settlement product
You hold customer money in your own current account before paying sellersThe pattern to avoid
04

The practical route: split settlements

Authorised PAs offer split or route settlement. The customer pays once; the PA holds funds in its escrow account and settles the seller's share to the seller and your commission to you. Each seller is onboarded as a sub-merchant with KYC. Your platform never holds seller funds, and you stay outside PA regulation.

Seller onboarding with KYCSplit rules per orderCommission to platformRefund handling across splitsSettlement reports per sellerTDS and GST on commissionHold and release for delivery confirmation
05

Rules that affect every merchant

Even as a merchant using a PA, some rules shape your product.

No card storageMerchants and PAs cannot store card details; use network tokenisation for saved cards
Recurring paymentsE-mandates need registration with additional authentication and pre-debit notifications
Refunds to sourceRefunds go back to the original payment method unless the customer has agreed otherwise
Merchant KYCExpect your PA to ask for business documents, website checks and periodic updates
06

Cross-border payments

Platforms that collect from overseas customers for Indian sellers, or from Indian customers for overseas merchants, fall under the PA-Cross Border category. Such entities keep separate collection accounts for inward and outward flows, and transactions are subject to a per-transaction value limit. Exporters and SaaS companies usually work with an authorised PA-CB rather than seeking authorisation themselves.

Sources · last reviewed October 1, 2026

This article explains what to build, not legal advice. Rules change; confirm against the current official text before relying on it.

Purushottam Kumar Suman
Written by
Purushottam Kumar Suman
Founder & CEO, Drema AI

Founder and CEO of Drema AI. Builds AI systems, SaaS platforms and industry software — and writes about what actually survives production.

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