Introduction

India's cross-border payments ecosystem has undergone significant regulatory transformation. On 31 October 2023, the Reserve Bank of India introduced the Payment Aggregator - Cross Border (PA-CB) framework, bringing entities facilitating online cross-border payment transactions directly under RBI regulation. This framework replaced the earlier OPGSP-led arrangement and introduced a dedicated authorization regime for cross-border payment aggregators.

Subsequently, RBI consolidated various payment aggregator regulations through the Master Direction on Regulation of Payment Aggregators, issued on 15 September 2025. The Master Direction established a unified framework covering Online Payment Aggregators, Physical Point-of-Sale Payment Aggregators, and Cross-Border Payment Aggregators.

For exporters, importers, SaaS businesses, marketplaces, freelancers, and digital service providers, understanding the PA-CB framework is essential for maintaining compliance while scaling international commerce. What Is a Cross-Border Payment Aggregator Authorization?

A Payment Aggregator - Cross Border (PA-CB) authorization allows eligible non-bank entities to facilitate online cross-border payment transactions related to the import and export of goods and services. Unlike domestic payment aggregators, PA-CBs operate in an environment that involves foreign exchange regulations, trade documentation requirements, FEMA compliance, and enhanced due diligence obligations.

Entities must be incorporated in India and comply with RBI requirements relating to governance, risk management, merchant onboarding, anti-money laundering controls, customer due diligence, and regulatory reporting. RBI Authorization Categories for Cross-Border Payment Aggregators

The RBI permits PA-CBs to operate under three categories depending on the direction of transaction flows.

PA-CB-E (Export Only)

This category is designed for entities facilitating inward payments from overseas buyers to Indian merchants, exporters, freelancers, and service providers.

Common use cases include:

• SaaS companies

• Freelancer platforms

• Service exporters

• Digital commerce businesses

Export transactions are processed through an Inward Collection Account (InCA) maintained with an Authorised Dealer Category-I Bank. The maximum transaction value is ₹25 lakh per transaction.

PA-CB-I (Import Only)

This category applies to entities facilitating payments from Indian buyers to overseas merchants for permissible import transactions.

Typical users include:

• Cross-border e-commerce platforms

• Import marketplaces

• International service procurement platforms

Import transactions are processed through an Outward Collection Account (OCA) maintained with an Authorised Dealer Category-I Bank. Enhanced due diligence may apply depending on transaction value and risk profile.

PA-CB-E&I (Export and Import)

This authorization covers both inward and outward cross-border payment flows and is suitable for international trade platforms, marketplaces, and multi-sided commerce ecosystems.

Entities operating under this category must maintain the required collection account structures and compliance processes for both export and import transactions.

Net Worth and Financial Requirements

The RBI prescribes minimum capital and net worth requirements for non-bank PA-CBs.

Existing Entities

• Minimum net worth of ₹15 crore at the time of application.

• Minimum net worth of ₹25 crore by 31 March 2026.

New Applicants

• Minimum net worth of ₹15 crore at the application stage.

• Minimum net worth of ₹25 crore by the end of the third financial year from authorization.

These thresholds are intended to ensure operational resilience and consumer protection across the payments ecosystem.

Operational Compliance Framework

PA-CBs operate under a detailed compliance framework designed to ensure accountability and transparency in cross-border transactions.

Key requirements include:

• Maintaining designated Inward Collection Account (InCA) & Outward Collection Account (OCA) with Authorised Dealer Category-I Banks.

• Processing only permissible transactions under applicable FEMA regulations and the Foreign Trade Policy.

• Conducting merchant due diligence and risk assessments.

• Implementing transaction monitoring and fraud-prevention controls.

• Complying with reporting and reconciliation obligations through regulated banking channels.

PA-CBs are not authorized to independently undertake foreign exchange activities and must work within the AD Category-I banking framework.

Regulatory Reporting and Oversight

Authorized PA-CBs operate under RBI supervision and are subject to compliance reviews, inspections, and reporting obligations.

Core responsibilities include:

• Registration with the Financial Intelligence Unit - India (FIU-IND).

• Compliance with AML and counter-terrorism financing requirements.

• Supporting FEMA-related reporting and reconciliation requirements through banking partners.

• Maintaining governance, grievance-redressal, and audit frameworks.

Application Process

Applications for PA authorization are submitted through RBI's PRAVAAH portal.

Typical documentation includes:

• Certificate of Incorporation

• Audited financial statements

• Net worth certification

• Board-approved policies

• Risk management framework

• Merchant onboarding framework

• AML and KYC controls

• FIU-IND registration details

• Fit-and-proper declarations for promoters and directors

Authorization timelines vary depending on the complexity of the application and RBI's review process.

Ongoing Compliance Obligations

Authorized PA-CBs must comply with ongoing operational and regulatory obligations, including:

• Governance and board oversight.

• Merchant onboarding controls.

• Information security and cybersecurity standards.

• Fraud prevention and transaction monitoring.

• Regulatory reporting requirements.

• AML monitoring and suspicious transaction reporting.

• Settlement and reconciliation controls.

• Customer grievance management systems.

Failure to maintain compliance may lead to supervisory action, including restrictions, suspension, or revocation of authorization.

KYC and Due Diligence Requirements for Cross-Border Transactions

PA-CBs must comply with RBI's KYC and customer due diligence requirements.

Merchant onboarding generally involves:

• Business registration verification.

• Identity verification of directors and authorized representatives.

• Beneficial ownership identification.

• Confirmation of business activities.

• Risk classification and ongoing monitoring.

For higher-risk or higher-value transactions, enhanced due diligence may be required, including additional documentation and verification procedures.

All records must be maintained in accordance with applicable regulatory and record-retention requirements.

Choosing a Cross-Border Payment Partner

Businesses evaluating a payment partner should independently verify:

• RBI authorization status.

• Banking partnerships.

• Compliance capabilities.

• Settlement timelines.

• Security certifications.

• Foreign currency support.

• Merchant onboarding processes.

Working with an RBI-authorized payment service provider can help simplify compliance, reconciliation, settlement management, and international payment processing.