Export Services India

What Are the Settlement Timelines for Cross-Border Payment Aggregators Under RBI Rules?

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Short answer

The PA-CB settlement timeline is not a fixed number of days under current RBI rules. RBI's 2025 Master Direction on Payment Aggregators leaves the credit to the merchant's account to the agreement between the aggregator and the merchant. That agreement must be fair and equitable. It must also state the settlement timelines transparently.

What do RBI rules require on settlement timelines for cross-border payment aggregators?

RBI rules require a cross-border payment aggregator to settle funds to the merchant within the timeline written in its agreement with that merchant. The current Master Direction does not fix a T+1 or seven-day limit for PA-CBs. It sets conditions on how the money is held before settlement and where it can be paid.

  • Agreement: Credit to the merchant's account is "as per the agreement between the PA and the merchant", and the agreement should be fair, equitable and must transparently mention the settlement timelines (Table 1, Timelines, Master Direction on Payment Aggregators).
  • Day-end balance: The day-end balance in the escrow account cannot be less than the amount realised towards funds payable to merchants but not yet settled to them (Table 1). Unsettled merchant money must stay in the account.
  • Own account: The aggregator must have validation mechanisms so that funds due to a merchant are credited only to the merchant's bank account (paragraph 13(g)).
  • Merchant list: The aggregator gives the escrow bank a list of onboarded merchants and updates it before initiating settlement. The bank must ensure payments go only to eligible merchants (paragraph 18(a)).
  • Currency: Settlement in currencies other than rupees is allowed only for Indian exporters directly onboarded by the PA-CB facilitating inward transactions (paragraph 11(i)).
  • No interest: No interest is payable on balances in an Inward Collection Account (Table 1, Interest-bearing), so funds waiting for settlement earn nothing for the exporter.
  • Bank change: If an aggregator moves its escrow account to another bank, the move must be time-bound and must not affect the payment cycle to merchants (paragraph 18(f)).

The PA-CB rules govern the provider and its bank. The exporter's own deadlines come from the FEMA export regulations, and the realisation period for services counts from the invoice date, so the settlement date does not reset that period.

Who do the PA-CB settlement timeline rules apply to?

The PA-CB settlement timeline rules apply to the aggregator that collects the payment and to the AD Category-I bank that holds its collection account. Exporters are bound by the agreement they sign with the aggregator, and the route by which they were onboarded decides whether they can be settled in foreign currency.

How does settlement of an export payment through a PA-CB work, step by step?

Settlement of an export payment through a PA-CB runs from the buyer's payment to the aggregator's Inward Collection Account, then to the exporter's own bank account on the agreed timeline. The exporter's AD bank then closes the export entry in EDPMS using information the aggregator provides.

  1. At onboarding, the exporter signs an agreement that must state the settlement timeline (Table 1) and cover refunds, failed transactions, reconciliation and grievance redressal (paragraph 8(b)).
  2. The overseas buyer pays through the aggregator, and the payment is to be identified as a cross-border transaction from timelines RBI specifies (paragraph 11(g)).
  3. The proceeds are credited to the aggregator's Inward Collection Account, kept separately for rupees and for each foreign currency (Table 1). Inward and outward funds are never mixed or netted (paragraph 11(a)).
  4. Any currency conversion is done only with an Authorised Dealer (paragraph 11(d)).
  5. On the agreed date, the aggregator pays the exporter from the InCA, which is a permitted debit, into the exporter's own bank account (Table 1 and paragraph 13(g)).
  6. The aggregator provides the documents or information the exporter's AD bank needs to close the EDPMS entry (paragraph 11(h)).
  7. The AD bank credits the exporter after satisfying itself that the transaction is genuine and simultaneously closes or updates the EDPMS entry (FEMA Regulation 4(2)).

Does T+1 settlement still apply to cross-border payment aggregators?

T+1 settlement no longer applies as an RBI rule for PA-CBs. The 2020 payment aggregator guidelines set T+1 style limits and also governed the domestic leg of import and export payments (paragraphs 2.2 and 8.4). The 2023 PA-CB circular applied other PA instructions to PA-CBs (paragraph 8.3). Both circulars were repealed by the 2025 Master Direction (Annexure 3).

  • Tp: date of charge or debit to the customer's account; funds to reach escrow on Tp+0 or Tp+1 basis.
  • Ts: date the merchant tells the aggregator about shipment; Ts+1 applied where the aggregator delivered.
  • Td: date the merchant confirms delivery; Td+1 applied where the merchant delivered.
  • Tr: date the merchant's refund period expires; Tr+1 applied where the agreement let the aggregator hold funds until then.

What was the seven-day rule for OPGSP export settlement?

The seven-day rule required balances in the OPGSP NOSTRO collection account to be credited to the exporter's account in India immediately on the importer's confirmation, and never later than seven days from credit to that account (2010 circular, paragraph 2(vi)). The 2015 circular kept seven days for exports (paragraph 4(iii)). These circulars were repealed in 2025, except for saved entities (paragraph 19).

How do refunds and chargebacks affect PA-CB settlement?

Refunds and chargebacks can reduce or reverse what is settled to the exporter. Refunds initiated by merchants for failed, disputed, returned or cancelled transactions are permitted credits to the collection account, and refunds to payers are permitted debits (Table 1). Reversed and refund transactions are routed back through the escrow account unless the merchant manages the refund directly, and customers' chargeback rights remain unaffected (paragraph 18(h)).

  • Refunds go to the original method of payment unless the payer asks for another mode belonging to the payer (paragraph 10(f)).
  • The aggregator's dispute mechanism must include timelines for processing refunds and follow RBI's TAT instructions for failed transactions (paragraph 8(a)).

Can a PA-CB hold export proceeds until a refund period ends?

The current Master Direction has no separate rule on holding funds until a refund period ends, so any holding period depends on the merchant agreement and its stated settlement timeline (Table 1). The repealed 2020 guidelines had allowed this where the agreement provided for it, with payment no later than Tr+1 (paragraph 8.4.3).

What are the key dates and deadlines around a PA-CB export settlement?

The key dates around a PA-CB export settlement are the agreed settlement date, the EDF deadline for services, the EDPMS closure at the time of credit and the nine-month realisation period. Only the first comes from the payment aggregator rules; the rest come from the FEMA export regulations in force from 1 October 2026.

What happens if a PA-CB settles export proceeds later than the agreed timeline?

If a PA-CB settles later than the agreed timeline, the Master Direction itself names no compensation payable to the exporter for that delay. The remedy lies in the agreement and the aggregator's grievance process. Meanwhile the exporter's FEMA realisation period keeps running from the invoice date.

  • Realisation clock: Services exports must be realised within nine months of the invoice date, or twelve months if invoiced or settled in rupees (FEMA Regulation 5(1)). A delayed payout does not pause this period.
  • Open EDPMS: The AD bank marks off the EDPMS entry only after ensuring that the export value has been realised (FEMA Regulation 18(1)(g)), so the entry stays open until the credit arrives. See EDPMS closure.
  • Grievance route: Every aggregator must appoint an officer for merchant issues and display that officer's details and an escalation matrix on its website (paragraph 8(d)).
  • Policy disclosure: The aggregator must publish its merchant policies and other terms on its website or app (paragraph 8(c)), which is where the settlement terms should be visible.
  • Failed payments: RBI's TAT framework sets outer limits for resolving failed transactions, but it covers only domestic transactions where both originator and beneficiary are in India (TAT circular, paragraph 4 and Annex note 7). For a delayed cross-border payout, rely on the agreement.
  • Long overdue: If proceeds remain unrealised for over one year after the due or extended date, further exports need full advance or an irrevocable letter of credit (FEMA Regulation 13). See export proceeds not realised.

Ask the aggregator in writing for the settlement timeline in your agreement and the status of the delayed payout, then use its escalation matrix. If the realisation deadline is close, ask your AD bank for an extension under FEMA Regulation 5 before it passes. See extension of the export realisation period.

Which RBI rule sets the settlement timeline for cross-border payment aggregators?

The RBI rule that sets the settlement timeline for cross-border payment aggregators is Table 1 of the Master Direction on Regulation of Payment Aggregator dated 15 September 2025. It leaves the timeline to the merchant agreement. The older T+1 and seven-day limits sat in circulars that the Master Direction repealed.

What mistakes do exporters make about PA-CB settlement timelines?

  • Assuming T+1: Quoting T+1 as an RBI guarantee. The T+1 rules sat in the 2020 guidelines, repealed by the 2025 Master Direction (Annexure 3).
  • Seven-day rule: Relying on the OPGSP seven-day limit. Those circulars are repealed except for saved entities with pending PA-CB applications (paragraph 19). See PA-CB vs OPGSP.
  • Unread terms: Not reading the settlement clause before onboarding. The agreement is where the timeline is fixed (Table 1).
  • Wrong clock: Treating the payout date as the start of the realisation period. For services it runs from the invoice date (FEMA Regulation 5(1)). See export realisation period.
  • Third-party payout: Asking for proceeds to go to a relative's or partner's account. Funds due to a merchant go only to the merchant's bank account (paragraph 13(g)), and third-party payouts are not a permitted InCA debit (Table 1).
  • Currency expectation: Expecting foreign currency credit when onboarded through a marketplace. Non-rupee settlement is only for directly onboarded exporters (paragraph 11(i)).
  • Skipping EDF: Waiting for the payout before filing the EDF for software exports. The EDF is due within 30 days from the end of the invoice month (FEMA Regulation 3(2)). See EDF form.

How did we verify this?

Every rule, deadline and form on this page is linked to its official source, checked on the dates below.

  1. Master Direction on Regulation of Payment Aggregator (PA), RBI/DPSS/2025-26/141, Paragraphs 4(i)(ii) Note 2, 5(a), 8, 10(f), 11, 13(d), 13(g), 16(a), 18, 19, 21, Table 1, Annexures 2 and 3 (checked 8 Oct 2026)
  2. Regulation of Payment Aggregator - Cross Border (PA - Cross Border), RBI/2023-24/80, Paragraphs 5.4, 8.3 and 8.4 (checked 8 Oct 2026)
  3. Guidelines on Regulation of Payment Aggregators and Payment Gateways, RBI/DPSS/2019-20/174 (updated 17 November 2020), Paragraphs 1.2, 2.2, 8.3 and 8.4 (checked 8 Oct 2026)
  4. A.P. (DIR Series) Circular No. 17: Processing and Settlement of Export related receipts facilitated by Online Payment Gateways, Paragraph 2(vi) (checked 8 Oct 2026)
  5. A.P. (DIR Series) Circular No. 16: Processing and settlement of import and export related payments facilitated by OPGSPs, Paragraphs 3(ii) and 4(iii) (checked 8 Oct 2026)
  6. Harmonisation of Turn Around Time (TAT) and customer compensation for failed transactions using authorised Payment Systems, RBI/2019-20/67, Paragraphs 4 to 6 and Annex general instruction 7 (domestic transactions only) (checked 8 Oct 2026)
  7. Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 (amended up to 22 September 2026), Regulations 3(2), 4(2), 5(1), 13 and 18(1) (checked 8 Oct 2026)
  8. A.P. (DIR Series) Circular No. 20: Export and Import of Goods and Services, RBI/2025-26/194, Paragraphs 4 and 7 (checked 8 Oct 2026)
  9. RBI: Status of applications received from Payment Aggregators (as on 01.10.2026), Table D and PA-CB entries (checked 8 Oct 2026)

Frequently asked questions

Is the PA-CB settlement timeline the same as the FEMA export realisation period?

The PA-CB settlement timeline is not the same as the FEMA export realisation period. The settlement timeline is set in your agreement with the aggregator. The realisation period is nine months from the invoice date for services, or twelve months if invoiced or settled in rupees, and your AD bank can extend it.

Does a PA-CB pay interest on export proceeds held in the Inward Collection Account?

A PA-CB does not pay interest on export proceeds held in the Inward Collection Account. Table 1 of RBI's Master Direction says no interest shall be payable on InCA balances. The interest exception for the core portion applies only to the domestic escrow account, so money waiting for settlement earns nothing for the exporter.

Can a PA-CB settle export proceeds to a family member's bank account?

A PA-CB cannot settle export proceeds to a family member's bank account on your instruction. Paragraph 13(g) of the Master Direction requires funds due to a merchant to reach the merchant's own bank account. Table 1 also excludes third-party payouts from permitted InCA debits. Separate FEMA rules govern third-party receipts through AD banks.

When does the AD bank close the EDPMS entry for a PA-CB receipt?

The AD bank closes or updates the EDPMS entry for a PA-CB receipt at the same time it credits your account, under FEMA Regulation 4(2). The aggregator must supply the documents or information the bank needs. For invoices up to Rs 10 lakh, the bank can close the entry based on your declaration of realisation.

Can a PA-CB pause settlement while moving its InCA to another bank?

A PA-CB moving its InCA or other escrow account to another bank must do it in a time-bound manner without affecting the payment cycle to merchants, under advice to RBI. This is paragraph 18(f) of the Master Direction. A bank change is therefore not a permitted reason to stop settling merchants on the agreed timeline.

Who settles an exporter onboarded through a marketplace under the PA-CB rules?

An exporter onboarded through a marketplace or another aggregator is paid through that onboarding entity. The InCA can pay another PA as part of the transaction flow for ultimate settlement to the merchant. Settlement in a foreign currency is allowed only for exporters directly onboarded by the PA-CB, so such exporters are settled in rupees.

Where can an exporter check whether a PA-CB is authorised or still awaiting a decision?

An exporter can check a PA-CB on RBI's page listing the status of applications from payment aggregators under the Payment and Settlement Systems Act, 2007. It shows existing and new PA-CBs in separate tables. The status matters because the old OPGSP circulars still apply to existing applicants with pending decisions.