What Is the Transaction Limit for Export Receipts via Cross-Border Payment Aggregators?

The PA-CB transaction limit for export receipts is a maximum of Rs 25 lakh per transaction processed by a cross-border payment aggregator. Paragraph 11(d) of the Master Direction applies this cap to both inward and outward transactions. A single export payment above Rs 25 lakh cannot go through a PA-CB.

• Exact wording: "In respect of inward or outward transactions processed by a PA - CB, the maximum value per transaction shall be ₹25 lakh" (paragraph 11(d)).
• Currency: The cap is stated in Indian rupees. A payment invoiced in US dollars, euros or pounds is measured against Rs 25 lakh, so the foreign currency amount that fits under the cap moves with the exchange rate.
• Who it binds: The cap is a rule for the PA-CB. A PA-CB facilitates aggregation of cross-border payments for current account transactions not prohibited under FEMA, for its onboarded merchants, through e-commerce mode (paragraph 4(i)(ii)).
• Exporters covered: The Master Direction defines a merchant to include exporters (paragraph 4(f)), so a freelancer or business selling to overseas buyers through a PA-CB is subject to the cap on each payment.
• Earlier rule: The 31 October 2023 PA-CB circular set the same Rs 25,00,000 figure, but as the maximum value per unit of goods or services sold or purchased (Annex, paragraph 8.2). That circular is now repealed.
• Card exclusion: A card transaction where the card network handles the foreign exchange settlement and the aggregator receives rupees is not PA-CB activity (Note 2 to paragraph 4(i)(ii)), so this cap is not the rule that governs it.

In short, Rs 25 lakh is the most a PA-CB can process in one export transaction. The cap sits in a payments regulation, so it limits the route, while your duties as an exporter under FEMA stay the same whatever route you use.

The PA-CB transaction limit applies to every transaction a PA-CB processes, whether the PA-CB is a bank or a non-bank. It reaches exporters indirectly, because it caps what their provider can collect in one payment. Payments received straight into a bank account, and card payments settled in rupees by a card network, fall outside the PA-CB rules.

The PA-CB transaction limit works as a ceiling on each payment the aggregator processes. If the rupee value of a single export payment is Rs 25 lakh or less, a PA-CB may process it. If the value is above Rs 25 lakh, the payment has to be received through a different route, such as a bank transfer.

1. Work out the rupee value of the payment you expect. For a foreign currency invoice, use a current exchange rate and allow a margin, because the rate can move before the buyer pays.
2. Compare that value with the Rs 25 lakh cap in paragraph 11(d). Ask your provider how it measures the rupee value for the cap, since the Master Direction does not say which rate is used.
3. If the value is within the cap, the buyer pays through the PA-CB. For a non-bank PA-CB, proceeds are credited to its Inward Collection Account with an AD Category-I bank (paragraph 16(a) and Table 1).
4. If the value is above the cap, ask the buyer to pay by bank transfer to your account, or agree genuine payment terms under the contract that suit the size of the deal.
5. Whatever the route, file the EDF and keep the realisation timeline. Service exporters file the EDF within 30 days of the end of the invoice month (FEMA Regulation 3(2)).

The key figures are the Rs 25 lakh cap per PA-CB transaction and the Rs 10 lakh threshold below which an EDPMS entry can be closed on the exporter's declaration. The cap has applied in its current per transaction wording since the Master Direction of 15 September 2025, which took effect immediately.

If an export payment is above the PA-CB transaction limit, the PA-CB cannot process it as a single transaction under paragraph 11(d). The buyer then needs to pay through another route. Your export obligations under FEMA do not change, so the money still has to be realised in time and the EDPMS entry closed.

• Payment blocked: The cap is a maximum per transaction (paragraph 11(d)). Expect the provider to decline or not offer collection for a single payment above Rs 25 lakh; confirm how your provider handles it.
• Delay risk: Switching routes late can push receipt past the realisation date. The full value must be realised within nine months of the invoice for services, unless the AD bank extends it (FEMA Regulation 5).
• Open entry: Your AD bank closes or updates the EDPMS entry when it credits the receipt (FEMA Regulation 4(2)). A payment that never arrives leaves the entry open.
• Long overdue: Proceeds unrealised for more than one year after the due or extended date restrict further exports to full advance or an irrevocable letter of credit (FEMA Regulation 13).
• Exchange moves: A foreign currency invoice priced just under Rs 25 lakh can go over the cap if the rupee weakens before payment, since the cap is fixed in rupees.

Check the rupee value of large invoices before you send them. Above Rs 25 lakh, give the buyer your bank account details for a direct transfer, tell your AD bank to expect the receipt, and ask the AD bank for an extension early if realisation will be late.

The RBI rule that sets the PA-CB transaction limit for exports is paragraph 11(d) of the Master Direction on Regulation of Payment Aggregators, dated 15 September 2025. It replaced the 2023 PA-CB circular and the OPGSP circulars. The FEMA export regulations in force from 1 October 2026 apply alongside it.

• Old limit: Quoting the USD 10,000 OPGSP limit as current. Since 2023 the figure has been Rs 25 lakh, now per transaction (paragraph 11(d)). See PA-CB vs OPGSP.
• Dollar thinking: Treating the cap as a fixed dollar amount. It is set in rupees, so the foreign currency headroom changes with the exchange rate.
• Repealed wording: Relying on the 2023 per unit wording. The 2023 circular was repealed by the Master Direction (Annexure 3).
• Late switch: Finding out at the payment stage that an invoice is over the cap. Check the value when you agree the contract, so the buyer can set up a bank transfer in time.
• Cap confusion: Mixing up the Rs 25 lakh PA-CB cap with the Rs 10 lakh EDPMS declaration threshold in FEMA Regulation 4(2). They are separate rules with separate purposes. See EDPMS closure.
• Skipping EDF: Assuming a payment within the cap needs no export paperwork. Service exporters still file the EDF (FEMA Regulation 3(2)). See EDF form.

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, CO.DPSS.POLC.No.S-633/02-14-008/2025-26, Paragraphs 2(a), 3(a), 4(f), 4(i)(ii) and Notes, 5(a), 11(d), 11(g), 11(i), 13(b), 16(a), 19, 21, Table 1, Annexure 3 (checked 8 Oct 2026)
2. Regulation of Payment Aggregator - Cross Border (PA - Cross Border), CO.DPSS.POLC.No.S-786/02-14-008/2023-24, Annex, paragraph 8.2 (checked 8 Oct 2026)
3. A.P. (DIR Series) Circular No. 17: Processing and Settlement of Export related receipts facilitated by Online Payment Gateways, Paragraph 2(ii) (checked 8 Oct 2026)
4. A.P. (DIR Series) Circular No. 109: Enhancement of the value of transaction, Paragraphs 1 and 2 (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(i) and 4(i) (checked 8 Oct 2026)
6. Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 (amended up to 22 September 2026), Regulations 3, 4(2), 5 and 13 (checked 8 Oct 2026)