What Is the Difference Between PA-CB and OPGSP Under RBI Rules?
- Author:
- Manoj Sharma
- Verified by:
- Editorial team
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Short answer
The difference between PA-CB and OPGSP is who RBI regulates. Under the OPGSP circulars, an AD bank ran a standing arrangement with an online gateway and answered for it. Under the PA-CB rules, the cross-border payment aggregator itself needs RBI authorisation. The OPGSP circulars were repealed in September 2025, with a saving for pending applicants.
| Applies to | Governed by | Deadline | Penalty | Last verified |
|---|---|---|---|---|
| Bank and non-bank entities that collect cross-border online payments for Indian exporters, the AD Category-I banks that hold their collection accounts, and exporters paid through them | Master Direction on Regulation of Payment Aggregators, 15 September 2025, issued under the Payment and Settlement Systems Act, 2007 and FEMA, 1999. It repealed the OPGSP circulars of 2010, 2013 and 2015 | Not applicable as a filing deadline for exporters. Existing non-bank cross-border platforms had to apply for PA-CB authorisation by 30 April 2024 (2023 PA-CB circular, Annex paragraph 2.2) | No penalty for exporters in the PA-CB rules. Exports unrealised for over one year past the due or extended date limit future exports to full advance or an irrevocable letter of credit (FEMA Regulation 13) | 8 Oct 2026 |
What is the difference between a PA-CB and an OPGSP under RBI rules?
A PA-CB is a payment aggregator that RBI authorises and regulates directly for cross-border e-commerce payments. An OPGSP, or Online Payment Gateway Service Provider, worked through a standing arrangement with an AD Category-I bank, and RBI's OPGSP instructions were addressed to that bank. The rest of the differences flow from that change.
- OPGSP model: RBI first let AD Category-I banks repatriate export receipts by entering into standing arrangements with OPGSPs in 2010 (A.P. (DIR Series) Circular No. 17, 16 November 2010). The bank did the due diligence on the OPGSP and opened the collection account.
- Bank in charge: The 2015 OPGSP circular told AD banks to vet each OPGSP, keep separate export and import collection accounts for it, check purpose codes, and reconcile and audit the accounts every quarter (A.P. (DIR Series) Circular No. 16, paragraph 2.1).
- PA-CB model: In October 2023 RBI decided to bring all entities facilitating cross-border payments for import and export of goods and services under its direct regulation, and to treat them as PA-CBs (PA-CB circular of 31 October 2023, paragraph 3).
- Current definition: A PA-CB is a payment aggregator that facilitates aggregation of cross-border payments for current account transactions not prohibited under FEMA, for its onboarded merchants, through e-commerce mode (Master Direction, paragraph 4(i)(ii)).
- Authorisation: A bank does not need authorisation to act as a payment aggregator. A non-bank must apply to RBI through its online portal and be a company incorporated in India (Master Direction, paragraphs 5(a) to 5(c)).
- Repeal: The three OPGSP circulars of 2010, 2013 and 2015 are repealed, except for an existing PA-CB that applied for authorisation on or before 30 April 2024 and is still awaiting RBI's decision (Master Direction, paragraph 19).
For an exporter, the practical change is that a non-bank platform collecting your money is now answerable to RBI for its capital, governance, merchant checks and escrow accounts. Your own duties under FEMA, such as declaring the export and realising the money on time, did not move to the platform.
Who is affected by the move from OPGSP to PA-CB rules?
The move from OPGSP to PA-CB rules mainly affects the platforms and their banks. Non-bank platforms now need RBI authorisation, AD banks keep a monitoring role, and exporters are affected indirectly through onboarding checks, transaction limits and how funds are settled to them.
| Entity type | Under OPGSP circulars | Under PA-CB rules | Best for |
|---|---|---|---|
| Non-bank cross-border platform | Worked through an AD bank's standing arrangement; a foreign OPGSP needed an RBI-approved liaison office in India (2015 circular, paragraph 2.2) | Needs RBI authorisation, Rs 15 crore net worth at application and Rs 25 crore by the end of the third financial year after authorisation (Master Direction, paragraphs 5 and 6) | Exporters checking whether a platform is regulated |
| Bank acting as payment aggregator | Offered the OPGSP facility through standing arrangements and reported each arrangement to RBI's Foreign Exchange Department (2015 circular, paragraph 2.1) | No separate authorisation needed (Master Direction, paragraph 5(a)) | Exporters collecting through their own bank's online checkout |
| AD Category-I bank holding collection accounts | Opened a NOSTRO collection account abroad and an export collection account in India (2015 circular, paragraph 4) | Holds the Inward Collection Account and must ensure FEMA requirements are met, using automated processes to fetch information from the PA-CB (Master Direction, paragraphs 11(e) and 11(f)) | Understanding who reports and closes your export entry |
| Indian exporter or freelancer | Onboarded by the OPGSP after due diligence; any notional account had to sweep funds to the bank's NOSTRO account (2015 circular, paragraphs 2.2 and 4(ii)) | Treated as a merchant; the PA-CB does customer due diligence and credits funds only to the merchant's bank account (Master Direction, paragraphs 13(a) and 13(g)) | Freelancers and small exporters selling online |
| Platform that applied by 30 April 2024 and awaits a decision | OPGSP circulars still apply to it | Repeal of the OPGSP circulars does not apply to it until RBI decides (Master Direction, paragraph 19) | Exporters whose platform shows as under process on RBI's list |
| Card payment where a card network handles the foreign exchange settlement and the aggregator receives local currency | No specific rule for this case in the OPGSP circulars | Not PA-CB activity (Note 2 to paragraph 4(i)(ii)) | Sellers accepting foreign cards through a domestic acquirer |
How did RBI rules for cross-border payment platforms change from OPGSP to PA-CB?
RBI rules for cross-border payment platforms changed in stages over fifteen years. Bank-led OPGSP arrangements started in 2010, export limits rose in 2013, imports were added in 2015, direct PA-CB regulation arrived in October 2023, and a single Master Direction replaced the earlier circulars in September 2025.
- 16 November 2010: RBI allowed AD Category-I banks to offer export receipt facilities through standing arrangements with OPGSPs, for exports of value not exceeding USD 500, with funds repatriated within seven days (A.P. (DIR Series) Circular No. 17).
- 11 June 2013: the value per transaction for export receipts through OPGSPs, set at USD 3,000 by A.P. (DIR Series) Circular No. 35 of 14 October 2011, was raised to USD 10,000 (A.P. (DIR Series) Circular No. 109, paragraph 2).
- 24 September 2015: RBI added an import facility of up to USD 2,000 and consolidated the OPGSP rules, keeping the USD 10,000 export limit per transaction (A.P. (DIR Series) Circular No. 16, paragraphs 3 and 4).
- 7 April 2022: RBI issued a draft circular for feedback on 'Online Export-Import Facilitators (OEIF) (erstwhile OPGSP)', which the October 2023 circular lists among its references (PA-CB circular, paragraph 1).
- 31 October 2023: RBI brought cross-border payment entities under direct regulation as PA-CBs, with export only, import only, and export and import categories, and a 30 April 2024 deadline for existing non-banks to apply (PA-CB circular, paragraph 3 and Annex paragraph 2.2).
- 31 July 2024: existing non-bank PA-CBs that could not meet the net worth rule or did not apply in time had to wind up PA-CB activity by this date (PA-CB circular, Annex paragraph 3.4).
- 15 September 2025: the Master Direction on Regulation of Payment Aggregators consolidated the PA rules, repealed the 2023 PA-CB circular and the OPGSP circulars, and saved approvals already granted (Master Direction, paragraphs 19, 21 and 22).
How did an export payment move under the old OPGSP arrangement?
Under the OPGSP arrangement, the buyer's payment went into a NOSTRO collection account opened abroad by the AD bank. It was then brought into an export collection account in India and credited to the exporter's bank account (2015 circular, paragraph 4).
- Funds had to reach the exporter within seven days of credit to the NOSTRO account (paragraph 4(iii)).
- No money could be kept in notional accounts the exporter held with the OPGSP; receipts were swept to the NOSTRO account (paragraph 4(ii)).
- Permitted debits were payments to exporters, the OPGSP's commission and chargebacks to the overseas buyer (paragraph 4(iv)).
How does an export payment move through a PA-CB today?
Today the payment goes into the PA-CB's Inward Collection Account (InCA) with an AD Category-I scheduled commercial bank, kept separately for rupees and for each foreign currency (Master Direction, paragraph 16(a) and Table 1). The PA-CB then settles the money to the exporter's bank account.
- Settlement timing follows the agreement between the PA-CB and the merchant, which must be fair and state the timeline clearly (Table 1). See PA-CB settlement timelines.
- Inward and outward funds must be kept apart, with no co-mingling or netting (paragraph 11(a)).
- Foreign currency is bought or sold only with an Authorised Dealer (paragraph 11(d)).
How did the transaction limit change from OPGSP to PA-CB?
The export limit moved from USD 10,000 per transaction under the OPGSP circulars (2015 circular, paragraph 4(i)) to Rs 25 lakh per transaction for a PA-CB (Master Direction, paragraph 11(d)). The 2023 circular had expressed Rs 25 lakh as a maximum value per unit of goods or services (Annex paragraph 8.2). See PA-CB transaction limits.
What does PA-CB authorisation mean for an exporter using a cross-border platform?
PA-CB authorisation means RBI has checked the platform against its capital, governance, security and merchant due diligence rules. It does not take over the exporter's FEMA duties. Service exporters still file the EDF within 30 days from the end of the invoice month (FEMA Regulation 3(2)) and realise the money on time.
- You will be asked for KYC, and the PA-CB first retrieves your record from CKYCR with your consent. If that record is not available, merchants with annual turnover up to Rs 40 lakh, or annual export turnover up to Rs 5 lakh, can be onboarded through a simpler PAN, contact point verification and one officially valid document route (Master Direction, paragraph 13(b)).
- The PA-CB must give your AD bank the documents or information needed to close your EDPMS entry (paragraph 11(h)).
- Foreign currency settlement is allowed only for Indian exporters onboarded directly by the PA-CB (paragraph 11(i)).
- You can check a platform's status on RBI's list of payment aggregator applications. See how to check RBI authorisation.
What are the main rule differences between OPGSP and PA-CB for export receipts?
The main rule differences between OPGSP and PA-CB are the regulated party, the limit, the accounts and the settlement timeline. OPGSP rules were set by RBI's foreign exchange side for AD banks. PA-CB rules come from RBI's payment systems side and bind the aggregator directly.
| Item | OPGSP rule | PA-CB rule | Best for |
|---|---|---|---|
| Who RBI regulates | The AD Category-I bank running the arrangement (2015 circular, paragraph 2.1) | The aggregator itself, plus AD banks to the extent specified (Master Direction, paragraph 3) | Understanding who is accountable for your money |
| Legal basis | FEMA, 1999 sections 10(4) and 11(1) (2015 circular, paragraph 6) | Payment and Settlement Systems Act, 2007 and FEMA, 1999 (Master Direction covering letter) | Reading the rules in the right source |
| Export limit | USD 10,000 per transaction (2015 circular, paragraph 4(i)) | Rs 25 lakh per transaction (Master Direction, paragraph 11(d)) | Exporters with large single invoices |
| Collection accounts | NOSTRO account abroad, then an export collection account in India (2015 circular, paragraph 4) | Inward Collection Account with an AD Category-I bank, separate for rupees and each foreign currency, no interest and no pre-funding (Master Direction, Table 1) | Knowing where funds sit before settlement |
| Settlement to exporter | Within seven days of credit to the NOSTRO account (2015 circular, paragraph 4(iii)) | As per the agreement between the PA-CB and the merchant (Master Direction, Table 1) | Exporters who need predictable cash flow |
| Merchant checks | OPGSP to onboard sellers with appropriate due diligence (2015 circular, paragraph 2.2(iv)) | Customer due diligence under RBI's KYC Master Direction, using CKYCR with consent (Master Direction, paragraph 13(a)) | Freelancers preparing for onboarding |
| Capital | No net worth rule; the OPGSP had to create a reserve fund suited to its return and refund policy (2015 circular, paragraph 2.2(iii)) | Rs 15 crore at application; Rs 25 crore by the end of the third financial year (Master Direction, paragraph 6(a)) | Judging the scale of a regulated platform |
| Export data closure | Bank to check bona fides and correct purpose codes (2015 circular, paragraph 2.1(iii)) | PA-CB to supply documents or information to the exporter's AD bank for EDPMS closure (Master Direction, paragraph 11(h)) | Exporters closing EDPMS entries |
What happens to an exporter if a cross-border platform is not authorised as a PA-CB?
If a cross-border platform is not authorised as a PA-CB and is not covered by the saving for pending applicants, it should not be running PA-CB business. The exporter risks delayed or blocked settlement, and still carries the FEMA duty to realise and document the export.
- Wind-up: Existing non-bank platforms that did not apply in time or could not meet the net worth rule had to wind up PA-CB activity by 31 July 2024 (2023 circular, Annex paragraph 3.4).
- Accounts closed: Banks had to close the PA-CB accounts of such platforms by 31 July 2024 unless they showed evidence of an application to RBI (Annex paragraph 3.5).
- Late realisation: Services exports must be realised within nine months of the invoice, or twelve months if invoiced or settled in rupees, unless your AD bank extends the period (FEMA Regulation 5). See export realisation period.
- Open EDPMS entry: Your AD bank closes the entry when it credits the receipt. Invoices up to Rs 10 lakh can be closed on your declaration (FEMA Regulation 4(2)). See EDPMS closure.
- Future exports: If proceeds stay unrealised for more than one year after the due or extended date, further exports need full advance or an irrevocable letter of credit (FEMA Regulation 13).
Check the platform on RBI's status list before onboarding, keep each transaction statement, and give your AD bank the documents it asks for. If money is stuck, ask the AD bank for an extension of the realisation period in writing.
Which RBI rules govern OPGSP and PA-CB arrangements?
The RBI rule now governing PA-CB arrangements is the Master Direction on Regulation of Payment Aggregators dated 15 September 2025. The OPGSP circulars of 2010, 2013 and 2015 and the 2023 PA-CB circular are repealed, with savings. Exporter duties come from the FEMA export regulations in force since 1 October 2026.
| Circular or regulation | Clause | Date | Plain meaning | Best for |
|---|---|---|---|---|
| A.P. (DIR Series) Circular No. 17 (RBI/2010-11/281) | Paragraph 2(ii) and 2(vi) | 16 November 2010 | Started OPGSP export receipts through AD banks; USD 500 limit; seven-day repatriation. Repealed with saving | History of OPGSP |
| A.P. (DIR Series) Circular No. 109 (RBI/2012-13/528) | Paragraph 2 | 11 June 2013 | Raised the OPGSP export limit from USD 3,000 to USD 10,000 per transaction. Repealed with saving | Explaining the old USD 10,000 figure |
| A.P. (DIR Series) Circular No. 16 (RBI/2015-16/185) | Paragraphs 2 to 4 | 24 September 2015 | Consolidated OPGSP rules for exports and imports. Repealed with saving | Understanding the bank-led model |
| Regulation of Payment Aggregator - Cross Border (RBI/2023-24/80) | Paragraph 3; Annex paragraphs 2 to 8 | 31 October 2023 | Brought cross-border platforms under direct RBI regulation as PA-CBs. Repealed by the 2025 Master Direction | Background on the switch |
| Master Direction on Regulation of Payment Aggregators (RBI/DPSS/2025-26/141) | Paragraphs 4(i)(ii), 5, 6, 11, 13, 16, 19 to 22 | 15 September 2025 | Current PA-CB rules, repeal of OPGSP circulars, and savings | Exporters choosing or checking a platform |
| Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 | Regulations 3(2), 4(2), 5 and 13 | In force 1 October 2026 | Exporter duties on EDF, EDPMS closure, realisation and unrealised exports | Exporters paid through any route |
| A.P. (DIR Series) Circular No. 20 (RBI/2025-26/194) | Paragraphs 4 and 7 | 16 January 2026 | Supersedes the Master Directions on export and import from 1 October 2026 | Knowing which export rules are current |
What mistakes do exporters make when comparing PA-CB and OPGSP rules?
- Old limit: Quoting USD 10,000 as the current cap. That was the OPGSP limit; the PA-CB cap is Rs 25 lakh per transaction (Master Direction, paragraph 11(d)).
- Seven-day rule: Expecting the old seven-day repatriation rule. Settlement timing now depends on your agreement with the PA-CB (Master Direction, Table 1), so read it before onboarding.
- Repealed circulars: Citing the 2023 PA-CB circular or the OPGSP circulars as current law. Both were repealed by the 2025 Master Direction (paragraphs 19 and 21).
- Status unchecked: Assuming every cross-border platform is authorised. RBI's status list shows PA-CB applications with in-principle authorisation, under process, or returned, withdrawn or refused, and RBI's Certificates of Authorisation list names authorised payment aggregators. See RBI licensed PA-CBs.
- Duties shifted: Thinking the platform files your EDF or closes EDPMS entries. The PA-CB supplies information; your AD bank closes the entry (FEMA Regulation 4(2)). See EDF form.
- Card payments: Treating every foreign card payment as PA-CB activity. A card transaction where the card network handles the foreign exchange settlement and the aggregator receives local currency is excluded (Note 2 to paragraph 4(i)(ii)).
How did we verify this?
Every rule, deadline and form on this page is linked to its official source, checked on the dates below.
- Master Direction on Regulation of Payment Aggregator (PA), RBI/DPSS/2025-26/141, CO.DPSS.POLC.No.S-633/02-14-008/2025-26, Covering letter; paragraphs 3, 4(i)(ii), 5, 6(a), 11, 13(a), 13(b), 13(g), 16(a), Table 1, 19 to 22 (checked 8 Oct 2026)
- Regulation of Payment Aggregator - Cross Border (PA - Cross Border), RBI/2023-24/80, CO.DPSS.POLC.No.S-786/02-14-008/2023-24, Paragraphs 1, 3; Annex paragraphs 2.2, 3.4, 3.5, 8.2 (checked 8 Oct 2026)
- A.P. (DIR Series) Circular No. 17 (RBI/2010-11/281): Processing and Settlement of Export related receipts facilitated by Online Payment Gateways, Paragraph 2(i), 2(ii), 2(iii), 2(vi) (checked 8 Oct 2026)
- A.P. (DIR Series) Circular No. 109 (RBI/2012-13/528): Enhancement of the value of transaction, Opening paragraph and paragraph 2 (checked 8 Oct 2026)
- A.P. (DIR Series) Circular No. 16 (RBI/2015-16/185): Processing and settlement of import and export related payments facilitated by OPGSPs, Paragraphs 2.1, 2.2, 3, 4 and 6 (checked 8 Oct 2026)
- Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, Notification No. FEMA 23(R)/2026-RB (amended up to 22 September 2026), Regulations 3(2), 4(2), 5 and 13 (checked 8 Oct 2026)
- A.P. (DIR Series) Circular No. 20 (RBI/2025-26/194): Export and Import of Goods and Services, Paragraphs 4 and 7 (checked 8 Oct 2026)
- RBI: Status of Applications received under Payment and Settlement Systems Act, 2007 (as on 01.10.2026), Part I, Tables D, E and F (PA-Cross Border) and notes ii and iii (checked 8 Oct 2026)
- RBI: Certificates of Authorisation issued by the Reserve Bank of India under the Payment and Settlement Systems Act, 2007 (dated 30 September 2026), Payment Aggregators (PA-O, PA-P and PA-CB) (checked 8 Oct 2026)
Frequently asked questions
What does OPGSP stand for in RBI circulars?
OPGSP stands for Online Payment Gateway Service Provider. RBI used the term in its 2010, 2013 and 2015 A.P. (DIR Series) circulars, which let AD Category-I banks enter standing arrangements with such providers to collect export receipts online. The 2025 Master Direction on payment aggregators repealed those circulars, except for saved pending applicants.
Is the OPGSP framework still valid in 2026?
The OPGSP framework is no longer valid for most platforms in 2026. The Master Direction of 15 September 2025 repealed the three OPGSP circulars. The only exception is an existing PA-CB that applied for authorisation on or before 30 April 2024 and is still awaiting RBI's decision. Check RBI's status list for any platform you use.
What were PA-CB-E, PA-CB-I and PA-CB-E&I under the 2023 circular?
PA-CB-E, PA-CB-I and PA-CB-E&I were the three authorisation categories in RBI's October 2023 PA-CB circular: export only, import only, and export and import. The 2025 Master Direction now describes two sub-categories instead, PA-CB facilitating inward transactions and PA-CB facilitating outward transactions. Exporters use the inward side.
What was the OEIF draft circular of 2022?
The OEIF draft circular was issued by RBI on 7 April 2022 for feedback on 'Online Export-Import Facilitators (OEIF) (erstwhile OPGSP)'. RBI's October 2023 PA-CB circular lists it among its references. The OEIF name did not become the final framework; cross-border platforms were instead regulated as PA-CBs.
Can a PA-CB pay export proceeds into a foreign currency account?
A PA-CB can settle in a non-INR currency only for Indian exporters it has onboarded directly, under paragraph 11(i) of the Master Direction. The permission does not extend to merchants onboarded by another aggregator or a marketplace. Whether your own account can receive foreign currency is a question for your AD bank.
Does the Rs 25 lakh PA-CB limit apply to a bank wire from a foreign client?
The Rs 25 lakh limit in paragraph 11(d) of the Master Direction applies to inward and outward transactions processed by a PA-CB. A direct bank transfer from a foreign client to your AD bank is not processed by a PA-CB, so this cap does not apply to it. FEMA export rules apply to both routes.
How should an exporter compare a PA-CB route with a direct bank transfer?
An exporter can compare a PA-CB route with a direct bank transfer by checking the final rupee amount credited for the same invoice, after all fees and the conversion rate. Also compare the settlement time in the agreement, the documents given to your AD bank for EDPMS closure, and whether the provider is authorised.