What Are the RBI Payment Aggregator Cross Border (PA-CB) Guidelines?
- Author:
- Manoj Sharma
- Verified by:
- Editorial team
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Short answer
The RBI PA-CB guidelines regulate payment aggregators that collect cross-border payments for Indian exporters and importers. They first came in an October 2023 circular. Since 15 September 2025 they sit in RBI's Master Direction on Regulation of Payment Aggregators. Each PA-CB transaction is capped at Rs 25 lakh.
| Applies to | Governed by | Deadline | Penalty | Last verified |
|---|---|---|---|---|
| Bank and non-bank payment aggregators handling cross-border e-commerce payments, the AD Category-I banks holding their collection accounts, and exporters who are paid through them | Reserve Bank of India (Regulation of Payment Aggregators) Directions, 2025 (Master Direction dated 15 September 2025), issued under the Payment and Settlement Systems Act, 2007 and FEMA, 1999 | Not applicable to exporters as a filing deadline. Export rules still apply: EDF for services within 30 days of the end of the invoice month and realisation within 9 months | The Master Direction sets no penalty for exporters. Exports left unrealised for over one year past the due date restrict future exports to full advance or an irrevocable letter of credit under FEMA Regulation 13 | 8 Oct 2026 |
What are the RBI PA-CB guidelines for cross-border payment aggregators?
The RBI PA-CB guidelines are the rules for payment aggregators that collect or send cross-border payments for goods and services sold online. They now form paragraph 11 and related parts of RBI's Master Direction on Regulation of Payment Aggregators, dated 15 September 2025.
- Definition: 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), Master Direction on Payment Aggregators).
- Sub-categories: There are two sub-categories: PA-CB facilitating inward transactions and PA-CB facilitating outward transactions (paragraph 4(i)(ii)). Exporters deal with the inward side.
- Merchant: The Master Direction defines a merchant as an entity or marketplace selling goods, services or investment products, and says this includes exporters and overseas sellers (paragraph 4(f)).
- E-commerce: E-commerce means buying and selling goods and services, including digital products, over a digital and electronic network (paragraph 4(c)).
- Exclusions: A card transaction where the card network handles the foreign exchange settlement and the aggregator receives rupees is not PA-CB activity. A non-bank AD Category-II handling non-trade current account transactions is also outside the definition (Notes to paragraph 4(i)(ii)).
- Legal basis: RBI issued the Master Direction under section 18 read with section 10(2) of the Payment and Settlement Systems Act, 2007, and sections 10(4) and 11(1) of FEMA, 1999 (Master Direction covering letter).
- History: Before 2023, cross-border online collections ran under the Online Payment Gateway Service Provider (OPGSP) circulars of 2010, 2013 and 2015. The 31 October 2023 PA-CB circular brought these entities under direct RBI regulation.
In short, the PA-CB guidelines regulate the aggregator and its bank. The exporter's own duties, such as declaring and realising exports, still come from the FEMA export regulations.
Who do the RBI PA-CB guidelines apply to?
The RBI PA-CB guidelines apply directly to bank and non-bank entities running cross-border payment aggregation, and to the AD Category-I banks that hold their collection accounts. Exporters are not regulated by the Master Direction itself, but its rules shape how their money is collected, converted and settled.
| Entity type | Applicable | Why | Best for |
|---|---|---|---|
| Non-bank PA-CB | Yes, needs RBI authorisation | A non-bank must apply through RBI's online portal and be a company incorporated in India (paragraph 5(b) and 5(c)) | Exporters checking whether an online collection provider is regulated |
| Bank acting as a payment aggregator | Yes, no separate authorisation | A bank does not require authorisation to carry out PA business (paragraph 5(a)) | Exporters collecting through their own bank's online checkout |
| AD Category-I bank holding the InCA | Yes | It must ensure FEMA requirements are met and fetch the needed information from the PA-CB through automated processes (paragraph 11(e) and 11(f)) | Understanding who reports your receipt and closes EDPMS entries |
| Indian exporter onboarded by a PA-CB | Indirectly | The exporter is the merchant; the PA-CB carries out due diligence on it and settles funds to its bank account (paragraph 13) | Freelancers and small exporters selling online |
| Card payment settled in rupees by a card network | No | Excluded from PA-CB activity (Note 2 to paragraph 4(i)(ii)) | Merchants accepting foreign cards through a domestic acquirer |
| Payment gateway with no handling of funds | No | A payment gateway that only provides technology is outside the Master Direction (paragraph 10(g)) | Understanding the difference between a gateway and an aggregator |
| Existing PA-CB that applied by 30 April 2024 with a decision pending | Old OPGSP circulars saved for it | The repeal of the OPGSP circulars does not apply to such entities until RBI decides (paragraph 19) | Exporters using an existing provider that RBI lists as able to operate while its application is pending |
How does an export payment move through a PA-CB under RBI rules?
An export payment through a PA-CB is collected from the overseas buyer, credited to the aggregator's Inward Collection Account with an AD Category-I bank in India, and then settled to the exporter's bank account. The AD bank uses the information from the PA-CB to report the receipt and close the export entry.
- The PA-CB onboards the exporter as a merchant and completes due diligence under RBI's KYC Master Direction, retrieving the KYC record from CKYCR with the merchant's consent (paragraph 13(a)).
- The overseas buyer pays through the PA-CB's interface. The payment must be identified as a cross-border transaction, from timelines RBI specifies (paragraph 11(g)).
- Proceeds are credited to the PA-CB's Inward Collection Account (InCA) with an AD Category-I scheduled commercial bank, held separately for rupees and for each foreign currency (paragraph 16(a) and Table 1).
- Any currency conversion is done with an Authorised Dealer only; the PA-CB cannot buy or sell foreign currency with anyone else (paragraph 11(d)).
- Funds are settled to the exporter's own bank account, on the timeline written in the agreement between the PA and the merchant (Table 1, Timelines; paragraph 13(g)).
- The PA-CB gives the exporter's AD bank the documents or information needed to close the EDPMS entry (paragraph 11(h)), and the AD bank closes or updates the entry when it credits the receipt (FEMA Regulation 4(2)).
What is the PA-CB transaction limit for exports?
The PA-CB transaction limit is Rs 25 lakh per transaction, for both inward and outward transactions (paragraph 11(d)). The 2023 circular had set the same figure as a maximum value per unit of goods or services (paragraph 8.2 of the Annex). See also PA-CB transaction limits.
- Older OPGSP limit for exports: USD 10,000 per transaction (A.P. (DIR Series) Circular No. 109, 2013).
- Original 2010 OPGSP limit: USD 500 per export (A.P. (DIR Series) Circular No. 17, 2010).
Can a PA-CB settle export proceeds in foreign currency?
A PA-CB can settle in a foreign currency only to Indian exporters it has onboarded directly (paragraph 11(i)). Exporters reached through another aggregator or marketplace are settled in rupees. Whether your own bank account can receive foreign currency is a separate question for your AD bank.
How fast must a PA-CB settle funds to an exporter?
The Master Direction leaves the settlement timeline to the agreement between the PA and the merchant, which must be fair, equitable and state the timeline transparently (Table 1, Credit to merchant's account). The old OPGSP rule required repatriation within seven days of credit to the collection account (2010 circular, paragraph 2(vi)). See PA-CB settlement timelines.
What KYC does a PA-CB need from a small exporter?
A PA-CB normally retrieves the merchant's KYC record from CKYCR with consent. Where that record is not available, it can use other methods in RBI's KYC Master Direction. If the merchant's annual turnover is up to Rs 40 lakh, or annual export turnover is up to Rs 5 lakh, a simpler route is also allowed (paragraph 13(a) and 13(b)).
- PAN or Form 60, verified with the issuing authority.
- Contact point verification of the place of business.
- A certified copy of one officially valid document of the proprietor or of the person holding power of attorney, as applicable.
What are the key PA-CB limits, accounts and dates under the RBI Master Direction?
The key PA-CB figures are a Rs 25 lakh cap per transaction, separate inward and outward collection accounts with an AD Category-I bank, and net worth of Rs 15 crore at application rising to Rs 25 crore. Escrow account rules had to be met by 31 December 2025.
| Item | Rule | Source | Best for |
|---|---|---|---|
| Transaction cap | Rs 25 lakh per inward or outward transaction | Paragraph 11(d) | Exporters with large single invoices |
| Inward Collection Account (InCA) | Held with an AD Category-I SCB; separate account for rupees and each foreign currency; no pre-funding; no interest on balances | Paragraph 16(a), Table 1 | Understanding where export money sits before settlement |
| Mixing of funds | Inward and outward funds kept separate; no co-mingling or netting under any circumstance | Paragraph 11(a) | Checking that export receipts are not offset against other flows |
| Third-party payouts from InCA | Not among permitted debits for the InCA | Table 1, Permitted debits | Exporters asking to route proceeds to someone else |
| Net worth of non-bank PA | Rs 15 crore at application; Rs 25 crore by the end of the third financial year after authorisation | Paragraph 6(a) | Judging the scale of a regulated provider |
| Escrow compliance date | Table 1 escrow requirements to be met by 31 December 2025 | Paragraph 16(a) | Background on when the new account rules took hold |
| Merchant re-verification | Merchants onboarded up to 31 December 2025 to meet the new due diligence rules within one year of the Master Direction; new merchants from 1 January 2026 onboarded under it | Paragraph 13(j) | Exporters asked by a provider to redo KYC |
| Banker certificate on InCA | Banker's certificate on InCA and OCA debits and credits by the 15th of the month after each quarter | Annexure 2 | Understanding the provider's reporting to RBI |
What happens to an exporter if a PA-CB payment does not meet the RBI rules?
If a PA-CB payment does not meet the RBI rules, the main risk for the exporter is an open EDPMS entry or a payment that cannot be settled. The export rules under FEMA still apply to the exporter, so unrealised or undocumented receipts become the exporter's problem with the AD bank.
- Over the cap: A single payment above Rs 25 lakh cannot be processed by a PA-CB (paragraph 11(d)), so the buyer would need to pay through another route, such as a bank transfer.
- Open EDPMS entry: Your AD bank closes the entry when it credits the receipt; for invoices up to Rs 10 lakh this can be done on your declaration (FEMA Regulation 4(2)). See EDPMS closure.
- Late realisation: The full export value must be realised within nine months of the invoice for services, or twelve months if invoiced or settled in rupees, unless the AD bank extends it (FEMA Regulation 5).
- Long overdue: If proceeds stay unrealised for more than one year after the due date or extended date, further exports need full advance or an irrevocable letter of credit (FEMA Regulation 13).
- Unregulated provider: A non-bank aggregator needs RBI authorisation, or a pending application where the rules allow it to continue (paragraph 5). RBI's list of payment aggregator applications shows which PA-CBs can operate; new PA-CBs whose applications are still under process cannot.
Ask the PA-CB for the transaction-wise documents your AD bank needs, give them to the bank promptly, and request an extension from the AD bank if realisation will be late. Check the provider's status on RBI's list before onboarding.
Which RBI rule says this about cross-border payment aggregators?
The RBI rule on cross-border payment aggregators is now the Master Direction on Regulation of Payment Aggregators dated 15 September 2025. It repealed the October 2023 PA-CB circular and the OPGSP circulars. The OPGSP circulars stay only for existing PA-CBs with pending applications. The FEMA export regulations apply alongside it.
| Circular or regulation | Clause | Date | Plain meaning | Best for |
|---|---|---|---|---|
| Master Direction on Regulation of Payment Aggregators (RBI/DPSS/2025-26/141) | Paragraph 4(i)(ii) | 15 September 2025 | Defines PA-CB and its inward and outward sub-categories | Checking whether a provider is a PA-CB |
| Master Direction on Regulation of Payment Aggregators | Paragraph 11 | 15 September 2025 | Rs 25 lakh cap, separate funds, AD-only conversion, EDPMS support, foreign currency settlement only for direct merchants | Exporters comparing collection routes |
| Master Direction on Regulation of Payment Aggregators | Paragraphs 16 to 18, Table 1 | 15 September 2025 | InCA and OCA rules, permitted credits and debits, settlement as per agreement | Understanding how money is held |
| Master Direction on Regulation of Payment Aggregators | Paragraphs 19 and 21, Annexure 3 | 15 September 2025 | Repeals the 2023 PA-CB circular and the OPGSP circulars; the OPGSP circulars stay for an existing PA-CB that applied by 30 April 2024 and awaits a decision | Reading older guidance correctly |
| Regulation of Payment Aggregator - Cross Border (CO.DPSS.POLC.No.S-786/02-14-008/2023-24) | Annex, paragraphs 1 to 8 | 31 October 2023 | Brought cross-border aggregators under direct RBI regulation; now repealed | Background and history |
| A.P. (DIR Series) Circular No. 16 | Paragraph 4 | 24 September 2015 | OPGSP export facility up to USD 10,000 per transaction; repealed except for saved entities | Understanding the older OPGSP model |
| Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 | Regulations 3, 4, 5 and 13 | In force 1 October 2026 | Exporter duties: EDF, EDPMS closure, realisation period and unrealised exports | Exporters paid through any route |
| A.P. (DIR Series) Circular No. 20 | Paragraph 4 | 16 January 2026 | Supersedes the Master Direction on Export of Goods and Services from 1 October 2026 | Knowing which export rules are current |
What mistakes do exporters make with PA-CB payments?
- Old limits: Quoting the USD 10,000 OPGSP limit. The current cap is Rs 25 lakh per transaction (paragraph 11(d)). See PA-CB vs OPGSP.
- Repealed rules: Citing the October 2023 circular as current. It was repealed by the September 2025 Master Direction (Annexure 3).
- Status unchecked: Onboarding with a provider without checking RBI's application status list. See how to check RBI authorisation.
- Missing documents: Assuming the provider closes EDPMS entries. The PA-CB supplies information; your AD bank closes the entry (paragraph 11(h); FEMA Regulation 4(2)).
- Card confusion: Treating every foreign card payment as PA-CB. Card transactions settled in rupees by a card network are excluded (Note 2 to paragraph 4(i)(ii)). See export payments by card.
- Skipping EDF: Forgetting that service exporters still file the EDF within 30 days of 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.
- Master Direction on Regulation of Payment Aggregator (PA), RBI/DPSS/2025-26/141, Paragraphs 4, 5, 6, 10(g), 11, 13, 16 to 19, 21, 22, Table 1, Annexures 2 and 3 (checked 8 Oct 2026)
- Regulation of Payment Aggregator - Cross Border (PA - Cross Border), CO.DPSS.POLC.No.S-786/02-14-008/2023-24, Annex paragraphs 2.2, 5 and 8.2 (checked 8 Oct 2026)
- A.P. (DIR Series) Circular No. 17: Processing and Settlement of Export related receipts facilitated by Online Payment Gateways, Paragraph 2(ii) and 2(vi) (checked 8 Oct 2026)
- A.P. (DIR Series) Circular No. 109: Enhancement of the value of transaction, Paragraph 2 (checked 8 Oct 2026)
- A.P. (DIR Series) Circular No. 16: Processing and settlement of import and export related payments facilitated by OPGSPs, Paragraph 4(i) (checked 8 Oct 2026)
- Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 (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: Export and Import of Goods and Services, Paragraphs 4 and 7 (checked 8 Oct 2026)
- RBI: Status of applications received from Payment Aggregators (as on 01.10.2026), Tables D, E and F (PA-CB) (checked 8 Oct 2026)
Frequently asked questions
Is the RBI PA-CB circular of October 2023 still in force?
The RBI PA-CB circular of 31 October 2023 is no longer in force. It was repealed by the Master Direction on Regulation of Payment Aggregators dated 15 September 2025, which carries its rules forward with changes. Approvals and actions taken under the old circular remain valid under the new Master Direction, as paragraph 22 states.
What do PA-CB-E, PA-CB-I and PA-CB-E&I mean?
PA-CB-E, PA-CB-I and PA-CB-E&I were the three authorisation categories in the October 2023 circular: export only, import only, and export and import. The 2025 Master Direction instead describes two sub-categories of PA-CB, facilitating inward transactions and facilitating outward transactions. Exporters receiving money are served by the inward side.
Does a freelancer count as a merchant under the PA-CB rules?
The Master Direction defines a merchant as an entity that sells goods, provides services or offers investment products, and says this includes exporters. A freelancer selling services online can therefore be onboarded as a merchant. Whether a particular payment flow is PA-CB activity depends on the provider's setup, so confirm with the provider.
Is an Inward Collection Account the same as an escrow account?
An Inward Collection Account, or InCA, is the escrow account a PA-CB keeps for inward transactions. It must be with an AD Category-I scheduled commercial bank, kept separately for rupees and each foreign currency, and used only for authorised PA business. No interest is payable on InCA balances, and pre-funding is not permitted.
Can a PA-CB pay export proceeds to a third party?
A PA-CB cannot pay export proceeds from its Inward Collection Account to a third party on the merchant's instruction. Table 1 of the Master Direction excludes that debit for the InCA, and paragraph 13(g) requires funds due to a merchant to reach the merchant's own bank account. Separate FEMA rules cover third-party receipts through AD banks.
Who issues the FIRA or e-BRC for a PA-CB receipt?
The PA-CB Master Direction does not name a specific certificate. It requires the PA-CB to give the exporter's AD bank the documents or information needed to close the EDPMS entry. Ask your AD bank which document it will issue or accept for the receipt, and keep the provider's transaction statement for your records.
Can a PA-CB convert foreign currency itself?
A PA-CB cannot buy or sell foreign currency with anyone other than an Authorised Dealer, under paragraph 11(d) of the Master Direction. In practice the conversion rate an exporter gets depends on the AD bank and the provider's pricing, so compare the final rupee amount credited, after all fees, before choosing a route.