Payment Aggregator - Cross Border (PA-CB) serves as a facilitator for online cross-border payment transactions associated with the import and export of permissible goods and services. On October 31, 2023, the Reserve Bank of India (RBI) issued a circular
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Payment Aggregator - Cross Border (PA-CB) serves as a facilitator for online cross-border payment transactions associated with the import and export of permissible goods and services. On October 31, 2023, the Reserve Bank of India (RBI) issued a circular titled 'Regulation of Payment Aggregator – Cross Border (PA – Cross Border)' (PA – CB Directions). This directive was specifically addressed to all payment system providers and participants. The release of PA – CB Directions is a follow-up to the earlier draft circular issued by the RBI on April 7, 2022, titled 'Processing and settlement of small value Export and Import related payments facilitated by Online Export-Import Facilitators (OEIF) (formerly OPGSP)' (Draft OEIF Directions).
The term Payment Aggregator Cross Border (PA-CB) specifically denotes the facilitation of online cross-border payments associated with the import and export of permissible goods and services. The Reserve Bank of India (RBI) has established distinct criteria and regulations for entities involved in PA-CB activities to ensure adherence to standards and accountability.
The RBI classifies PA-CB activities into three primary categories: export-only PA-CB, import-only PA-CB, and export and import PA-CB. Each category comes with its own set of requirements and guidelines, delineating the specific criteria applicable to entities engaged in these respective activities.
APPLICABILITY OF AUTHORIZATION
Non-bank entities aspiring to operate as Payment Aggregator Cross Border (PA-CB) must secure approval from the Department of Payment and Settlement Systems (DPSS) at the Central Office (CO) of the Reserve Bank of India (RBI). The approval process is to be conducted in accordance with the procedures specified in the relevant circular issued by the RBI. This ensures that non-bank entities seeking to engage in PA-CB activities adhere to the regulatory framework and requirements set forth by the DPSS.
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AD Category-I Banks |
No separate approval required |
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Non-banks which provide PA-CB services as on the date of the circular |
Apply to RBI on or before 30th April 2024 as prescribed in the circular |
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Non- Banks wiling to act as PA-CB |
Seek approval from DPSS, RBI |
Net-worth
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For Non-Banks which are already providing such services |
INR 15 Crores at the time of submission of application and INR 25 Crores by the 31st March 2026 |
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For Non-Banks which do not provide PA-CB services as on the date of the circular / New Non- bank PA-CBs. |
INR 15 crores the time of the application submission and INR 25 Crores by end of third financial year from the date of grant of authorization |
Import and Export Accounts
Import-only Payment Aggregator Cross Borders (PA-CBs) are required to uphold an Import Collection Account (ICA) with an AD Category-I scheduled commercial bank. The funds collected from customers for import transactions are initially received in an escrow account held by the PA and subsequently transferred to the ICA. The ICA is then utilized for the onward settlement of payments to the offshore merchants.
Similarly, export-only Payment Aggregator Cross Borders (PA-CBs) are mandated to maintain an Export Collection Account (ECA) with an AD Category-I scheduled commercial bank. The ECA can be denominated in either Indian Rupees (INR) or foreign currency, offering flexibility in the currency of choice for conducting export-related transactions.
Payment Aggregator Cross Borders (PA-CBs) are obligated to establish an agreement with the AD Category-I bank to maintain a collection account. The AD bank responsible for managing the Import Collection Account (ICA) or Export Collection Account (ECA) must ensure compliance with all requirements stipulated under the Foreign Exchange Management Act (FEMA). This includes fulfilling obligations related to reporting and reconciliation of entries in the Export Data Processing and Monitoring System (EDPMS) or Import Data Processing and Management System (IDPMS). Consequently, PA-CBs and AD banks must define and agree upon their respective obligations from a foreign-exchange compliance perspective.
For import PA-CBs, it is imperative to maintain a sufficient balance in the Import Collection Account. Effective fund management becomes a crucial aspect to ensure seamless remittance and adherence to regulatory requirements.
Financial Intelligence Unit – India (FIU – IND)
Before applying for Payment Aggregator – Cross Border (PA-CB) authorization from the Reserve Bank of India (RBI), all existing PA-CBs are required to register with the Financial Intelligence Unit - India (FIU-IND). FIU-IND functions as India's national agency for managing information concerning financial transactions. It plays a crucial role in supporting intelligence, investigation, and enforcement agencies globally in their endeavors to combat money laundering and the financing of terrorism. This registration mandate ensures that existing PA-CBs are integrated into the broader framework of financial intelligence and compliance measures.
Customer Due Diligence and KYC
Payment Aggregator Cross Borders (PA-CBs) are mandated to conduct Customer Due Diligence (CDD) and adhere to Know Your Customer (KYC) procedures for merchants integrated into their platforms. This obligation extends to merchants on boarded directly, collaborations with e-commerce marketplaces, or partnerships with entities offering Payment Aggregator services abroad. Furthermore, for import transactions surpassing INR 2,50,000 per unit, it is imperative to carry out due diligence on the buyer as part of the regulatory requirements. This ensures a comprehensive and vigilant approach to verifying the identity and legitimacy of both merchants and buyers involved in transactions facilitated by PA-CBs.
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