The RBI’s PA-CB (Payment Aggregator – Cross Border) framework brings all cross-border payment facilitators under a formal regulatory regime. Non-bank entities handling international payments must now obtain RBI authorization, meet net worth requirements, maintain separate collection accounts, and comply with strict KYC, AML, and FEMA regulations. The framework also creates new opportunities in forex services, trade finance, virtual accounts, and global payment solutions.
What’s Inside? (Key Points)
RBI Authorization Mandatory
- All non-bank cross-border payment aggregators must obtain RBI approval to operate.
Three PA-CB Categories
- PA-CB-E: Export Payments
- PA-CB-I: Import Payments
- PA-CB-E&I: Both Export & Import Payments
Net Worth Requirements
- Minimum ₹15 crore at application.
- Increase to ₹25 crore within prescribed timelines.
Separate Collection Accounts
- Import Collection Account (ICA) and Export Collection Account (ECA) required with AD Category-I banks.
KYC, AML & FIU-IND Compliance
- Mandatory customer due diligence, transaction monitoring, and reporting obligations.
Business Opportunities
- Forex conversion & hedging
- Cross-border wallet payments
- QR-based collections
- Import financing
- Subscription & recurring payments
- Virtual accounts
- Export bill discounting
Regulatory Grey Areas
- Applicability to offline transactions
- Treatment of Delivery vs Payment (DvP) models
- Interpretation of the ₹25 lakh “per unit” transaction cap
