RBI Notification

Cross-Border Payment Aggregators: 2026 RBI Regulations, Eligibility, Net Worth & Business Use Cases

From a small-scale apparel seller to a mid-level online saree distributor, online global opportunities are no longer restricted to large enterprises. As of 2026, an SME in Pune or a SaaS startup in Bengaluru can have clients in London, Tokyo, or Dubai. The rise of digitalization and globalization via e-commerce has made it easier for Indian businesses to reach a large number of customers in the international market.

Such cross-border business opportunities only work with the ability of a business or customer to send and receive money across the global market through a secure and safe passage. With India’s service exporters crossing USD 420 billion in 2025, the importance of a strong cross-border payments compliance amplifies by 10X speed.

Prior to RBI’s circular and regulations, all cross-border transactions for import and export of goods and services were governed and enabled through the online payment gateway providers (OPGSPs)- businesses were only needed to open accounts with Authorized Dealer Category-I Banks to enable global payments for imports and export transactions.

Since the Dec. 23 RBI circular and subsequent regulations, non-bank entities are now allowed to enter into the cross-border payment aggregator business, which was earlier limited to AD for online international transactions. Along with the import of services, now even goods are eligible for import PACB, which was earlier restricted under the OPGSPs without having to deal with the AD banks.   

So, whether you are an exporter, merchant, a D2C brand, or an SME, this blog will help you understand RBI’s guidelines to deal with the essentials.

What Do Cross Border Payments Mean?  

Cross-border payment is a type of transaction that includes senders and receivers who are in different countries. Most funds in this payment flow for foreign trade (import/export), SaaS, software, freelance services, and remittances in India. These need mandatory currency conversion and compliance with RBI’s guidelines on AML/CFT. 

Why Does RBI Regulate Cross-Border Payment Aggregators?  

The reason why RBI regulate cross-border payment aggregators and their transaction ecosystem is simple- to protect both the merchants and the financial system of the country. If the money is entering India, the central banking authority wants to make sure that:

  • The payment is made for genuine business purposes and/or intentions.
  • The merchant is properly verified.
  • The transaction doesn’t reflect suspicion of money laundering, CFT, or fraud.
  • Forex rules are properly followed throughout the transaction process.
  • Each and every payment received in India follows RBI and FEMA-specific guidelines.

Why Cross-Border Payment Aggregators Matter in India in 2026? 

Heavily driven by exports, online marketplaces, services, inbound remittances, and freelancing, India has one of the largest consumer markets for cross-border payment aggregators. 

USD 135 Billion 

Remittances received by India in FY 2024-25 (RBI) 

USD 406 Billion 

India’s services exports (RBI / Commerce Ministry, FY2025–26 estimate stats) 

USD 840 Billion 

India’s total goods + services exports (FY2025–26) trade stats 

Increase in Service Exports 

A sharp surge in IT/ITeS, SaaS, consulting, and professional services. 

International E-Commerce Expansion 

Enhanced expansion and increased reach of Indian D2C brands and sellers overseas, either via their own online marketplaces or storefronts. 

Freelance Economy 

Global extension of gig and creator economy- freelance professionals, designers, developers, consultants, and advisors getting payments from all across the globe. 

RBI’s Framework Building 

The Reserve Bank of India is constantly bringing in a cross-border payment transaction system into an auditable framework for better transparency and compliance. 

What are the Criteria for Cross-Border Payment Aggregators? 

Take a look at the following criteria before you apply for cross-border payment aggregators: 

  • The applicant should be a company registered in India.
  • KMP and directors must have a clear track record- financial and criminal.
  • No lawsuit pending against top management personnel.
  • Proper channel and mechanism for KYC verification, beneficial ownership checks, and risk classification.
  • Transaction monitoring system for continuous payment tracking and STR to the FIU-IND/RBI.
  • Policies for data protection, access control, cybersecurity, and payment infrastructure.
  • Compliance with RBI’s data localization laws and record retention rules.
  • Full risk management framework, business continuity plan, and disaster recovery.
  • Creation of an independent system of audit and cybersecurity assessment via board approval.
  • Auditor certified financial statements and FEMA compliance.
  • Minimum capital as per the RBI rules during application procedure
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Is there a Difference Between Cross-Border Payment Aggregators and Domestic PAs? 

Understand the key differences between cross-border payment aggregators and domestic PAs.

Basis Domestic PA PA-CB (Cross-Border) 
Governing Circular PA/PG Guidelines 2000 PA-CB, Circular Oct 31, 2023 
ScopeWithin India (INR) Export and Import 
Ongoing Net Worth INR 25 crore (by the end of third FY) INR 25 crore (by the end of third FY) (by March 31, 2026, for existing entities) 
Key Bank Accounts Escrow with Scheduled Bank ICA or ECA with an AD Bank 
Regime RBI, KYC, and PSS FEMA, FIU-IND, Forex 
Transaction Cap Not ApplicableINR 25 lakh per unit of goods or services 

Capital Required  

All cross-border payment aggregators must have a net worth of INR 15 crore at the time of application for authorization to the Reserve Bank of India.

As a PA-CB, you will have to maintain at least INR 25 crore by the end of your third financial year and from that point onwards.

Your net worth can consist of paid-up equity capital, preference shares, free reserves, premium accounts, and capital reserves from asset sales.

In case you fail to maintain the Net Worth requirements throughout your business journey on an ongoing basis, you will have to end up either with license revocation or complete business shutdown by the RBI. 

What are the Categories Under Cross-Border Payment Aggregators? 

Currently, there are three categories of cross-border payment aggregators under the RBI guidelines, as follows: 

Export-Only (PA-CB-E) 

This category helps with the cross-border flows, enabling companies to collect and repatriate funds coming into India from international clients to Indian exporters or freelancers.

Import-Only (PA-CB-I) 

The only import category that helps companies get payments for the imports of goods and services. The collection account holders maintain an import collection account (ICA).

Export and Import (PA-CB-E&I) 

A category that will help you facilitate payment of transactions for both eligible products and services under export and import. Needs separate accounts for ICA and ECA to prevent overlapping.

Common Business Use Cases  

The most common business use cases via cross-border payment aggregators are: 

Currency Conversions 

Payment aggregators can facilitate currency conversions and foreign exchange hedging services to customers after proper due diligence. 

Wallet Payments 

PA-CBs can help companies with wallet-enabled payment services for customers. As a registered entity with the RBI, they can also tie up with wallet providers and facilitate wallet payments.

QR Scan Payments 

Payment aggregators-exporters can share proxy identifiers, like a QR code, to obtain payments from their customers without revealing their bank account details.

Line of Credit Facility 

Import PA-CBs can provide credit services to their clients, so the latter can make instant payments to sellers and beneficiaries.

Integration Business Models  

Exporter payment aggregators can integrate or embed the links for remittances into the business model. Payment link generation through a website or a chatbot.

Shareable Payment Links 

You can accept payments by generating links on behalf of customers without a website. The link can be embedded or shared with the payee to get the amount.

Recurring Payments 

PA-CBs can facilitate clients to get cross-border payments and their subscription management.

Export Bill Discounting 

With the assistance of a letter of credit backing issued by the importer’s bank, you can provide an export bill discounting service to the sellers.

Virtual Account Maintenance 

Facilitate tracking of receivables and reconciliation of the payments to your customers via virtual account management services as an export payment aggregator.

Common Challenges 

As an applicant for cross-border payment aggregators, you may encounter the following challenges during the application process for cross-border payment aggregator license

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Meeting RBI Guidelines 

Satisfying RBI’s criteria like fit & proper for directors/KMP, internal governance, tech, and operational mandates can be challenging for a lot of up-and-coming fintechs with less management experience and compliance readiness.

Net Worth 

Most startups and smaller companies need additional capital to satisfy the RBI-mandated fund requirement before licensing, and also find it hard to maintain INR 25 crore on an ongoing basis by the third financial year after the authorization.

Heavy Compliance 

Cross-border payment aggregators have to follow multiple regulations, such as anti-money laundering, know your customer, CFT, internal governance, continuous transaction monitoring, risk mitigation system, and fraud management, which can be quite exhausting if they don’t have proper team assistance and specialized knowledge.

Merchant Onboarding 

Constant KYC screening, due diligence processing, and verification of businesses, merchants, vendors, and risk categorization can be tedious and may lead to risks if suspicious accounts aren’t reported to the RBI and FIU-IND within the prescribed timelines.

Complex FEMA and Global Transaction Compliance 

Interpreting FEMA, RBI, and import/export guidelines and regulations can be complex for new companies that are trying to handle their core business and compliance requirements.

Tech and IS Mandates 

Before you get the authorization by the RBI, you will have to show proper secure payment infrastructure, data protection controls, access mechanism system, business continuity plans, and IS disaster recovery audits.

Extensive Scrutiny 

The central banking authority will check your documentation and payment mechanism substantially and extensively for your cross-border payment aggregator application, which can sometimes be lengthy and time-consuming.

Bank Partnership and Settlement  

New companies often find it difficult to establish banking partnerships and payment processing settlement mechanisms for operating as PA-CBs in India.

Foreign Exchange Management 

Without specialized professional assistance, it can be difficult to manage currency conversions, reconciliations, settlement timeline handling, and foreign exchange reporting.

Audit Needs 

After you get a PA-CB license from the RBI, you will have to conduct audits, coordinate with external auditors, prepare assessments, and conduct regulatory inspections.

Continuous Monitoring and Regulatory Changes 

With rapid changes in the legal-tech world and global trade, companies need to constantly update their processes and systems to align them with RBI, FEMA, DPDP, and FIU-IND requirements.

Multiple Jurisdictional Compliance 

As a cross-border payment aggregator, you will have to comply with the customs, data protection, sanctions, and payment regulations of various countries, which can be overwhelming and confusing for newly registered fintechs.

Top Businesses That Rely on Cross-Border Payment Aggregators 

Here’s a list of common businesses that heavily rely on cross-border payment aggregators: 

  • E-Commerce Exporters and D2C Brands 
  • SaaS Companies 
  • IT & Software Service Providers 
  • Freelancers 
  • Online Operators and Marketplaces 
  • Digital Learning Platforms 
  • Online Travel and Ticket Booking 
  • Digital Hotel Reservations 
  • Gaming Companies 
  • Digital Content Creators and Platforms 
  • Consulting and Advisory Firms 
  • Trading and Export Houses 
  • Telemedicine 
  • Entertainment and Digital Asset Sellers 

In India, there are thousands of SaaS companies, sellers on e-commerce platforms, outsourcing firms, and tech companies that earn a major portion of their revenue internationally. The global payment system has increased significantly in the last decade due to an increase in online shopping and the enrollment of students in online courses. 

How Can Enterslice Help?  

  • Specialist RBI and FEMA team for PA, PA-CB, NBFC, and related fintech digital payments.
  • From basic eligibility checks to formal structuring and payment aggregator compliance– your centralized solution zone.
  • Network of CAs, lawyers, company secretaries, and domain specialists’ bench of PAN India and global professionals.
  • Hassle-free drafting of AML and KYC/CFT policies in line with RBI and FIU-IND guidelines.
  • Enhanced guidance for Forex and FEMA for import/export flows, collection accounts, and transactions.
  • On time reporting, periodic audits, and capital adequacy maintenance.

In a Nutshell 

With a sharp increase in cross-border payments, the Reserve Bank of India is determined to establish a strong framework for businesses and merchants facilitating international payment transactions. The evolving global import and export market with increased transaction flows emphasizes the importance of secure, safe, encrypted, and streamlined cross-border payment systems.   

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Currently, in the changing trajectory, the financial and compliance sector is eagerly waiting for new advancements in the RBI’s cross-border framework, which would not only foster a more protected environment but also a conducive environment for innovation and sustainable growth.   

For cross-border payment aggregator license, talk to our experts at Enterslice.

FAQs Related To Cross-Border Payment Aggregators

  1. What is a cross-border payment aggregator in simple words?

    A PA-CB is a financial service entity that enables businesses to securely accept and send payments to vendors, clients, and companies in international jurisdictions. It eliminates the use of separate bank accounts and eases the payment process, which helps overseas customers to pay you in their local currency, which you receive in yours. Payment checkouts are done through links or gateways on websites or mobile apps.
    Since payment aggregators are registered with the RBI, they are transparent with their compliance with cross-border transaction and billing rules.

  2. Which RBI guidelines or regulations govern the cross-border goods and service transactions?

    The Reserve Bank of India’s framework on PA-CB, EXIM guidelines, and LRS schemes regulates and implements the procedures of the Foreign Exchange Management Act of 1999 rules on cross-border import-export products and services.

  3. What are the current net worth requirements for cross-border payment aggregators?

    As of 2026, all new applicants need to facilitate around INR 15 crore before application and at least INR 25 crore towards the end of their third financial year since receiving the authorization from the RBI.

  4. Is there a pre-transaction limit for PA-CBs? 

    Absolutely, under the Reserve Bank of India rules and regulations, all cross-border payment aggregators have a set limit of INR 25 lakh per unit of goods and services, including both inward and outward transactions. Also, you will have to conduct specific due diligence in case import transactions exceed INR 2.5 lakh per unit of a buyer.

  5. What are an ICA and an ECA under payment aggregators?

    An import collection is used to process payments for goods and services bought from foreign merchants, whereas an export collection account is used to obtain payments from global customers on behalf of said Indian merchantṣ.

  6. Is FIU-IND registration mandatory for cross-border payment aggregators with international transactions? 

    Yes, all registered PA-CBs are required to register with the Financial Intelligence Unit- India (FIU-IND) to prevent money laundering, regularly report suspicious transactions, file mandatory reports, and conduct customer due diligence after enrollment with the FIU-IND.

  7. How different is a cross-border payment aggregator from a domestic PA in India?

    Well, the key difference is that a domestic PA only processes transactions in Indian Rupee currency (INR), whereas cross-border payment aggregators facilitate multiple currencies, handling foreign exchange, and compliance with FEMA.

  8. Which businesses benefit from the PA-CBs?

    Fintech companies, international traders, cloud providers, streamlining services, Software-as-a-service, global merchants, e-commerce platforms, independent freelancers, and importers/exporters.

  9. What KYC documents are needed for RBI’s cross-border payment aggregator licensing?

    A typical checklist for getting your RBI authorization for a cross-border payment aggregator includes company’s registration certificate, MOA, AOA, PAN, KYC of all directors and promoters, GST, DIN & DSC of partners/directors, net worth verified certificate, audited financial statements, business address, balance sheet of the company, details of all bank accounts, AML, CFT, and KYC policies, PCI-DSS certificate, disaster recovery plan, and a business model with projections of at least three years.  

  10. What does the RBI’s LRS scheme mean?  

    The Reserve Bank of India’s liberalized remittance scheme is a facility that enables Indian residents to freely send up to USD 250,000 abroad in a financial year for allowed personal or capital transactions, such as college in foreign institutions, medical treatments, gifts, and investment in foreign stocks.   

  11. Are cross-border payments legal in India?  

    Of course, cross-border payments are fully legal in India, given that they are properly conducted through an authorized dealer bank or regulated payment aggregator. PA-CBs, being non-banking and fintech entities, are strictly required to get a license to process such transactions online through a secure and safe procedure.   

  12. Which bank account is required for cross-border payment aggregators? 

    You will need a dedicated collection account for import or export with an authorized dealer category-I (AD category- I) scheduled commercial banking authority. Want to know more about how to secure a banking facility after licensing with the RBI? Join Enterslice for a free discussion and find seamless solutions.

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