RBI Issues a New Notification on the Regulation of Cross-Border Payment Aggregators

Narendra Kumar

04 Nov, 2023

The Reserve Bank of India (RBI) has recently issued a circular RBI/2023-24/80, marking a significant move in the regulation of Payment Aggregators for Cross-Border (PA-CB) transactions. This circular serves as an important progression from previous guidelines, particularly focusing on entities that facilitate cross-border payment transactions for imports and exports. This development is crucial for maintaining the integrity and security of India’s financial system, especially in the backdrop of burgeoning digital payment landscapes and international e-commerce.

Expanding Scope of Regulation

Prior to this circular, the focus was predominantly on domestic transactions processed by Payment Aggregators (PAs). However, the recent shift to include cross-border transactions under the RBI’s purview marks a proactive step towards addressing the complexities of international trade and digital payments.

Mandatory Authorisation and Compliance

A key element of the circular is the requirement for non-bank entities providing PA-CB services to seek RBI authorisation. The deadline set for this is April 30, 2024. Moreover, entities are expected to comply with stringent guidelines encompassing governance, customer grievance, dispute management, and technology standards. These measures indicate RBI’s intent to tighten oversight and enhance operational standards.

Networth Requirements

The circular stipulates that non-bank PA-CBs must have a minimum net worth of ₹15 crore at the time of the authorisation application, increasing to ₹25 crore by March 31, 2026. This requirement echoes the RBI’s emphasis on ensuring that entities engaging in cross-border payment services are financially robust and reliable.

Account Management and Due Diligence

Importantly, the circular mandates the maintenance of separate Import Collection Accounts (ICAs) and Export Collection Accounts (ECAs). This segregation aids in precise tracking and management of funds related to imports and exports. Furthermore, PA-CBs are responsible for conducting due diligence, particularly for transactions exceeding ₹2,50,000, underscoring the RBI’s focus on mitigating money laundering and fraud risks.

Operational Implications

Entities facilitating both import and export transactions must adhere to guidelines for both ICA and ECA. This provision is indicative of the regulatory focus on transparency and accountability in handling foreign currency transactions.

Potential Implications

Enhanced Security and Transparency

This regulation will likely enhance security and transparency in cross-border transactions, thus fostering trust among international trade participants.

Increased Compliance Costs

Entities might face increased operational and compliance costs to meet the stringent requirements, potentially impacting smaller players more significantly.

Market Consolidation

Tighter regulations may lead to market consolidation, benefiting larger entities with the requisite capital and infrastructure to comply.

Technological Investments

Meeting the RBI’s technology and security standards will necessitate significant investments in cybersecurity and fraud detection systems.

Forward-Looking Insights

As digital payments continue to evolve, regulations like these will be pivotal in shaping the landscape. We can anticipate:

1. Increased Regulatory Oversight: Other countries may follow suit with similar regulations, leading to a more standardized global framework.
2. Technological Advancements: The need for advanced technology solutions for compliance and security will surge, driving innovation in fintech.
3. Collaborations and Partnerships: Banks and fintech firms might explore collaborative models to navigate the regulatory environment efficiently.
4. Consumer Impact: Enhanced security and streamlined processes could result in better consumer experiences in international e-commerce.

Conclusion

The RBI’s regulation of PA-CB entities is a commendable step towards fortifying the integrity of India’s financial system in the digital age. While it presents challenges, particularly in terms of compliance and operational adjustments, the long-term benefits in terms of secure, transparent, and efficient cross-border payment processing are undeniable. This move will not only protect the interests of consumers and businesses but also bolster India’s position in the global digital economy. As the landscape evolves, continuous engagement between the RBI, payment aggregators, and other stakeholders will be essential to ensure that the ecosystem remains dynamic, secure, and conducive to growth.