Payment Aggregator Advisory and Compliance Support
Advisory on the RBI payment aggregator authorisation path, compliance documents and merchant onboarding frameworks.
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Payment aggregator advisory supports companies that want to collect payments from customers on behalf of online merchants, which in India is a regulated activity authorised by the Reserve Bank of India under the Payment and Settlement Systems Act, 2007 and the RBI directions for payment aggregators. This is different from a merchant who simply integrates a payment gateway into a website. Our team of Chartered Accountants and Company Secretaries advises on the authorisation path, helps organise net-worth and governance documentation, and supports the policies and merchant onboarding framework that RBI expects. Authorisation itself is granted only by RBI.
Who provides this service: our team of Chartered Accountants.
Who Needs Payment Gateway Aggregator Solutions?
- Fintech founders planning to collect payments for multiple online merchants
- Marketplace operators that hold and settle seller funds
- Technology companies unsure whether their payment product is regulated
- Existing payment businesses preparing documents for a regulatory review
Key Benefits
- Clarity on whether your model needs RBI authorisation or only a gateway integration
- A documented roadmap of the application stages and what RBI is likely to examine
- Support with net-worth computation, certification workings and capital planning
- Board-approved policy drafts coordinated for risk, security, grievance and merchant onboarding
- Merchant due-diligence and onboarding frameworks that match the regulatory expectations
- Compliance calendar for periodic reporting and audits after authorisation
How It Works
Assess the business model
We study how funds will flow between customers, your entity and merchants, and tell you whether the activity makes you a payment aggregator, a technology provider only, or something that needs a different permission.
Check eligibility and structure
The applicant company, its shareholding, directors and objects are reviewed against the RBI directions. Gaps in the structure, such as ownership or main objects, are pointed out before an application is attempted.
Plan net worth and capital
We prepare the working papers on net worth, show how the required level is to be met and maintained by the stated deadlines, and coordinate certification by the statutory auditor where RBI asks for it.
Prepare policies and documents
Policies on information security, risk, grievance redressal, merchant onboarding and escrow management are drafted with your team, together with the technical and audit documents the application needs.
Support the application
The application is assembled on the RBI portal route, queries from the regulator are tracked, and responses are prepared with input from your technology and finance teams.
Post-authorisation compliance
After authorisation we help set up escrow account reconciliation, periodic returns, system audits and merchant monitoring routines so that the authorised entity stays compliant.
Documents Required
- Certificate of incorporation, memorandum and articles of the applicant
- Shareholding pattern and details of beneficial owners
- Directors profile, KYC and fit-and-proper declarations
- Audited financial statements and net-worth certificate
- Business plan and projected financials for the payment activity
- Information security and cyber security policies
- Merchant onboarding, KYC and risk management policies
- Escrow arrangement details with the partner bank
- Technology architecture and system audit reports
Timeline and Fees
Indicative timeline: Preparation of documents and policies usually takes several weeks. The regulator then reviews the application over a period that depends entirely on RBI, and queries can extend the time considerably.
Professional fee: The fee depends on the current structure of your company, the volume of policies and technical documents to be prepared, the extent of regulator queries and whether post-authorisation compliance support is included. Regulatory fees are separate and set by the authority.
What Can Go Wrong if This Is Missed or Done Incorrectly
- Carrying on payment aggregation without the required authorisation can attract regulatory action under the payment systems law
- Incomplete or inconsistent applications can be returned or delayed by the regulator
- Failure to maintain net worth or follow RBI directions after authorisation can put the authorisation at risk
- Weak merchant due diligence or security controls can expose the business to fraud and enforcement action
Frequently Asked Questions
What is a payment aggregator in India?
A payment aggregator is an entity that collects payments from customers on behalf of merchants, holds the funds for a short period and then settles them to the merchants. Non-bank entities carrying on this activity need authorisation from the Reserve Bank of India under the Payment and Settlement Systems Act.
How is a payment aggregator different from a payment gateway?
A payment gateway is technology that securely passes payment data between the customer, the merchant and the banks. An aggregator also handles the money, collecting and settling to merchants. Because the aggregator touches funds, it is regulated by RBI, while a pure technology gateway is not authorised in the same way.
Does my online store need a payment aggregator licence?
No. A merchant that accepts payments through an authorised aggregator or a bank gateway does not need its own authorisation. The requirement applies to a business that onboards other merchants and handles their settlements. If you only sell your own goods, integrating an authorised provider is usually enough.
What are the main requirements for RBI authorisation?
RBI directions cover items such as the nature of the applicant company, minimum net worth to be reached and maintained, board-approved policies, merchant due diligence, an escrow account with a bank, security audits and reporting. The exact amounts and timelines are in the current RBI directions, so confirm them there.
Can you obtain the authorisation for me?
No one can promise approval, because RBI alone decides on every application. What we do is assess your model, prepare documents and policies, support the application and respond to queries, so your submission is complete and consistent. Outcomes and timelines depend on the regulator.
Is a payment gateway licence the same as an aggregator authorisation?
People use the terms loosely, but they are not the same. Many businesses offering gateway services are actually aggregators in a regulatory sense. Our team reviews your fund flow to identify the correct category and suggests the right route. See our payment gateway licence page for more.
Official Sources
Rules, forms and fees change. Check the current position on the official portal:
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Last reviewed: . Laws, fees and procedures change; check the official portal before you act.
Disclaimer: The information on this page is for general informational purposes only and does not constitute professional legal, tax or compliance advice. Requirements vary by situation. Please consult a qualified CA or CS for advice specific to your needs. Government fees and timelines are subject to change; verify with the relevant authority before proceeding.