finpeel Answers · India · updated 2026-08-14
Yes, if you are a non-bank entity operating as a Payment Aggregator in India. Under the RBI's current Master Direction on Regulation of Payment Aggregators, a non-bank PA must obtain RBI authorisation; a bank does not need a separate PA authorisation for that activity.
The current RBI Master Direction covers multiple PA categories, including online, physical and cross-border payment aggregation. The earlier idea that Indian PA regulation is only an 'online aggregator' framework is therefore no longer a complete description of the current perimeter.
A Payment Gateway is different: the RBI defines a PG as a technology-infrastructure provider that routes and facilitates payment processing without involvement in handling funds. The distinction is not simply whether your software appears in the settlement flow; it is whether your business meets the regulatory definition of a PA rather than a technology-only PG.
If your model combines aggregation with cross-border settlement, wallet issuance or another regulated payment-system activity, additional RBI requirements can apply. Map each function separately instead of assuming PA authorisation covers the whole product stack.
Regulator: Reserve Bank of India (RBI)
Primary sources: RBI — Master Direction on Regulation of Payment Aggregators
Directional — not legal advice. Verify with the regulator before committing.