finpeel Answers · India · updated 2026-08-14
A pure Payment Gateway that only provides technology and does not handle funds is not treated the same as a non-bank Payment Aggregator under the RBI PA framework. But if the business operates a regulated payment system or performs PA functions, RBI authorisation can be required.
The safest test is substance: who receives the merchant’s customer funds, who controls settlement and who operates the regulated payment service.
Do not rely on the word “gateway” if the commercial model has evolved into aggregation, merchant onboarding or settlement control.
Regulator: Reserve Bank of India (RBI)
Primary sources: RBI — Guidelines on Regulation of Payment Aggregators and Payment Gateways
Directional — not legal advice. Verify with the regulator before committing.
Read on finpeel.com · All answers · Check the licensing perimeter