finpeel Answers · India · updated 2026-08-14
Not if the fintech itself issues a regulated Prepaid Payment Instrument. It can instead build a distribution or technology layer over an authorised bank or non-bank PPI issuer, provided the authorised issuer remains the regulated issuer.
The closed-system exception can also matter where value is usable only for the issuing entity’s own goods or services and does not constitute a regulated payment system.
Map who legally owes the stored value to the customer and where the balance can be used before deciding whether the fintech is an issuer or a partner.
Regulator: Reserve Bank of India (RBI)
Primary sources: RBI — Master Direction on Prepaid Payment Instruments · RBI — FAQs on Prepaid Payment Instruments
Directional — not legal advice. Verify with the regulator before committing.
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