Governing The Gateways: Ambiguities In RBI's Guidelines On Payment Aggregators

In a long-awaited move, the Reserve Bank of India (RBI) recently released its guidelines for the regulation of payment aggregators and gateways. These guidelines were issued exactly six months after the RBI published its initial discussion paper, which proposed, for the first time, several possible approaches to regulate payment intermediaries. While several industry players have welcomed the RBI's announcement as a step in the right direction, a closer look at the guidelines raises several unsettling questions.

What happens to old-fashioned intermediaries?

The RBI has, to everyone's relief, distinguished between pure-play technology providers (payment gateways) and more involved players (payment aggregators). The regulator has chosen to limit the scope of the guidelines to the latter, i.e. entities that are actively involved in the flow of funds during payment transactions. However, these guidelines don't explicitly supersede or replace the RBI's 2009 circular on