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ARTICLE · 07 JANUARY 2026

RBI Master Direction On Digital Payment Aggregators: Understanding Compliance Requirements And Industry Implications

AK & Partners
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On September 15, 2025, the Reserve Bank of India ("RBI") issued a single, consolidated Master Direction ("MD") to regulate Payment Aggregators ("PAs") operating in India...

IndiaFinance and Banking
Kritika Krishnamurthy
Kritika Krishnamurthy

Executive Summary

On September 15, 2025, the Reserve Bank of India ("RBI") issued a single, consolidated Master Direction ("MD") to regulate Payment Aggregators ("PAs") operating in India, bringing together rules for online, physical/point of sale and cross-border aggregation in a coherent framework. The MD applies to all banking, non-banking (Indian), and scheduled commercial banking entities that interact with the three categories of PAs: physical, online and cross-border. Payment Gateways ("PGs") that only provide routing tech and do not touch funds are explicitly out of scope, although PGs are encouraged to adopt the MD's baseline tech recommendations.

The new MD seeks to reduce systemic, consumer-protection and FX-related risk by introducing modern cyber-resilience, data sovereignty, audit requirements, tightening merchant Know Your Customer ("KYC") and ongoing transaction thresholds, on top of the pre-existing PA architecture. It is also set to strengthen governance by

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