RBI Master Directions 2025, Compliance And Operational Challenges For Payment Aggregators.

1. Background

On 15 September 2025, the Reserve Bank of India issued the Master Direction on Regulation of Payment Aggregators, 2025 ("Master Directions 2025"), a consolidated framework that replaces and supersedes the 2020–21 guidelines on payment aggregators and gateways and earlier directions on cross border payment aggregation. Issued under the Payment and Settlement Systems Act, 2007 together with relevant provisions of FEMA, the Master Directions unify regulation of online, physical and cross border payment aggregation under a single regime applicable to banks, non‑bank entities and Authorised Dealer (AD) banks. For fintechs, e‑commerce platforms, marketplaces and large corporate treasuries that rely on aggregator rails, the Directions represent both a tightening of oversight and an opportunity to reset business models and compliance architectures around a more explicit rule set rather than scattered circulars.