RBI and FEMA

How long can a PA-CB take to settle export payments to me?

Author:: Editorial team, serviceexportguide.com
Verified by:: Editorial team
Published: 28 October 2026
Last modified: 30 October 2026
Reading time: 7 min read

Short answer

RBI does not set a fixed number of days for PA-CB settlement.¹ Its Master Direction of 15 September 2025 says a PA-CB credits the merchant "as per the agreement between the PA and the merchant".¹ That agreement must "transparently mention the settlement timelines".¹ The exporter must still realise the invoice within nine months, or twelve months for rupee invoices.²³

Applies to	Governed by	Deadline	Penalty	Last verified
Exporters paid through a cross-border payment aggregator (PA-CB)	RBI Master Direction on Regulation of Payment Aggregator, 15 September 2025, paragraph 16 and Table 1; FEMA 2026 Regulations, regulation 5¹²	Settlement as per the agreement; realisation within nine months of invoice (twelve months in rupees)¹³	Not applicable	28 October 2026

A Payment Aggregator, Cross Border (PA-CB) collects a foreign client's payment and then settles it to the Indian exporter. The gap between the two, the settlement time, decides when a freelance illustrator can pay rent or an agency can run payroll. The Reserve Bank of India (RBI) does not fix that gap in days. It requires the timeline to be written into your agreement with the PA-CB.¹

This page explains what the rules say, how they differ from the old Online Payment Gateway Service Provider (OPGSP) rules, and how settlement fits with your own FEMA deadlines. For the general meaning of the term, see what a settlement period is.

What is the PA-CB settlement timeline under RBI rules?

The PA-CB settlement timeline is whatever your agreement with the PA-CB says, because RBI's Master Direction on Regulation of Payment Aggregator, dated 15 September 2025, does not fix a number of days.¹ Table 1 under paragraph 16 says, for "Credit to merchant's a/c": "As per the agreement between the PA and the merchant. Such an agreement should be fair, equitable and must transparently mention the settlement timelines."¹

Disclosure: the rule is about disclosure and fairness, with no fixed number of days.¹
Roles: paragraph 8(b) adds that agreements between a PA, its merchants and banks must clearly set out roles and responsibilities, including refunds, failed transactions, reconciliation and grievance redressal.¹

Read the settlement clause before you sign, because that clause is your timeline.

Who does the PA-CB settlement rule apply to?

The settlement rule applies to non-bank PA-CBs and the exporters they pay, with different treatment for direct onboarding and for existing PA-CBs still awaiting a decision.¹

Party	Applicable	Why	Best for
Non-bank PA-CB	Yes	Must state settlement timelines and hold collections in an InCA¹	Checking the agreement
Exporter onboarded directly by the inward PA-CB	Yes, with non-INR option	Paragraph 11(i) allows non-INR settlement only for directly onboarded exporters¹	Exporters wanting foreign-currency settlement
Exporter onboarded through another arrangement	Yes, INR settlement	Non-INR settlement needs direct onboarding¹	Exporters happy with rupees
Existing PA-CB that applied by 30 April 2024, awaiting a decision	Old OPGSP circulars still relevant	The Master Direction's repeal excludes these¹	Checking which rules a provider follows

Settlement time matters differently by exporter. Freelancers with monthly bills such as rent or EMIs feel a two- or three-day difference most; agencies paying contractors need predictable dates; SaaS businesses with many small receipts care about batching; consultants with occasional large invoices care more about holds and document requests than speed.

How do you check settlement terms in a PA-CB agreement?

You check settlement terms by reading six clauses in the agreement before you sign. If a provider does not publish a figure, treat it as "not published" and ask in writing.¹

Settlement timeline: the stated number of business days from the client's payment to credit in your account.¹
Currency of settlement: whether you receive INR or foreign currency. Non-INR settlement is allowed only if the PA-CB onboarded you directly.¹
Holds and reserves: when the provider may delay or withhold settlement, for example on a dispute. See payout on hold.
Refunds and chargebacks: how reversed card payments are recovered from you. Refunds go back to the original payment method unless the payer instructs otherwise.¹
Grievance contact: RBI requires a PA to display a responsible officer and escalation matrix on its website.¹
EDPMS documents: the PA-CB must give your bank what it needs to close your EDPMS entry.¹

Compare the written settlement clause across providers on the PA-CB licence list, and confirm each provider's authorisation on RBI's own pages.

What rules apply to an exporter's money while it waits for settlement?

While it waits for settlement, an exporter's money with a non-bank PA-CB is held in an Inward Collection Account (InCA) with an Authorised Dealer Category-I Scheduled Commercial Bank.¹

InCA rule	What it means for you	Best for
Separate account for INR and for each non-INR currency	Your USD and GBP receipts may sit in different accounts	Exporters paid in several currencies
Pre-funding not permitted	The PA cannot top up the account to pay you early from its own money	Understanding why payouts wait
No interest payable on balances	Nobody earns interest on your unsettled funds in the InCA	Exporters with large balances
Day-end balance at least equal to amounts due to merchants	Money owed to you must be covered every day	Checking the safety of funds
Used only for authorised PA business	The account cannot fund the PA's other activities	Checking the safety of funds

Inward and outward funds must also be kept apart, with no co-mingling or netting.¹ The PA must submit a quarterly auditor's certificate on escrow balances and a bankers' certificate on InCA debits and credits to RBI.¹

What is the timeline for PA-CB settlement and the FEMA deadlines?

The only fixed dates that matter to an exporter are the FEMA ones: realisation within nine months from the invoice date, and the EDF within 30 days from the end of the month of invoicing.²³ The Master Direction's own fixed dates apply to PAs.¹

Event	Deadline	Best for
Realisation of a service export	Nine months from invoice; twelve months if invoiced or settled in rupees²³	Every exporter
Export Declaration Form (EDF)	Within 30 days from the end of the month of invoicing, or for non-software services on or before the date payment is received²	Every exporter
PA escrow requirements (existing PAs)	By 31 December 2025¹	Checking a PA's compliance
Escrow account (existing PA, after authorisation)	Within two months of authorisation¹	Checking a PA's compliance
Old OPGSP credit to exporter (repealed)	No later than seven days from credit to the NOSTRO collection account⁴	Comparing with the old regime

Failed-transaction refunds follow RBI's turnaround-time instructions referred to in paragraph 8(a).¹ Under the OPGSP circulars, balances in the NOSTRO collection account had to be credited to the exporter's account in India "immediately on receipt of the confirmation from the importer and, in no case, later than seven days".⁴ Those circulars were repealed by the 2025 Master Direction, except for existing PA-CBs that applied by 30 April 2024 and are awaiting a decision.¹

What happens if a PA-CB payout is delayed near the FEMA deadline?

If a PA-CB payout is delayed near the FEMA deadline, your obligation does not move, because the deadline runs from your invoice and not from settlement.²³ Under regulation 5 of the FEMA (Export and Import of Goods and Services) Regulations, 2026, as amended, the full value of a service export must be realised and repatriated within nine months from the date of invoice, or twelve months if invoiced or settled in Indian rupees.²³

Short delays: a few days' settlement delay rarely matters against a nine-month window.³
Late client plus stuck payout: this is when the delay matters.
Extension: if you are close to the deadline, ask your Authorised Dealer bank for an extension; regulation 5 lets it extend the period when satisfied with your reasons.²

See the export realisation period for the full rules.

Which RBI rule says this?

The settlement rules come from RBI's Master Direction on Regulation of Payment Aggregator dated 15 September 2025, and the realisation rule from the FEMA 2026 Regulations.¹²

Rule	Clause	Date	Plain meaning
Master Direction on Regulation of Payment Aggregator	Paragraph 16, Table 1	15 September 2025	Settlement as per a fair agreement that states the timeline¹
Same	Paragraph 8(b)	15 September 2025	Agreements set out roles, refunds, failed transactions, reconciliation and grievances¹
Same	Paragraph 11(i)	15 September 2025	Non-INR settlement only for directly onboarded exporters¹
FEMA 2026 Regulations, as amended	Regulation 5	Amendment dated 22 September 2026	Realisation within nine months, or twelve months in rupees²³
A.P. (DIR Series) Circular No. 16	OPGSP settlement	24 September 2015 (repealed)	Old seven-day credit rule⁴

Read the Master Direction itself for the full InCA and escrow conditions.¹

What are the common mistakes with PA-CB settlement?

The common mistakes with PA-CB settlement are expecting a regulatory number of days, ignoring the holds clause, and treating the payout date as the FEMA date.¹²

Expecting T+1 by law: RBI leaves the timeline to the agreement.¹
Ignoring holds: the holds and reserves clause decides when settlement can be withheld.
Assuming dollar settlement: non-INR settlement needs direct onboarding.¹
Counting from the payout: the realisation period runs from the invoice date.²³

Keep the agreement's settlement clause with your records, so you can point to it if a payout runs late.

How did we verify this?

We checked this page against the sources below on 30 October 2026. Read our methodology or report an error.

Frequently asked questions

Does RBI say a PA-CB must settle within T+1 or T+2?+

No. RBI's 2025 Master Direction on Regulation of Payment Aggregator does not set T+1, T+2 or any other number of days. It leaves the settlement timeline to the agreement between the PA and the merchant, which must be fair and equitable and must state the settlement timeline transparently.¹

Can a PA-CB hold an exporter's money in its own account?+

A non-bank PA-CB must keep inward collections in an Inward Collection Account (InCA) with an AD Category-I bank, used only for authorised PA business. Its day-end balance cannot be less than the amount collected for merchants but not yet settled, so money owed to exporters must be covered every day.¹

What was the settlement deadline under the old OPGSP rules?+

Under the repealed OPGSP circulars, export proceeds in the NOSTRO collection account had to reach the exporter's account in India no later than seven days from the date of credit to that account. The 2025 Master Direction repealed those circulars, except for existing PA-CBs that applied by 30 April 2024.¹⁴

Does a PA-CB payout delay change an exporter's FEMA deadline?+

No. The nine-month realisation period runs from the invoice date under regulation 5 of the FEMA 2026 Regulations, whatever the payout date. If a payout is stuck near the deadline, ask your AD bank for an extension, which regulation 5 lets the bank grant when satisfied with your reasons.²³

Can a PA-CB settle export payments to an Indian exporter in dollars?+

Only if the PA-CB onboarded the exporter directly. Paragraph 11(i) of RBI's Master Direction on Regulation of Payment Aggregator allows non-INR settlement only for exporters directly onboarded by the inward PA-CB. Exporters reached through another arrangement receive settlement in rupees.¹

Can a PA-CB pay an exporter early from its own money?+

No. RBI's rules for the Inward Collection Account say pre-funding is not permitted, so the PA cannot top up the account to pay merchants early from its own money. No interest is payable on InCA balances, and inward and outward funds must be kept apart with no co-mingling or netting.¹

This page is general information for Indian service exporters, not tax or legal advice. Rules change and outcomes depend on your facts, so confirm with a chartered accountant before acting.

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