RBI and FEMA

What is the PA-CB transaction limit for export payments?

Author:: Editorial team, serviceexportguide.com
Verified by:: Editorial team
Published: 28 October 2026
Last modified: 30 October 2026
Reading time: 6 min read

Short answer

Each inward or outward transaction processed by a Payment Aggregator, Cross Border (PA-CB) is capped at ₹25 lakh, under paragraph 11(d) of RBI's Master Direction dated 15 September 2025.¹ The cap is in rupees and applies per transaction.¹ A larger invoice needs another channel, such as a bank wire.³ Old OPGSP routes were capped at USD 10,000 per transaction.⁵

Applies to	Governed by	Deadline	Penalty	Last verified
Inward (export) and outward (import) transactions processed by a PA-CB	RBI Master Direction on Regulation of Payment Aggregator, 15 September 2025, paragraph 11(d)¹	Not applicable	Not applicable	28 October 2026

When a client abroad pays an Indian exporter through a Payment Aggregator, Cross Border (PA-CB), each payment has a ceiling. The Reserve Bank of India (RBI) sets it at ₹25 lakh per transaction.¹ For most freelancers, tutors and small agencies this never bites. For a software firm billing a quarterly retainer, or a consultancy closing a large project, it can.

What is the PA-CB transaction limit?

The PA-CB transaction limit is ₹25 lakh per inward or outward transaction. Paragraph 11(d) of RBI's Master Direction on Regulation of Payment Aggregator, dated 15 September 2025, says: "In respect of inward or outward transactions processed by a PA - CB, the maximum value per transaction shall be ₹25 lakh."¹

Currency: the limit is set in Indian rupees.¹
Per transaction: the Master Direction sets no daily, monthly or annual cap.¹
Direction: the limit applies to both inward (export receipts) and outward (import payments) PA-CB transactions.¹

The cap is a regulatory maximum, so a provider can choose to accept less.¹

Who does the PA-CB transaction limit apply to?

The PA-CB transaction limit applies to payments processed by a PA-CB, so it mostly affects exporters with single payments above ₹25 lakh.¹ The exporter rows below are illustrative, not data.

Exporter	Typical invoice	Likely to hit ₹25 lakh?	Best for
Freelance designer or writer	Small, frequent	Rarely	PA-CB or bank route, as preferred
Online tutor or coach	Small, recurring	Rarely	PA-CB or bank route, as preferred
Marketing or video agency	Monthly retainers	Sometimes, for large retainers	Bank wire for retainers near the cap
SaaS company	Many small subscriptions	Rarely per payment	PA-CB checkout
IT services or consulting firm	Large project invoices	Often	Bank wire for large invoices

A SWIFT transfer straight to your bank account is not a PA-CB transaction, so the cap does not apply to it.¹

How do you receive an export payment above ₹25 lakh?

You receive an export payment above ₹25 lakh through a channel the PA-CB cap does not limit, usually a direct bank transfer (SWIFT wire) to your account with an Authorised Dealer (AD) bank in India.¹³ Under the 2026 Regulations, the AD bank credits an export receipt after satisfying itself that the transaction is genuine.³

Check the rupee value of the invoice against the ₹25 lakh cap at the current rate.¹
Ask the client to pay by bank wire for the full amount. See receiving a large international payment.
If the contract genuinely has stages (design, build, launch), invoice and receive each stage separately. See milestone payments in export contracts.
For an advance plus balance, route both through the same AD bank, as regulation 10 of the 2026 Regulations requires, unless you inform both banks of a change.³
File the EDF and track realisation, covered below.³

Do not break one invoice into several card payments just to stay under the cap. A bank or PA-CB that sees an unusual pattern may hold the payment or ask for documents.

What FEMA documents and deadlines apply whatever the channel?

The FEMA paperwork is the same whatever the channel: a service exporter files an Export Declaration Form (EDF) and must realise the invoice within the realisation period.³

Requirement	Rule	Deadline or threshold	Best for
EDF	Regulation 3, 2026 Regulations	Within 30 days from the end of the month of invoicing; non-software exporters may file on or before the date payment is received³	Every service exporter
Realisation	Regulation 5	Nine months from invoice; twelve months if invoiced or settled in rupees³	Every service exporter
Reduction in value	Regulation 6	On your declaration alone for invoices up to ₹10 lakh³	Clients who underpay

The PA-CB limit changes the channel, not this paperwork.³

What happens if you split an invoice to fit the PA-CB limit?

If you split one invoice into several payments to fit the PA-CB limit, the bank or PA-CB may hold the payment or ask for documents, because the bank must be satisfied a transaction is genuine before crediting it under regulation 4(2) of the 2026 Regulations.³

Genuine stages: milestone invoices that match the contract are a different case from artificial splitting.
Card limits: paragraph 10(d) says a PA "shall not place limits on transaction amount for a particular payment mode", leaving those to the issuing bank, so the binding limit on a card payment is often the client's own card limit.¹
Provider caps: check each provider's published terms for any lower cap it applies, and treat a missing figure as "not published".

Choose the channel before invoicing to avoid either problem.

Which RBI rule says this, and how did the limit change?

The current rule is paragraph 11(d) of the Master Direction dated 15 September 2025; it replaced the older Online Payment Gateway Service Provider (OPGSP) arrangements, which used dollar caps.¹²⁴⁵

Period	Rule	Cap per transaction	Best for
From 16 November 2010	A.P. (DIR Series) Circular No. 17 (OPGSP)	USD 500	Historical reference
From 14 October 2011	A.P. (DIR Series) Circular No. 35 (OPGSP)	USD 3,000	Historical reference
From 11 June 2013	A.P. (DIR Series) Circular No. 109 (OPGSP)	USD 10,000	Historical reference
From 31 October 2023	PA-CB circular, paragraph 8.2	₹25,00,000 per unit of goods or services	Historical reference
From 15 September 2025	Master Direction, paragraph 11(d)	₹25 lakh per transaction	Current transactions

The 2010 cap is from Circular No. 17; the 2011 and 2013 figures are as recorded in Circular No. 109; the 2023 and 2025 figures are from the PA-CB circular and the Master Direction.¹²⁴⁵ The OPGSP and 2023 circulars have been repealed.¹

Did the wording of the PA-CB cap change in 2025?

Yes, slightly. The 31 October 2023 PA-CB circular said "the maximum value per unit of goods / services sold / purchased shall be ₹25,00,000", while the 2025 Master Direction says "the maximum value per transaction shall be ₹25 lakh".¹²

Amount: the amount is the same.¹²
Basis: the 2025 wording ties the cap to each transaction rather than to each unit sold.¹
Import due diligence: the 2023 circular also asked import-side PA-CBs to carry out due diligence of the buyer where a unit imported was worth more than ₹2,50,000; that circular has since been repealed.¹²

Older articles quoting the "per unit" wording describe the repealed circular.²

What are the common mistakes with the PA-CB transaction limit?

The common mistakes with the PA-CB limit are reading it in dollars, splitting invoices to fit it, and assuming it applies to bank wires.¹³

Reading it in dollars: the cap is ₹25 lakh, so its dollar value moves with the rate.¹
Artificial splitting: the bank must be satisfied each transaction is genuine.³
Applying it to wires: a SWIFT transfer straight to your bank account is not a PA-CB transaction.¹
Quoting old limits: the USD 10,000 OPGSP cap has been repealed.¹⁵

If a large invoice is coming, agree the channel with the client and your bank in advance.

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

Is the ₹25 lakh PA-CB limit per invoice or per year?+

The ₹25 lakh PA-CB limit applies per transaction. Paragraph 11(d) of RBI's 2025 Master Direction on Regulation of Payment Aggregator says the maximum value per transaction is ₹25 lakh, and the Master Direction sets no daily, monthly or annual cap on top of that for PA-CB transactions.¹

Is the PA-CB limit set in dollars?+

No. The PA-CB limit is ₹25 lakh, set in Indian rupees, so the foreign currency equivalent moves with the exchange rate. Check the rupee value of a large invoice at the current rate before choosing the payment channel, because an invoice under the cap one month may be over it the next.¹

Can an exporter split a large invoice into several PA-CB payments?+

Only if the split is genuine, for example milestone invoices set out in the contract. Under regulation 4(2) of the FEMA 2026 Regulations, the bank must be satisfied a transaction is genuine before crediting it, and splitting one invoice artificially to avoid the PA-CB limit invites questions and holds.³

Does the PA-CB limit apply to a normal bank wire?+

No. The ₹25 lakh cap is in RBI's Payment Aggregator Master Direction and applies to transactions processed by a PA-CB. A SWIFT transfer straight from the client to your account with an AD bank in India is not a PA-CB transaction, so the cap does not apply to it.¹³

What were the old OPGSP transaction limits?+

The old Online Payment Gateway Service Provider limit was USD 500 per transaction from November 2010. RBI raised it to USD 3,000 in 2011 and to USD 10,000 in June 2013, as recorded in Circular No. 109. Those OPGSP circulars have since been repealed and replaced by the PA-CB regime.¹⁴⁵

Does a card limit matter more than the PA-CB cap?+

Often, yes. Paragraph 10(d) of the Master Direction says a payment aggregator shall not place limits on transaction amount for a particular payment mode, leaving those to the issuing bank. In practice the binding limit on a client's card payment is often the client's own card limit.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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