RBI and FEMA

What is the difference between a PA-CB and an OPGSP?

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

An OPGSP (Online Payment Gateway Service Provider) worked under a standing arrangement with an Indian bank.³ OPGSP export receipts were capped at USD 10,000 per transaction from June 2013.⁴ A non-bank PA-CB needs its own RBI authorisation and can handle up to ₹25 lakh per transaction.¹ RBI's 15 September 2025 Master Direction repealed the OPGSP circulars, with one exception.¹

Applies to	Governed by	Deadline	Penalty	Last verified
Cross-border payment aggregators and the exporters they serve	RBI Master Direction on Regulation of Payment Aggregator, 15 September 2025; Payment and Settlement Systems Act, 2007¹	Existing non-bank PA-CBs had to apply by 30 April 2024²	Those that did not apply or meet the net worth test had to wind up PA-CB activity by 31 July 2024²	28 October 2026

Before 2023, many Indian freelancers and small exporters who took card or wallet payments from abroad were served under the Online Payment Gateway Service Provider (OPGSP) arrangement. Today the same activity falls under the Payment Aggregator, Cross Border (PA-CB) regime of the Reserve Bank of India (RBI).¹ The names sound similar, but the legal set-up is different, and so are the limits and protections.

What is a PA-CB, and what was an OPGSP?

A PA-CB is a payment aggregator that facilitates cross-border payments for current account transactions not prohibited under FEMA, for its onboarded merchants, through e-commerce mode; an OPGSP was an online payment gateway, often foreign, that helped exporters collect small cross-border payments through a standing arrangement with an Indian Authorised Dealer (AD) Category-I bank.¹³

PA-CB sub-categories: inward (money into India) and outward (money out of India).¹
PA-CB entity: a non-bank PA-CB must be an Indian company authorised by RBI under the Payment and Settlement Systems Act, 2007; banks do not need separate authorisation.¹
OPGSP origin: RBI introduced the framework in November 2010 after finding that some OPGSPs had let exporters keep export proceeds abroad without repatriation, in violation of FEMA.³
OPGSP duties: the bank, not the OPGSP, carried the main regulatory duties: due diligence of the OPGSP, a NOSTRO collection account abroad, and checking purpose codes.³⁵ A foreign OPGSP had to open a liaison office in India with RBI approval.⁵

RBI first set out PA-CB rules in a circular dated 31 October 2023, and folded them into the Master Direction on Regulation of Payment Aggregator dated 15 September 2025.¹²

Who do the PA-CB rules apply to?

The PA-CB rules apply to non-bank companies that aggregate cross-border payments, with a carve-out for banks and transitional treatment for existing PA-CBs that applied on time.¹⁶

Entity type	Applicable	Why	Best for
Non-bank cross-border aggregator	Yes	Needs a Certificate of Authorisation¹	Checking RBI's list
Bank	No separate authorisation	Banks do not need PA authorisation¹	Bank wires and bank collection accounts
Existing PA-CB that applied by 30 April 2024, decision pending	Old OPGSP circulars kept alive	Paragraph 19 exception¹	Checking RBI's status page
New PA-CB applicant	Cannot operate yet	Must be authorised first⁶	Waiting for authorisation

Exporters do not need the authorisation themselves; they check their provider's status.¹⁶

How do you check a provider under the PA-CB regime?

You check a provider by finding its Indian legal entity on RBI's pages, then reading the settlement clause and checking the cap against your invoices.¹⁶

Check the legal entity: find which Indian company settles your money, then look for it on RBI's authorisation list or status page.⁶
Read the settlement clause: RBI now relies on your contract for timelines, so the clause matters. See PA-CB settlement timelines.
Watch the ₹25 lakh cap on large invoices.¹ See the PA-CB transaction limit.
Keep your FEMA paperwork going: the channel does not change your Export Declaration Form or realisation duties. See FEMA rules for freelancers.

The PA-CB licence list shows the entities RBI lists as authorised.

How do PA-CB and OPGSP rules compare side by side?

The PA-CB rules regulate the aggregator directly, cap transactions in rupees and keep funds in India, while the OPGSP rules worked through the bank, capped transactions in dollars and used an account abroad.¹³⁴⁵

Point	OPGSP (repealed circulars)	PA-CB (2025 Master Direction)	Best for
Who is regulated	AD bank, under a standing arrangement	The PA-CB itself, if a non-bank, plus its banks	Knowing who answers for compliance
RBI authorisation	Bank reported each arrangement to RBI	Non-bank needs a Certificate of Authorisation	Checking a provider's status
Entity	Often foreign, with an Indian liaison office	Company incorporated in India	Identifying the legal entity
Minimum net worth	Not specified	₹15 crore at application; ₹25 crore by end of third financial year	Judging financial standing
Export cap per transaction	USD 10,000 (from 11 June 2013)	₹25 lakh	Exporters with large invoices
Where funds sit	NOSTRO collection account abroad, then export collection account in India	Inward Collection Account with an AD Category-I bank in India	Understanding fund safety
Settlement to exporter	Within seven days of credit to the NOSTRO account	As per the written agreement, which must state timelines	Planning cash flow
Foreign currency settlement	Not provided for	Only for exporters onboarded directly	Exporters wanting non-INR settlement
EDPMS support	Bank checks purpose codes	PA-CB gives exporter's bank documents to close EDPMS entries	Closing export records

The table compares the OPGSP rules in the 2010 to 2015 circulars with the PA-CB rules in the 2025 Master Direction.¹³⁴⁵

How did money move under the OPGSP model?

Under the OPGSP circulars, money moved from the gateway into the AD bank's NOSTRO collection account abroad, then to India, then to the exporter.³⁵

NOSTRO account: the AD bank opened a NOSTRO collection account abroad for export receipts collected through the OPGSP.³
No retention: if the OPGSP gave exporters notional accounts, no funds could be retained in them; receipts had to be swept automatically into the bank's NOSTRO collection account.³⁵
Export Collection account: from 2015, balances were repatriated to an Export Collection account in India and then credited to the exporter.⁵
Allowed debits: only three debits were allowed from the Export Collection account: payment to the Indian exporter, the OPGSP's commission at contracted rates, and a chargeback to the overseas buyer where the exporter had failed to perform the contract.⁵
Audit: each collection account was to be reconciled and audited quarterly.⁵

Under the PA-CB rules, funds sit in an Inward Collection Account with an AD Category-I bank in India instead.¹

What happens to existing OPGSP arrangements now?

Existing OPGSP arrangements survive only for an existing PA-CB whose application is still pending. Paragraph 19 of the 2025 Master Direction repeals the 2010, 2013 and 2015 OPGSP circulars "except for an existing PA-CB which had applied for authorisation as PA-CB on or before April 30, 2024 and a decision thereon is pending".¹

Status page: RBI's status page as on 16 October 2026 shows which existing PA-CBs are still pending and "can operate".⁶
Exporter check: check whether your provider is authorised, pending, or neither. See the PA-CB licence list.

If your arrangement started under the old OPGSP model and you are unsure which regime applies to it, ask the provider and your bank in writing.

Which RBI rule says this?

The current rules are in RBI's Master Direction on Regulation of Payment Aggregator dated 15 September 2025, which replaced the 2023 PA-CB circular and three OPGSP circulars.¹

Rule	Date	Plain meaning
A.P. (DIR Series) Circular No. 17	16 November 2010	OPGSP framework for export receipts (repealed)³
A.P. (DIR Series) Circular No. 109	11 June 2013	OPGSP cap raised to USD 10,000 (repealed)⁴
A.P. (DIR Series) Circular No. 16	24 September 2015	OPGSP processing and settlement of import and export payments (repealed)⁵
PA-CB circular CO.DPSS.POLC.No.S-786	31 October 2023	Cross-border aggregators brought under PA rules (repealed)²
Master Direction on Regulation of Payment Aggregator, paragraph 19	15 September 2025	Current rules; repeals the above, with one exception¹

RBI's 2023 circular put cross-border aggregators under the same authorisation, net worth, governance and KYC rules as domestic payment aggregators.² Existing non-bank PA-CBs had to apply by 30 April 2024 and register with the Financial Intelligence Unit-India (FIU-IND); those that did not apply or meet the net worth test had to wind up PA-CB activity by 31 July 2024.²

What are the common mistakes when comparing PA-CB and OPGSP?

The common mistakes are quoting the old dollar cap, assuming an old OPGSP is authorised, and reading pending status as authorisation.¹⁴⁶

Old dollar cap: the USD 10,000 OPGSP cap has been replaced by ₹25 lakh per transaction.¹⁴
Assuming continuity: a provider that was an OPGSP needs PA-CB authorisation or a pending application that qualifies for the exception.¹
Pending read as authorised: RBI's status page separates pending applicants from authorised entities.⁶
Expecting a seven-day rule: settlement now follows the written agreement.¹

Check the provider's legal entity on RBI's pages before your first payment.

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

Are OPGSPs still allowed to operate in India?+

Mostly not under the old rules. RBI's 15 September 2025 Master Direction repealed the OPGSP circulars, except for an existing PA-CB that applied for authorisation on or before 30 April 2024 and is still awaiting RBI's decision. Other providers need PA-CB authorisation, or must work through a bank.¹

Who regulated OPGSPs before the PA-CB regime?+

RBI's Foreign Exchange Department regulated OPGSPs through A.P. (DIR Series) circulars addressed to AD Category-I banks. Banks entered standing arrangements with OPGSPs and carried the main regulatory duties, and a foreign OPGSP had to open a liaison office in India with RBI approval.³⁵

Is a PA-CB the same as a PA-O?+

No. A PA-O (online) covers domestic online payments, while a PA-CB covers cross-border payments for current account transactions through e-commerce mode. The two are separate categories on RBI's list, and one entity can hold both a PA-O and a PA-CB authorisation at the same time.¹

Can a provider that used to be an OPGSP keep serving exporters?+

An existing PA-CB that applied on time can continue unless RBI advises otherwise, according to the notes on RBI's status page as on 16 October 2026. New applicants cannot operate until they are authorised. Check the provider's legal entity on RBI's pages before relying on it.⁶

Was the OPGSP export limit set in rupees?+

No. OPGSP export limits were set in US dollars: USD 500 per transaction in 2010, later raised to USD 3,000, and then to USD 10,000 per transaction from 11 June 2013. The PA-CB cap that replaced them is set in rupees, at ₹25 lakh per transaction.¹³⁴

What net worth does a non-bank PA-CB need?+

Under RBI's Master Direction, a non-bank PA-CB needs a net worth of ₹15 crore at the time of application and ₹25 crore by the end of the third financial year. The old OPGSP circulars did not specify a net worth for the gateway itself.¹³

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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