What do RBI's PA-CB guidelines mean for Indian exporters?

A Payment Aggregator, Cross Border (PA-CB) is a company that collects cross-border payments for its merchants, including Indian exporters, and settles the money to them.¹ For example, if a translator in Pune is paid by card by a client in Berlin through an online checkout, or a SaaS founder in Bengaluru collects subscription fees from US customers, the collection is often handled by a PA-CB.

Since 15 September 2025, all RBI rules for payment aggregators sit in one Master Direction, issued under the Payment and Settlement Systems Act, 2007 and sections 10(4) and 11(1) of the Foreign Exchange Management Act (FEMA), 1999.¹ This page covers the parts that matter to an exporter receiving money. For who holds a licence, see the PA-CB licence list.

What is a PA-CB under RBI's 2025 Master Direction?

A PA-CB is a payment aggregator that "facilitates aggregation of cross-border payments for current account transactions, that are not prohibited under FEMA, for its onboarded merchants through e-commerce mode".¹

• Sub-categories: PA-CB facilitating inward transactions (money coming into India) and PA-CB facilitating outward transactions (money leaving India).¹
• Merchants: the Master Direction defines "merchant" to include exporters.¹
• Outside PA-CB: a non-bank AD Category-II entity handling current account transactions other than purchase or sale of goods or services.¹
• Also outside PA-CB: a card transaction where the card network handles the foreign exchange settlement and the aggregator receives the payment in local currency.¹

An exporter meets the PA-CB rules as a merchant.

Who do the RBI PA-CB guidelines apply to?

The RBI PA-CB guidelines apply to non-bank payment aggregators, which need RBI authorisation, and to the exporters they onboard as merchants; banks do not need authorisation to carry on PA business.¹

RBI publishes the entities it has authorised, with their category (PA-O, PA-P, PA-CB-I, PA-CB-O or PA-CB-I & O).⁵

How does an exporter receive money through a PA-CB?

An exporter receives money through a PA-CB by passing its due diligence, having client payments collected into an Inward Collection Account, and being settled under the timelines in the merchant agreement.¹

1. Due diligence: the PA carries out customer due diligence under RBI's Know Your Customer Master Direction, retrieving your KYC record from the Central KYC Records Registry (CKYCR) with consent.¹
2. Settlement clause: read the settlement timelines written into your agreement before signing.¹
3. Collection: client payments go into the PA-CB's Inward Collection Account (InCA) with an AD Category-I bank.¹
4. Settlement: the PA-CB credits you as per the agreement; non-INR settlement is allowed only if the inward PA-CB onboarded you directly.¹
5. Closing the export entry: file your Export Declaration Form (EDF), and the PA-CB gives your bank the documents needed to close the EDPMS entry.¹³

The steps below explain each stage in more detail.

Where does an exporter's money sit before settlement?

A non-bank PA-CB keeps inward collections in an InCA with an Authorised Dealer Category-I Scheduled Commercial Bank.¹

• Currencies: the InCA is held separately for INR and for each non-INR currency.¹
• No pre-funding or interest: pre-funding is not permitted and no interest is paid on the balance.¹
• Day-end balance: cannot be less than the amount collected for merchants but not yet settled to them.¹
• Permitted debits: payment to the onboarded merchant, refunds to the payer and the PA's commission.¹

How fast must a PA-CB settle to an exporter?

The Master Direction does not set a fixed number of days for PA-CB settlement. It says credit to the merchant's account is "as per the agreement between the PA and the merchant", and that the agreement "should be fair, equitable and must transparently mention the settlement timelines".¹ See PA-CB settlement timelines.

What due diligence will a PA-CB do on an exporter?

A PA must carry out customer due diligence on its merchants, with a simpler route for small exporters.¹

• Small merchants: for merchants with annual export turnover up to ₹5 lakh (or annual turnover up to ₹40 lakh), an alternative process is allowed: PAN or Form 60 verified with the issuer, a contact point verification of the business address and one officially valid document.¹
• Monitoring: the PA also does background checks and monitors your transactions against your business profile.¹
• Existing merchants: merchants onboarded until 31 December 2025 must meet these requirements within one year of the Master Direction.¹

Which PA-CB limits and rules affect an exporter directly?

The PA-CB rules an exporter will notice are in paragraph 11 of the Master Direction, including the ₹25 lakh transaction cap.¹

All rows are from paragraph 11 of the 2025 Master Direction.¹ For more on the cap, see the PA-CB transaction limit.

What happens if an exporter treats a PA-CB receipt as outside FEMA export rules?

An exporter who treats a PA-CB receipt as outside FEMA can miss duties that still apply: from 1 October 2026, the FEMA (Export and Import of Goods and Services) Regulations, 2026 (the 2026 Regulations) require every service exporter to file an EDF and to realise the invoice value within nine months of the invoice date, or twelve months if invoiced or settled in rupees.³⁴

• EDF: receiving through a PA-CB does not remove the EDF duty.³
• Realisation: the nine-month or twelve-month period still runs from the invoice date.³⁴
• EDPMS: the PA-CB's job under paragraph 11(h) is to give your bank the information needed to close the EDPMS (Export Data Processing and Monitoring System) entry.¹ See EDPMS for service exporters.

The PA-CB rules sit alongside the FEMA export rules.

Which RBI rule says what about PA-CBs?

The Master Direction on Regulation of Payment Aggregator dated 15 September 2025 is the PA-CB rulebook, and it repealed the earlier PA-CB and OPGSP circulars.¹

The Master Direction also repealed the 2020 and 2021 PA guidelines.¹ For the history, see PA-CB vs OPGSP.

What are the common mistakes with RBI PA-CB guidelines?

The common mistakes are assuming a PA-CB has a fixed settlement period, assuming every exporter can be settled in foreign currency, and skipping the EDF.¹³

• Fixed settlement days: the Master Direction leaves settlement timelines to the agreement.¹
• Foreign currency settlement: only exporters onboarded directly by the inward PA-CB can be settled in non-INR currencies.¹
• Large invoices: a single transaction above ₹25 lakh exceeds the PA-CB cap.¹
• Skipping the EDF: the 2026 Regulations still require an EDF for every service export.³

Note: This page summarises RBI's rules. Whether a particular provider is compliant is for RBI to decide; check its authorisation and, if your situation is unusual, ask your bank or a chartered accountant.