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Feedback to RBI on draft amendments related to Payment Aggregator Regulations
Feedback to RBI on draft amendments related to Payment Aggregator Regulations

June 4, 2024

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We submitted feedback to Reserve Bank of India (RBI) on the: (1) draft regulation on Payment Aggregators – Physical Point of Sale (PA-P), and (2) draft clarifications to Guidelines on Regulation of Payment Aggregators and Payment Gateways (PA-PG Guidelines).

Our feedback was divided into 2 parts, and covered the following:

Part I: Concerns with the draft amendments to the PA-PG Guidelines with a view to minimising unintended consequences on legitimate business practices and adopting least burdensome measures that achieve the desired objective. We raised the following issues:

  1. The definition of PA-P and PA-O based on the time of delivery of goods/services, needs to be reviewed.
  2. The basis (i.e., annual turnover) of categorisation of merchants needs to be reviewed.
  3. PAs should be continued to be allowed to debit escrow account as per merchant’s instructions.
  4. Contact Point Verification of small and medium merchants should be reviewed. 

Part II: Need for clarifications under the draft amendments to PA-PG Guidelines and the draft PA-P regulation, to avoid ambiguity and enable effective compliance by the industry. This included, inter alia:

  1. Would PAs need to maintain escrow accounts for online and offline activity separately? Would PAs be allowed to operate 2 escrow accounts each for PA-P and PA-O business?
  2. How often should transaction activity be monitored to determine when a merchant should transition to a different CDD category? 
  3. How would a PA ensure that the processed transactions align with the merchant’s business profile?
  4. How should the requirement of displaying name of merhcant and PA be fuldilled in case the payment page is mantained by the merchant?

Our submission is attached below. 

For any information, please write to garima@nasscom.in with a copy to policy@nasscom.in.


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20240531-PAamendments-RBI-nasscom.pdf

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Garima Prakash
Manager, Public Policy and Government Affairs

Reach out to me for all things policy about e-commerce, international trade, export controls, start-ups and fintech

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