RBI PA/PG payment aggregator license deadline June 30, 2026: who still needs to apply and the 30-day final extension
By Tejaswi Pandya & Ishita Chatterjee · · RBI
The Reserve Bank of India's Payment Aggregator and Payment Gateway (PA-PG) guidelines, first issued in March 2020 and amended through 2022, 2023, and 2024, require every non-bank entity facilitating online payment acceptance for merchants to hold an RBI PA license. The original transition deadline of June 30, 2021 was extended multiple times in response to industry feedback, and the current, and RBI has stated, final, extension expires on June 30, 2026.
The pool of entities still without a PA license but operating in PA-equivalent capacity includes marketplace platforms with their own checkout flow, SaaS billing platforms collecting subscriptions on behalf of customer-merchants, travel and insurance aggregators with closed-loop payment arrangements, and a long tail of fintech intermediaries that have been operating under banking-channel arrangements without their own PA license. As of mid-May 2026, RBI had granted approximately 47 in-principle approvals and 28 final licenses out of a reported applicant pool of 215. The remaining applicants are at various stages of due diligence, with the most common reasons for delay being net worth shortfall, governance documentation gaps, and merchant onboarding KYC framework deficiencies.
The net worth threshold is the most binding constraint. Existing PAs (operating before March 17, 2020) need minimum ₹15 crore net worth at the time of application and must maintain ₹25 crore by March 31, 2027. New PAs must have ₹25 crore from day one. Net worth must be in the form of paid-up equity capital and free reserves, not borrowed funds or accumulated debt. Quarterly net worth certification by a registered Chartered Accountant is mandatory post-license, and a breach of the net worth threshold triggers a stop-onboarding direction from RBI within 30 days.
The white-listing of merchants is the operational dimension of PA compliance that most entities underestimate. Every merchant onboarded by a PA must be screened against the Specially Designated Nationals list, the FATF non-cooperative jurisdiction list, and any RBI-issued no-go merchant list. Onboarding documentation requires GST registration, bank account verification, business activity classification under PA Merchant Category Code (MCC), and a video-KYC of the merchant's authorised signatory. The video-KYC requirement, in particular, is a significant operational lift for PAs onboarding at scale, and many applicants have under-built this capability.
The consequence framework for non-compliance after June 30, 2026 is unusually direct for an RBI rule set. Non-licensed payment aggregation activity from July 1 will be treated as unauthorised payment system operation under Section 4 of the Payment and Settlement Systems Act, 2007. Penalties include monetary fines up to ₹10 lakh per contravention, directions to cease operations, and freezing of merchant settlements. Banking partners that act as sponsor banks for non-licensed PAs are required by RBI's master circular to terminate such arrangements from July 1, meaning the operational channel itself disappears.
For applicants currently in the in-principle-approval stage who have not converted to final license by June 30, RBI has indicated that the in-principle approval will continue to provide operational cover for a further 90 days, but final license documentation must be completed by September 30, 2026 for that cover to remain valid.
KAMRIT's banking and payments compliance desk handles PA license application end-to-end including net worth structuring, merchant onboarding framework, video-KYC implementation review, and the RBI submission with follow-up coordination.
Co-Author - Ishita Chatterjee, Associate, Corporate Compliance
Frequently asked
Who must hold an RBI PA license by June 30, 2026?
Any non-bank entity facilitating online payment acceptance for merchants — including marketplace platforms with their own checkout, SaaS billing platforms collecting on behalf of customers, and travel/insurance aggregators with closed-loop payment flows. Banks acting as PAs are exempt (they are already regulated). Pure payment gateways without merchant settlement flow do not need PA license but need PG registration under the same framework.
What's the ₹15 crore net worth threshold for PA license?
Existing PAs (operating before March 17, 2020) need minimum ₹15 crore net worth at application and must maintain ₹25 crore by March 31, 2027. New PAs must have ₹25 crore from day one. Net worth must be in the form of paid-up equity capital and free reserves, not borrowed funds. Quarterly net worth certification by a registered Chartered Accountant is mandatory post-license.
What happens to non-licensed PAs after July 1, 2026?
RBI has stated that non-licensed payment aggregation activity after June 30, 2026 will be treated as unauthorised payment system operation under the Payment and Settlement Systems Act, 2007. Penalties include monetary fines, directions to cease operations, and freezing of merchant settlements. Banking partners (sponsoring banks) are required to terminate arrangements with non-licensed PAs from July 1.
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