PA authorisation: bank, non-bank and category transitions

Check both the entity and the PA category; online, physical and cross-border aggregation have defined perimeters.

Published by Finin2min · Updated 24 October 2026

How this provision works

A bank does not require PA authorisation under paragraph 5(a). A non-bank PA must be an Indian Companies Act 2013 company with the proposed activity in its objects and must apply through RBI’s portal.
An applicant regulated by another financial-sector regulator applies with its NOC within 45 days of that NOC. Do not substitute the PPI framework’s 30-day NOC period.
An already authorised PA commencing another PA category must intimate RBI at least 30 days before the new business under paragraph 5(d). Existing physical-only operators had a December 31, 2025 application deadline and, on failure, a February 28, 2026 wind-up date; those are past dates at this review.
A pure PG without fund handling is outside this MD; its adoption of the PA baseline technology recommendations is encouraged. A brand, marketplace contract or application pending with RBI is not proof that authorisation has already been granted.
The common June 2026 authorisation direction adds its covered portal, net-worth certification, fit-and-proper and continuing-validity requirements. Retained permissions and narrowly saved pending PA-O/PA-CB arrangements must be read under the actual 2025 repeal/saving clauses.

Practical illustration

A physical-only aggregator that missed the December 2025 application date cannot cite that expired transition as permission to start new unlicensed operations in October 2026.

The example is illustrative; it is not a reported company or court case.

Questions answered

Is a PA application equivalent to a granted certificate?

No. The application status and any specific transitional permission must be distinguished from final authorisation.

Is the other-regulator NOC filing period 30 days for a PA?

The PA direction states 45 days; the PPI route has a different period.

Primary source and edition

RBI PA Directions of 15 September 2025, read with the stated current common and payment-system instruments. PA paragraphs 3–5,10(g),19–23; PSO Authorisation MD 2026 paragraphs 3–6.

Open the official instrument at this provision

Legal effect follows the instrument’s commencement and amendment provisions; a website upload date does not by itself change the law.

Related primary authorities

Payment-system Authorisation Directions, 15 June 2026

Scope and source editions

Reviewed against the named official editions on 24 October 2026. Product, regulated entity, transaction type and the instrument’s commencement or saving provisions determine applicability. Examples are illustrations rather than reported company cases.