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Finin2min
RBI · Payment Aggregators

PA-13: Audit, reporting and change control

Paragraph-level professional implementation page for Payment Aggregators.

Payment AggregatorsPA-13PSS Act, 2007; PMLA and IT overlays

Finin2min Summary — in 2 Minutes

PA-13 — Audit, reporting and change control. Submit statutory/system audit, cyber incident, escrow and regulator returns and pre-clear material changes.

Official source and legal ownership

Instrument ownerPSS Act, 2007; PMLA and IT overlays
Source statusCURRENT OFFICIAL SOURCE GATEWAY
Review date2026-07-19
Primary sourceMaster Direction on Regulation of Payment Aggregator, 15 September 2025

Paragraph-wise Finin2min interpretation

Legal trigger

Submit statutory/system audit, cyber incident, escrow and regulator returns and pre-clear material changes.

Control owner

Business identifies the event; Compliance confirms law; Operations/Technology executes; Independent review tests evidence.

Evidence

Official source snapshot, policy/SOP, system rule, customer/transaction record, maker-checker log, exception approval and regulatory acknowledgement.

Failure consequence

Customer harm, reporting defect, prudential misstatement, supervisory observation, monetary penalty, restriction or remediation.

Practical example

Scenario: An exception arises under Audit, reporting and change control. The owner records the trigger, regulated entity, paragraph/reference PA-13, affected customer or exposure, applicable threshold, approval and system evidence. Compliance then tests the result against the official source rather than relying on a generic policy statement.

Implementation and evidence controls

Practical Q&A

What is the first test for Audit, reporting and change control?

Confirm entity, product, event date, official paragraph and any stated exception.

Can a portal or system acceptance cure a legal defect?

No. Technical processing does not override the substantive Direction.

What should be retained for review?

The official source version, legal mapping, calculation or decision record, approvals, communications and filing evidence.

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