By Reeju Datta, Co-founder, Cashfree
The guidelines provide welcome recognition to payment gateways (PGs) and payment aggregators (PAs) through a clear definition. The RBI has chosen the direct regulation route for PAs, requiring both authorisation and compliance with baselines tech recommendations. PGs will only need to optionally comply with the latter. The effect is that an entity can now choose whether to act as a money handler or a tech provider or both.
The guidelines remove the physical presence requirement for merchants proposed under the Discussion Paper, specifically allowing both import and export-related transactions. For such transactions, it would be assumed that online payment gateway service providers (OPGSP) guidelines would need to be adhered to, however, this needs to be clarified. The OPGSP norms could also need a relook since they don’t allow import payments for services.
It is a relief for the digital payments industry that the net worth requirements have been lowered, the Discussion Paper had proposed INR 100cr and that is now INR 15 – 25cr.
The most significant change is the move from nodal accounts (under the intermediary norms) to escrow accounts for non-bank PAs; escrow accounts give a lot more flexibility to operate. The one issue here is that a non-bank PA can have accounts with only 1 Scheduled Commercial Bank at a given point of time, which as demonstrated by the recent Yes Bank incident, may create issues with the payments cycle.