IN PURSUIT OF A LEVEL PLAYING FIELD – RBI’S NEW DRAFT GUIDELINES FOR PAYMENT AGGREGATORS

The Reserve Bank of India (“RBI”) issued draft circulars on regulation of payment aggregators – physical point of sale and draft amendments for the PA-PG Guidelines. These draft circulars mark a significant shift in the payment aggregation regime with the proposal of offline payment aggregation being brought into the realm of regulation and significant changes sought to be made to the current applicable framework including the permissible manner of settlement of funds to merchants and involvement of marketplaces in the aggregation and settlement process. INDUSLAW's Namita Viswanath, Shreya Suri, Raghav Muthanna, Sana Khan and Aditya G provide a nuanced analysis of the draft circulars and point out potential issues and regulatory ambiguities posed by the said circulars.