PA-CB Guidelines by RBI: The OPGSP-to-PA-CB Rules Explained

If you receive money from overseas clients through a fintech or payment gateway, the rules behind that flow changed in a way that affects you. In October 2023 the Reserve Bank of India brought every cross-border payment facilitator under one framework: PA-CB.

The old OPGSP arrangement is gone. In its place sits a licensed category with net-worth floors, transaction caps and RBI authorisation. For an exporter, the practical question is simple: is the platform holding your money actually allowed to?

This guide explains what the PA-CB guidelines say, what the numbers are, and what they mean for you when you choose a provider for cross-border payments for service exporters.

• PA-CB stands for Payment Aggregator - Cross Border, the RBI category that now regulates any non-bank facilitating cross-border payments for import or export.
• The rules come from the RBI circular dated 31 October 2023, which withdrew the older OPGSP framework.
• Non-banks needed to apply to the RBI for authorisation by 30 April 2024 to keep operating.
• Minimum net worth is ₹15 crore at application, rising to ₹25 crore by 31 March 2026.
• There is a ₹25 lakh per-unit transaction cap, and enhanced due diligence above ₹2.5 lakh.

PA-CB is short for Payment Aggregator - Cross Border. It is the RBI's regulatory label for any entity that collects or disburses money across India's borders on behalf of buyers and sellers, for the import or export of goods and services.

In plain terms, if a platform sits between your overseas client and your Indian bank account, moving the funds and handling the paperwork, it is acting as a PA-CB. These sit alongside domestic payment aggregators, but with an added cross-border layer of rules.

Banks that already offer this service do not need a separate PA-CB authorisation, since they are regulated as banks. The framework targets non-bank fintechs, which is most of the modern cross-border payment market.

Before 2023, cross-border collections ran under the Online Payment Gateway Service Provider (OPGSP) route, a 2015-era arrangement operated through banks rather than under direct RBI authorisation. As volumes grew, the RBI wanted direct oversight.

The online payment gateway service provider opgsp model was therefore withdrawn. No new OPGSPs are permitted, and existing ones had to either migrate to the PA-CB framework or wind down their collection accounts.

The shift is about accountability. Under OPGSP the bank carried the relationship; under PA-CB the facilitator itself answers to the RBI, with capital, reporting and payment compliance obligations of its own.

The change did not happen overnight. The RBI set a sequence of dates that providers had to meet, and the gaps between them are why some platforms paused onboarding during 2024.

The practical effect on exporters was real. Providers that could not meet the net-worth floor or the application deadline had to stop collecting, so some businesses found their payment route disrupted mid-year and had to move to an authorised platform.

The lesson for choosing a provider today is to look past the marketing and confirm the authorisation is final, not pending, because a provider still "awaiting" approval is one that can be told to stop.

The RBI does not treat all cross-border flows the same. A provider is authorised for one of three activity types, and must keep the relevant collection accounts separate.

Holding the export-and-import authorisation is the harder standard, because it means the provider is trusted with money moving in both directions. Only a handful of players hold both. The distinction also matters when you compare a licensed aggregator with a merchant of record model, covered in MoR vs PA CB.

The framework sets hard financial and transactional limits. These are the numbers that decide whether a provider can legally operate, and how large a single payment can be.

The net-worth floor is the real gatekeeper. It filters out under-capitalised operators, which is exactly the protection an exporter wants from the platform holding their receipts. Robust AML compliance and screening are folded into the same obligations.

Getting authorised is not a form-filling exercise. A non-bank applies to the RBI for authorisation as a Payment System Operator under the Payment and Settlement Systems Act, 2007.

The broad sequence runs like this:

• Meet the net-worth floor: demonstrate ₹15 crore net worth at the time of application.
• Apply to the RBI: existing providers had to file by 30 April 2024 to continue operating.
• Receive in-principle approval: typically valid for a defined window while the entity readies systems.
• Meet post-authorisation conditions: complete compliance and technology requirements within the RBI's timeline.
• Operate under ongoing supervision: maintain net worth, reporting and the required collection accounts.

Falling short at any stage means no authorisation, and no authorisation means the provider cannot legally collect your cross-border payments. That is why the choose the right cross border payment solution for your business question belongs at the top of any provider check.

PA-CBs route funds through ring-fenced accounts held with authorised dealer (AD) banks, not through the provider's own balance sheet. In practice you are assigned a virtual bank account number that collects the inflow before settlement.

• Export Collection Account (ECA): receives your overseas client's payment before it is settled to your Indian bank account.
• Import Collection Account (ICA): holds a buyer's funds before they reach an overseas seller.

Keeping these accounts separate, and separate from the provider's own money, is a core safeguard. It also keeps your export documentation intact, so your RBI purpose code for inward remittance and reconciliation continue to work as before. The same logic connects to the wider EDPMS vs IDPMS monitoring the RBI runs on exports and imports.

For most exporters the framework is good news, once you know what to check. It turns "trust me" into "authorised by the RBI".

Three practical takeaways:

• Confirm authorisation, not intent: ask whether a provider holds final PA-CB authorisation, and for which category, before you route money through it.
• Match the category to your flow: if you both receive and pay overseas, you want a provider with export-and-import cover, not export-only.
• Check the paperwork continues: a compliant PA-CB still issues your FIRC or FIRA; see FIRC vs FIRA for which document does what.

The ₹25 lakh per-unit cap is worth understanding in practice. It applies per transaction unit, so a single invoice above that value may need to be structured or handled differently, and a provider used to larger service-export tickets will guide you rather than let a payment bounce. Anything above ₹2.5 lakh also triggers extra due diligence, which is normal, not a red flag.

The framework does not change your own obligations, your GST and income-tax filing under cross border tax compliance stay the same. It changes who is allowed to move the money for you. A provider built for IT-enabled services exporters will already hold the right authorisation for your flow.

When shortlisting, weigh authorisation alongside rate and speed, the way the better cross border payments companies are compared.

The whole point of the framework is to make "is this provider allowed to hold my money" a question you can answer with a yes.

Xflow holds final RBI PA-CB authorisation for both exports and imports (as of February 2026), one of the few non-banks with cover for both directions. Details are set out in Xflow holds PACB license explainer.

That authorisation sits on top of independent security certification. Xflow is ISO 27001 and SOC 2 certified, covered in the Xflow achieves SOC 2 and ISO compliance certification note, and works with AD-1 banks for FX and reconciliation.

In practice, your export proceeds land in a receiving accounts setup, settle to your Indian bank on the next business day (T+1), and arrive with the FIRA and purpose-code documentation already handled. You can see exactly what a collection costs on the pricing page rather than guessing.

The result for B2B cross border payments is that the compliance becomes the platform's job, framed as relief rather than another thing on your checklist.