OPGSP vs PA-CB Guidelines: Key Differences Explained
TL;DR - Summary
- What is OPGSP (Online Payment Gateway Service Provider)? - OPGSP stands for Online Payment Gateway Service Provider, the regulatory category under which companies facilitated cross-border online payments before the PA-CB framework existed, with an AD-I bank holding the regulatory accountability instead of the payment company holding its own RBI licence.
- What is PA-CB (Payment Aggregator–Cross Border)? - PA-CB stands for Payment Aggregator–Cross Border, the category RBI created in October 2023 for non-bank entities that facilitate cross-border online payments for import or export of goods and services, and a PA-CB must obtain direct authorisation from RBI to operate.
- What are the key differences between OPGSP and PA-CB? - An OPGSP operated through an AD-I bank tie-up with the bank accountable, while a PA-CB needs direct RBI authorisation, carries the regulatory accountability itself, and faces net worth, escrow and KYC obligations that did not exist under the OPGSP arrangement.
- What does the shift from OPGSP to PA-CB mean for Indian businesses today? - If you receive international payments today, PA-CB is the only compliant framework, so the question for your business is whether the platform you use has obtained PA-CB authorisation.
What Is OPGSP?
OPGSP stands for Online Payment Gateway Service Provider, the regulatory category under which companies facilitated cross-border online payments before the PA-CB framework existed. An OPGSP did not need its own RBI licence. It only needed a tie-up with an Authorised Dealer Category-I (AD-I) bank, and that bank held the regulatory accountability.
Indian businesses such as exporters, e-commerce sellers and SaaS companies used OPGSPs to receive payments from foreign buyers online. The AD-I bank acted as the regulated intermediary behind the scenes.
Take a Bengaluru software exporter receiving $3,000 from a US client in 2020. That payment would have come through a platform operating as an OPGSP and backed by an AD-I bank, rather than through a directly RBI-authorised aggregator.
⚠️ COMMON MISCONCEPTION
OPGSP was not an RBI licence. It was an operational arrangement permitted under an RBI circular, with the bank holding the actual regulatory responsibility.
What Is PA-CB?
PA-CB stands for Payment Aggregator–Cross Border, the regulatory category RBI created in October 2023 for non-bank entities that facilitate cross-border online payments for import or export of goods and services. Unlike an OPGSP, a PA-CB must obtain direct authorisation from RBI to operate. It cannot rely on a bank tie-up, because the regulatory responsibility now sits on the aggregator itself, not the bank.
RBI introduced PA-CB because cross-border payment volumes had grown significantly and the bank-intermediated OPGSP model left payment companies outside direct regulatory oversight. The PA-CB framework brought them under RBI's direct supervision.
PA-CBs are classified into three types based on the direction of payment: export-only, import-only, or both. Each type must maintain separate collection accounts for the respective flow.
The October 2023 RBI circular introducing PA-CB was later consolidated into the September 2025 Master Directions for Payment Aggregators. These unified PA-Online, PA-Physical and PA-Cross Border into a single framework, which makes the September 2025 Master Directions the current operative reference.
Three requirements set PA-CB apart from the OPGSP arrangement:
- Net worth: PA-CBs need a net worth of ₹15 crore at entry, rising to ₹25 crore by March 2026. No equivalent net worth requirement existed under the OPGSP arrangement.
- Import transaction cap: The cap for imports is ₹25 lakh per unit of goods or services, a significant increase from the old OPGSP import cap of $2,000.
- Import scope: Import coverage now extends to services, not just goods. The OPGSP framework was more limited in what import transactions it permitted.
OPGSP vs PA-CB: Key Differences
The biggest difference between OPGSP and PA-CB is who answers to RBI. An OPGSP operated through an AD-I bank tie-up without RBI authorisation, and the bank held the accountability. A PA-CB must hold direct RBI authorisation and carries that accountability itself. The two also differ on import transaction scope and cap, net worth, collection and escrow structure, KYC and merchant onboarding, and FIRC and reporting.
| Factor | OPGSP | PA-CB |
|---|---|---|
| Full form | Online Payment Gateway Service Provider | Payment Aggregator–Cross Border |
| Governing framework | 2015 RBI OPGSP framework | October 2023 RBI circular; consolidated in September 2025 Master Directions |
| RBI authorisation required | No. Operated via AD-I bank tie-up | Yes. Direct RBI authorisation mandatory |
| Who holds regulatory accountability | The AD-I bank, not the payment platform | The PA-CB entity directly |
| Transaction types covered (import) | Goods (limited scope); import cap of $2,000 per transaction | Goods and services; cap of ₹25 lakh per unit |
| Net worth requirement | None | ₹15 crore at entry; ₹25 crore by March 2026 |
| Collection/escrow structure | As prescribed under OPGSP rules via AD bank | Separate collection accounts for export and import; PA-CB-specific escrow obligations |
| KYC / merchant onboarding | Requirements channelled through AD bank | Structured KYC, AML, and merchant due diligence obligations on the PA-CB directly |
| FIRC / reporting | Through AD bank channels | PA-CB directly responsible for reporting; FIRC issuance tied to PA-CB compliance |
Skydo is a PA-CB authorised platform. Indian exporters and freelancers can start receiving compliant international payments in 10 to 15 minutes. Every transaction comes with a free FIRC certificate and predictable flat-fee pricing, with no hidden charges and no chasing banks.
⚠️ COMMON MISCONCEPTION
Many assume PA-CB is just a renamed OPGSP. It is not. PA-CB introduced mandatory RBI authorisation, escrow account obligations, and KYC requirements that did not exist under the OPGSP circular, making it a structurally different compliance regime.
Why Did RBI Introduce PA-CB Regulations?
RBI introduced the PA-CB framework because cross-border online commerce and digital payment volumes had grown substantially, while the companies actually handling these payments, the OPGSPs, sat outside direct RBI oversight. Accountability rested on AD banks instead. By creating the PA-CB category, RBI closed that oversight gap.
The OPGSP model created a structural gap. Payment platforms processed significant cross-border transaction volumes without being directly regulated, supervised, or held to net worth, escrow or KYC standards by RBI.
The PA-CB category brought payment aggregators facilitating cross-border transactions under the same direct regulatory perimeter RBI had already established for domestic payment aggregators.
The framework also extended import coverage to services, not just goods, and raised transaction limits. That reflects the growth of India's services exports and digital commerce since the original OPGSP rules were written.
The September 2025 Master Directions unified PA-Online, PA-Physical and PA-Cross Border. This signals that RBI now treats all payment aggregation activity as a single, coherent regulatory category rather than a patchwork of separate circulars.
What Changed for Businesses Using OPGSPs?
The OPGSP era is over. Any platform that previously operated under an OPGSP arrangement had to either obtain direct RBI PA-CB authorisation or stop facilitating cross-border payments. For you as an exporter or freelancer, the changes show up in FIRC validity, merchant onboarding documentation, transaction monitoring, settlement flows and platform stability. Businesses that did not check which path their platform took may have continued transacting through a non-authorised intermediary.
- FIRC validity: FIRCs (Foreign Inward Remittance Certificates) are now issued within the PA-CB compliance framework. If your platform is not PA-CB authorised, the FIRC it provides may not be recognised under FEMA.
- Merchant onboarding: PA-CBs must conduct KYC and due diligence on the businesses they onboard. Exporters and SaaS companies may be asked for documentation they were not previously required to submit under the lighter OPGSP-era arrangements.
- Transaction monitoring: Monitoring obligations now sit directly with the PA-CB, not just the AD bank. Your platform is accountable for AML checks and reporting, which affects how settlements are processed and how long they take if a transaction is flagged.
- Settlement flows: For e-commerce businesses and marketplaces, the separation of export and import collection accounts under PA-CB means settlement flows may have changed compared to the earlier OPGSP arrangement.
- Platform stability: The net worth and escrow obligations on PA-CBs affect platform stability and reliability. A PA-CB-authorised platform has met RBI's financial soundness thresholds, which was not a requirement under OPGSP.
⚠️ WATCH OUT
Not all platforms that claim to help you receive foreign payments are PA-CB authorised. Operating through an unauthorised aggregator can result in your foreign inward remittance not being recognised under FEMA, which creates issues during GST refund claims and income tax filings.
OPGSP vs PA-CB: Which One Applies to Your Payment?
OPGSP no longer applies to any new payment, because the October 2023 RBI circular effectively ended the framework. If you are receiving international payments today, the only compliant framework is PA-CB.
If you received payments before October 2023 through a platform operating as an OPGSP, those transactions were valid under the rules at the time. The PA-CB framework is not retroactive.
From October 2023 onwards, any non-bank entity aggregating cross-border payments in India is required to be PA-CB authorised. So the question for a business owner is whether the platform they use has obtained that authorisation.
These use cases all fall squarely under the PA-CB-Export category, and the platform handling the payment must hold that authorisation:
- Indian freelancers invoicing foreign clients
- SaaS founders receiving subscription revenue from abroad
- Exporters of goods or services
A practical check is to ask your payment platform to confirm its PA-CB authorisation status with RBI. A platform that cannot confirm this should be treated as a compliance risk for your foreign remittances, FIRC issuance and FEMA reporting.
How Skydo Helps You Receive International Payments Under PA-CB Rules
Once you know that your payment platform needs PA-CB authorisation, and that your FIRC is what you need for GST refund claims, income tax filings and FEMA compliance, the next problem is finding a platform that covers all of it. Skydo is a PA-CB authorised platform, which means every payment you receive through Skydo is processed within RBI's current compliance framework. Your FIRC, FEMA reporting and remittance recognition are covered from day one.
- Quick setup: Setup takes 10 to 15 minutes, with no relationship manager calls, no SWIFT copy chasing and no manual paperwork to start receiving foreign payments compliantly.
- Flat, transparent pricing: Under $2,000 costs $19 flat, $2,000 to $10,000 costs $29 flat, and over $10,000 costs 0.3%. There is no hidden forex markup, and no percentage fees on smaller transfers eating into your earnings.
- Free FIRC on every transaction: Every transaction comes with a free FIRC certificate automatically, with no separate request, no fee and no delay.
- Free virtual accounts: You get free virtual accounts in USD, EUR, GBP, SGD, AUD and CAD, so you can give foreign clients a local bank account to pay into. That reduces friction and eliminates SWIFT delays.
- eBRC closure: If you need eBRC closure, you link your DGFT account once, then bulk-upload shipping bills to auto-map IRMs and generate eBRC in a click. That removes the manual follow-up traditional banking requires.
- Predictable settlement: Settlement happens within 1 working day, so you are not left guessing when funds will hit your account.
- India-based support: Support is India-based and multi-modal (WhatsApp, call, text), with no global queue and no ticket black hole.
Is OPGSP still valid for receiving international payments in India?
No. The OPGSP framework was effectively ended by the October 2023 RBI circular. Any platform aggregating cross-border payments in India today must hold direct RBI PA-CB authorisation to operate compliantly.
What is a PA-CB licence and who needs it?
How do I know if the payment platform I use is PA-CB authorised?
What is the net worth requirement for a PA-CB?
What is the transaction limit under the PA-CB framework?
Does PA-CB cover both imports and exports?
What happens to my FIRC if I use a non-PA-CB-authorised platform?
What is the current RBI regulation governing PA-CBs?
