Current · Source: Reserve Bank of India · RBI/2020-21/68 · issued 17 Nov 2020 · ~2 min read
Quick answerRBI now permits non-bank PPI issuers and payment aggregators to maintain an additional escrow account with a different scheduled commercial bank, easing earlier single-account rule to diversify risk and ensure business continuity.
The rule, in the simplest words
Non-bank PPI issuers and payment aggregators can now maintain two escrow accounts with different scheduled commercial banks.
They can transfer funds between these accounts with auditor certification, but this is discouraged.
Prior RBI approval is no longer required to shift accounts, only prior intimation is needed.
How it plays out — a real example
Rohan reviews Paytm's existing escrow account agreement and updates it to include clauses allowing only permitted debits/credits and inter-escrow transfers with auditor certification. He then trains Paytm's relationship managers to handle requests for additional escrow accounts and ensures compliance monitoring for inter-escrow transfers. A branch operations officer in Indore, Rohan, helps a payment aggregator, Paytm, open a second escrow account with a different bank to reduce risk and ensure business continuity.
What changed
Previously, non-bank PPI issuers and payment aggregators could only maintain one escrow account with a single scheduled commercial bank. Now, they may open one additional escrow account with a different bank, and inter-escrow transfers are allowed (though discouraged) with auditor certification. The requirement for prior RBI approval to shift accounts has been relaxed to prior intimation.
What it means for you
Banks can now compete for and service multiple escrow accounts from the same PPI issuer or PA, potentially increasing fee income and deposit balances. However, banks must ensure escrow agreements restrict fund usage to permitted purposes only, and inter-escrow transfers require clear audit trails. This change reduces concentration risk for payment entities, but banks need to update their internal controls and agreements accordingly.
What you must do
Update escrow account agreements to include clauses allowing only permitted debits/credits and inter-escrow transfers with auditor certification.
Train relationship managers to handle requests for additional escrow accounts from existing PPI/PA clients.
Ensure compliance monitoring for inter-escrow transfers and report any unusual patterns to RBI as per guidelines.
Review internal systems to track multiple escrow accounts per entity and flag any non-compliance with fund usage restrictions.
Who it affects
Scheduled commercial banks offering escrow services, Non-bank PPI issuers, Payment aggregators, Payment system providers and participants
❓ Common questions
Can a PPI issuer now have escrow accounts in two different banks simultaneously?
Yes, RBI allows one additional escrow account in a different scheduled commercial bank, so a PPI issuer can maintain up to two escrow accounts at the same time.
Are inter-escrow transfers between the two accounts allowed?
Yes, but they should be avoided as far as possible. If done, the auditor's certification must clearly mention such transactions.
Do banks need to get RBI approval before a client shifts its escrow account?
No, prior RBI approval is no longer required; only prior intimation to RBI is needed for migration.
📜 Read the original circular — full text as issued by RBI
RBI/2020-21/68
DPSS.CO.PD.No.660/02.14.008/2020-21
November 17, 2020
All Scheduled Commercial Banks / Authorised Prepaid Payment Instrument Issuers /
Payment Aggregators / Payment System Providers / System Participants
Madam / Dear Sir,
Maintenance of Escrow Account with a Scheduled Commercial Bank
A reference is invited to the instructions issued by Reserve Bank of India vide (a) DPSS.CO.PD.No.1164/02.14.006/2017-18 dated October 11, 2017 (updated as on February 28, 2020) on ‘Issuance and Operation of Prepaid Payment Instruments (PPIs)’; and (b) DPSS.CO.PD.No.1810/02.14.008/2019-20 dated March 17, 2020 on ‘Regulation of Payment Aggregators (PAs) and Payment Gateways (PGs)’.
2. An authorised PPI Issuer or a PA is required to maintain an escrow account with a scheduled commercial bank on an ongoing basis. With a view to diversify risk and address business continuity concerns, it has been decided to allow one additional escrow account in a different scheduled commercial bank. The relevant instructions are being modified as per Annex 1 and 2 to this circular.
3. These directions are issued under Section 18 read with Section 10(2) of the Payment and Settlement Systems Act, 2007.
Yours faithfully,
(P. Vasudevan)
Chief General Manager
Annex 1
Modifications to Master Direction on Issuance and Operation of PPIs (PPI-MD)
DPSS.CO.PD.No.1164/02.14.006/2017-18 dated October 11, 2017
(updated as on February 28, 2020)
Para No.
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2020-21/68 · issued 17 Nov 2020. The plain-English explanation above is BankPulse’s own independent summary.
Review internal systems to track multiple escrow accounts per entity and flag any non-compliance with fund usage restrictions.
📜 Compliance
Update escrow account agreements to include clauses allowing only permitted debits/credits and inter-escrow transfers with auditor certification.
Train relationship managers to handle requests for additional escrow accounts from existing PPI/PA clients.
Ensure compliance monitoring for inter-escrow transfers and report any unusual patterns to RBI as per guidelines.
Grouped from the action items above — a single circular may involve more than one team.
Worked example & action-note template
Example: if you are a Compliance officer at a bank this circular applies to (Scheduled commercial banks offering escrow services, Non-bank PPI issuers, Payment aggregators, Payment system providers and participants), your first concrete step on “RBI Allows Second Escrow Account for PPIs and PAs” is: “Update escrow account agreements to include clauses allowing only permitted debits/credits and inter-escrow transfers with auditor certification.” (RBI issued this 17 Nov 2020).
Circular: RBI/2020-21/68 -- RBI Allows Second Escrow Account for PPIs and PAs
Issued: 17 Nov 2020
Action required: Update escrow account agreements to include clauses allowing only permitted debits/credits and inter-escrow transfers with auditor certification.
Action required: Train relationship managers to handle requests for additional escrow accounts from existing PPI/PA clients.
Action required: Ensure compliance monitoring for inter-escrow transfers and report any unusual patterns to RBI as per guidelines.
Action required: Review internal systems to track multiple escrow accounts per entity and flag any non-compliance with fund usage restrictions.
Owner: ____________ Target date: ____________
Board/committee approval needed? Y / N
Evidence filed in compliance register on: ____________
Built only from this circular’s own published fields — not legal advice; always confirm against the official RBI source.
💬 Banker Discussion
Discuss this circular with fellow bankers — reply, upvote what helps, report what doesn’t belong. Be professional; no client data. Views are the commenter’s own, not BankPulse’s.
BankPulse Compliance Evidence Pack — generated 03 Aug 2026 · status cross-checked against RBI’s official withdrawal register (refreshed weekly). Official RBI source: https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=11996&Mode=0 — Plain-English summary by BankPulse (bankpulse.ai), reviewed by our expert reviewer, CA Amit Jain. Independent platform, not affiliated with the Reserve Bank of India; is our own plain-English paraphrase, not RBI’s original wording.
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