What changed
RBI extended timelines for four payment system requirements: non-bank PPI issuers must meet the Rs 15 crore net-worth condition based on financial position as of September 30, 2021 instead of March 31, 2021; the harmonisation of TAT and customer compensation for failed transactions will continue to use 'working days' until September 30, 2021 instead of switching to 'calendar days'; authorised Payment System Operators now have until September 30, 2021 to submit their annual System Audit Report instead of May 31, 2021; existing non-bank payment aggregators have until September 30, 2021 to apply for authorisation instead of June 30, 2021.
What it means for you
Banks and payment entities get breathing room to comply with critical payment system rules during the pandemic surge. The extension reduces immediate compliance pressure, especially for non-bank PPI issuers needing to shore up net worth and for PAs finalising authorisation applications. However, the deadlines are now fixed at September 30, 2021, so entities must use this window to complete all requirements without further delay.
What you must do
- Non-bank PPI issuers: Ensure audited financials as of September 30, 2021 show minimum net worth of Rs 15 crore.
- Review TAT and customer compensation processes: Continue using 'working days' for failed transactions until September 30, 2021.
- Authorised PSOs: Schedule system audit by CERT-IN empanelled auditors or equivalent and submit report by September 30, 2021.
- Existing non-bank PAs: Complete authorisation application to RBI by September 30, 2021.
- Monitor RBI circulars for any further updates on these timelines.
Who it affects
All Scheduled Commercial Banks, Regional Rural Banks, Urban Co-operative Banks, State Co-operative Banks, District Central Co-operative Banks, Payments Banks, Small Finance Banks, Local Area Banks, Non-Bank PPI Issuers, Authorised Payment System Operators, Payment Aggregators and Payment Gateways
What is the new deadline for non-bank PPI issuers to meet the Rs 15 crore net-worth requirement?
The deadline is now based on the financial position as of September 30, 2021, instead of March 31, 2021. This means the audited balance sheet for the period ending September 30, 2021 must show at least Rs 15 crore net worth.
Does the extension affect the requirement for payment aggregators to put in place workable solutions for paragraphs 7.4 and 10.4 of the March 17, 2020 circular?
No, the extension specifically states that the timeline for putting in place workable solutions for those paragraphs is not impacted. Only the authorisation application deadline for existing non-bank PAs has been extended to September 30, 2021.