RBI Extends Payment System Compliance Deadlines Amid COVID-19
Current · Source: Reserve Bank of India · RBI/2021-22/41 · issued 21 May 2021 · ~2 min read
Quick answerRBI has extended deadlines for payment system compliance due to COVID-19 resurgence. Key changes: non-bank PPI issuers now have until Sept 30, 2021 to meet net-worth requirements; TAT compensation rules use 'working days' until same date; system audit reports and PA authorization deadlines also pushed to Sept 30, 2021.
The rule, in the simplest words
Non-bank PPI (prepaid payment instrument like a gift card) companies must have at least Rs 15 crore net worth (money left after subtracting debts) by September 30, 2021, based on their financial report for that date.
For failed payments, banks must follow 'working days' (Monday to Friday, not counting holidays) to calculate how fast they must fix the problem and pay compensation, until September 30, 2021.
Payment system operators (companies that run payment networks) must get a system audit (checking their computer systems) done by a CERT-IN approved auditor and send the report to RBI by September 30, 2021.
Non-bank payment aggregators (companies that help merchants accept payments) must apply to RBI for official permission by September 30, 2021.
How it plays out — a real example
A branch operations officer in Indore, Priya, processes a customer's failed UPI transaction. She checks the new rule: she must use 'working days' (not counting Sundays or holidays) to calculate the turnaround time and compensation until September 30, 2021. This gives her bank extra time to fix the issue without rushing during the COVID-19 surge.
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
❓ Common questions
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.
📜 Read the original circular — full text as issued by RBI
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2021-22/41 · issued 21 May 2021. The plain-English explanation above is BankPulse’s own independent summary.
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.
📜 Compliance
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.
Monitor RBI circulars for any further updates on these timelines.
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 (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), your first concrete step on “RBI Extends Payment System Compliance Deadlines Amid COVID-19” is: “Non-bank PPI issuers: Ensure audited financials as of September 30, 2021 show minimum net worth of Rs 15 crore.” (RBI issued this 21 May 2021).
Action required: Non-bank PPI issuers: Ensure audited financials as of September 30, 2021 show minimum net worth of Rs 15 crore.
Action required: Review TAT and customer compensation processes: Continue using 'working days' for failed transactions until September 30, 2021.
Action required: Authorised PSOs: Schedule system audit by CERT-IN empanelled auditors or equivalent and submit report by September 30, 2021.
Action required: Existing non-bank PAs: Complete authorisation application to RBI by September 30, 2021.
Action required: Monitor RBI circulars for any further updates on these timelines.
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=12095&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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