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RBI Relaxation Compliance Norms with Various Payment System Requirements

Keeping in view the resurgence of the COVID-19 pandemic and the representations received from the various bank and non-bank entities, it has been decided to extend the timeline of certain compliance Norms with respect to the Various Payment System Requirements.

The Reserve Bank of India (RBI) vide circular No. RBI/2021-22/41  — CO.DPSS.POLC.No.S-106/02-14-003/2021-2022 dated 22.05.2021, in the exercise of its power under Section 10(2) read with Section 18 of the Payment and Settlement Systems Act, 2007 (Act 51 of 2007), has issued circular w.r.t. Relaxation in the timeline for compliance with various payment system requirements to provide relief to taxpayers in view of the severe pandemic and spike in Covid-19 cases:

Annexure (Relaxations) to RBI Circular CO.DPSS.POLC.No.S-106/02-14-003/2021-2022 dated May 21, 2021

SN Instruction / Circular Present Timeline Revised Timeline
1. All existing non-bank PPI issuers (at the time of issuance of PPI-MD) to comply with the minimum positive net-worth requirement of Rs.15 crore for the financial position as of March 31, 2020 (audited balance sheet). Financial position as of March 31, 2021 Financial position as of September 30, 2021
2. Harmonization of TAT and customer compensation for failed transactions using authorized Payment Systems – “Calendar days” to be read as “Working days”. Working days until December 31, 2020 (Calendar days from January 1, 2021) Working days – Prospective – Until September 30, 2021
3. Authorized Payment System Operators (PSOs) are required to furnish System Audit Report conducted by CERT-IN impaneled auditors or a Certified Information Systems Auditor registered with Information Systems Audit and Control Association or by a holder of a Diploma in Information System Audit qualification of the Institute of Chartered Accountants of India, on an annual basis within two months of the close of their respective financial year. By May 31, 2021 By September 30, 2021
4. Existing non-bank entities offering PA services shall apply for authorization on or before June 30, 2021. By June 30, 2021 By September 30, 2021,*

* Extension provided vide circular CO.DPSS.POLC.No.S33/02-14-008/2020-2021 (click here) dated March 31, 2021, to enable payment system providers and participants to put in place workable solutions to comply with the provisions of Paragraphs 7.4 and 10.4 of the circular dated March 17, 2020 (Click Here) will not be impacted.

Recommended Read: Extension of Cheque Truncation System (CTS) across all bank branches

  • This Circular issued to the followings:
  • The Chairman / Managing Director / Chief Executive Officer
  • All Scheduled Commercial Banks, including 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 /
  • Authorized Payment System Operators / Participants

The RBI noted that the relaxations are being introduced in view of the present situation in the country. The nationwide lockdown in the wake of COVID-19 abruptly disrupted business operations across sectors. RBI’s decision to extend these timelines is a welcome step as it would afford some breathing space for payment system operators/participants to meet the various compliance requirements.


Every effort has been made to avoid errors or omissions in this material. In spite of this, errors may creep in. Any mistake, error or discrepancy noted may be brought to our notice which shall be taken care of in the next edition. In no event, the author shall be liable for any direct, indirect, special or incidental damage resulting from or arising out of or in connection with the use of this information.

CS Lalit Rajput TaxClue
CS Lalit Rajput
Company Secretary having 5 years of post-qualification experience in the Compliance Management Services industry by serving Corporates including Listed Companies, Corporate Secretarial Firms, and LLP.

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