RBI PA & PG

RBI PA and PG Audit

  • Identify gaps: Map findings to RBI PA requirements.
  • Prioritize risks: Focus on high impact issues.
  • Improve readiness: Build evidence for RBI submission.

Who Requires an RBI PA and PG Audit?

Audit obligations depend on whether you operate as a payment aggregator or only as a payment gateway.

Online Payment Aggregators (PA-O)

Online Payment Aggregators (PA-O)

Physical Payment Aggregators (PA-P)

Physical Payment Aggregators (PA-P)

Cross-Border Payment Aggregators (PA-CB)

Cross-Border Payment Aggregators (PA-CB)

Applicants for PA Authorisation

Applicants for PA Authorisation

Payment Gateways Adopting RBI Baselines

Payment Gateways Adopting RBI Baselines

E-Commerce Firms with PA Businesses

E-Commerce Firms with PA Businesses

Our RBI PA and PG Audit Approach

A structured, regulation-mapped audit covering systems, security controls and cyber resilience.

Business Understanding

Business Understanding

Review payment operations, transaction flows, entity type, and regulatory context.

Regulatory Mapping

Regulatory Mapping

Map applicable RBI directions, circulars, and control requirements.

Scope Finalization

Scope Finalization

Confirm in-scope systems, applications, integrations, and third parties.

Infrastructure & Security

Infrastructure & Security

Assess networks, endpoints, cloud environments, and supporting controls.

Application & Transaction Security

Application & Transaction Security

Review APIs, transaction flows, encryption, fraud controls, and integrations.

Access Governance

Access Governance

Assess IAM, privileged access, authentication, and third-party access.

Monitoring & Incident Readiness

Monitoring & Incident Readiness

Review logging, SOC visibility, incident response, and reporting readiness.

Reporting & Remediation

Reporting & Remediation

Deliver prioritized findings and regulation-mapped remediation roadmap.

Deliverables You Can Expect

Regulation-specific outputs for your compliance team and RBI submission.

System & Cyber Security Audit Report

System & Cyber Security Audit Report

Annual audit report against applicable RBI PA requirements

Regulatory Gap Assessment

Regulatory Gap Assessment

Gaps mapped to the PA Directions and cyber resilience directions

Executive Compliance Summary

Executive Compliance Summary

Board-level view of compliance posture and priorities

Benefits of RBI PA and PG Audits

Timely RBI Submission

Annual audit completed with clear, organized evidence

Enhanced Payment Security

Transaction and fraud control weaknesses prioritized

Reduced Regulatory Risk

Gaps identified before RBI reviews them

Stronger Governance

Board-ready reporting mapped to RBI requirements

Authorisation Readiness

Clear view of controls for applicants

Merchant & Bank Trust

Independent evidence for partners and acquirers

Why Payment Aggregators Choose QRC

RBI-focused expertise. Payment security depth. Actionable, audit-ready outcomes.

RBI PA Regulatory Expertise

Audits aligned to the PA Directions 2025 and RBI's cyber resilience directions for non-bank PSOs.

Governance + Technical Depth

Combined review of governance, security controls, infrastructure and operational practices.

CERT-In Empanelled Auditor

QRC Assurance and Solutions is listed by CERT-In as an empanelled information security auditing organization.

Integrated Compliance Capability

Experience across RBI PSS, PCI DSS, data localization and ISO 27001.

Supporting Services

Services that complement your PA audit across application testing, data storage and payment compliance.

API Security

Tests payment APIs and merchant integrations for security flaws.

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Web Application Security (WAPT)

Tests checkout and merchant portals for exploitable weaknesses.

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Mobile Application Security

Tests payment and merchant mobile apps for security weaknesses.

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RBI Data Localization Audit (SAR)

System Audit Report on storage of payment data in India.

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PCI DSS Compliance

Card data security assessment for aggregators handling card payments.

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24×7 Managed SOC Services

Continuous monitoring to support detection and incident reporting.

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Case Studies

Real-World RBI PA Audit Outcomes

How payment aggregators have used QRC audits to meet RBI's annual audit expectations.

PCI Case Studies

RBI PA and PG Resource Center

Practical resources to help payment aggregators and gateways understand RBI requirements.

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Frequently Asked Questions

RBI's Payment Aggregator Directions, issued in September 2025, consolidate the earlier PA and PG guidelines. Non-bank PAs must also follow RBI's Master Directions on Cyber Resilience and Digital Payment Security Controls for non-bank payment system operators.

Yes. The PA Directions require an annual system audit, including a cyber security audit, by a CERT-In empanelled auditor, with the report submitted to RBI within the timelines it prescribes.

Payment gateways that only provide technology, without handling funds, fall outside the PA Directions. RBI encourages them to adopt its baseline technology recommendations, which QRC can review.

They are the online, physical (point of sale) and cross-border categories of payment aggregators under the PA Directions. Your category shapes the audit scope.

QRC is a CERT-In empanelled auditor, which the PA Directions require for the annual system and cyber security audit.

Timing depends on the entities, systems and locations in scope and how readily evidence is available. QRC confirms a realistic timeline after the scoping call.

Ready to Complete Your RBI PA Audit?

Define your scope, identify priority gaps and prepare for RBI submission.