November 2025
I. NPCI Realm
A. UPI <> TIPS and Fawri+
Not just in India but UPI is relentlessly expanding outside India. Already UPI is accepted in 8 countries (France, Singapore, Bhutan, Nepal, Sri Lanka, Mauritius, UAE, and Qatar) with plans to add more countries (Japan, Peru, Trinidad and Tobago)
Also, UPI is interlinked with Real-Time payment systems of other countries to create cross-border express highways.
Already UPI is interlinked with Singapore’s PayNow.
This month, two more such initiatives were started
UPI will be integrated with the European Central Bank’s TIPS (TARGET Instant Payment Settlement System).
UPI integration with Bahrain’s Fawri+
These interlinked RTP cross-border highways aim to make remittance faster and cheaper.
II. RBI Realm
A. PA Licenses became Easy
Master Directions on Regulation of Payment Aggregator (MD - RoPA) allows a licensed/authorized PA to start another type of business with just intimation to RBI.
E.g. If an entity is holding PA-O license then it can intimate RBI its intention to start PA-Cross Border (inward/outward/both). RBI will issue a new authorization letter.
You can see many entities are flaunting that they have all three licenses (PA-O, PA-CB, PA-P).
Very soon, one entity holding multiple licences will be the norm.
Although licensing has become easy, it is not easy to manage compliance, operations and making money in this ultra competitive space. So the early enthusiasm of multi-license will be tested.
B. SROs
RBI recognized (Self Regulated PSO Association) as SRO (Self Regulated Organization) of PSO (Payments System Operators).
SRPA comprises major PSOs such as Billdesk, CC Avenue, RazorPay, PhonePe, MasterCard etc. [link]
Formation of SRO is to bring self governance among India’s payments/FinTech ecosystem players and the SROs are recognized and operate under the RBI’s framework.
Other two SROs are:
FIDC (Finance Industry Development Council) is SRO for NBFCs
FACE (FinTech Association for Consumer Empowerment) is SRO for all types of FinTechs.
The best result for a group comes from when every individual in the group does what is best for themselves and for the group - John Nash
C. API Based Payout under scanner
RBI is looking into API based payout! [Link]
Yes… RBI has turned its focus on the beautiful and yet complex and at times shady part of the payments ecosystem.
Usually payout is done by business to other businesses or customers for various use cases such as loan disbursement, COD refund, incentive payout, commission payments, account beneficiary name validation using penny drop etc.
Payout is done via NEFT, IMPS, RTGS and UPI rails.
Payout has two distinct business models (not getting hybrid models)
Connected Banking - payout API is used on a merchant’s own bank account
Pooled account - A common account (held by payout facilitator) is used by merchants for payout.
Many of the PAs, TSPs, RegTechs and FinTechs provide payout solutions to merchants.
To know more in detail, read articles (this and this) or refer to Chapter 15 of Auth N Capture (Revised Edition).
Payout rails do solve some genuine payment related requirements but at the same time they can be used for moving funds without much oversight.
See, entities that provide Payout Services (Except banks) are not regulated.
So RBI has started looking closely into this…
and possible outcomes? - more oversight, banks will tighten the access to payout APIs and possibly licensing…. Let’s see how this will shape up.
Increase in financial frauds:
https://the420.in/rbi-rabi-sankar-cbdc-digital-public-infrastructure-financial-fraud/
D. TRAI in reducing frauds
The dark side of payments are frauds… and recently, the RBI Deputy Governor said that “Frauds per number of transactions has been increasing since July ‘25”.
There are various entities fighting frauds and prosecuting fraudsters in their own capacity [read this article]
Last month, banks rolled out the bank.in domain… Now we clearly know that if the url is not ending with bank.in then it is not legitimate.
Now is the time for phone numbers.
Based on TRAI (Telecom Regulatory Authority of India) initiative DOT (Department of Telecom) has allotted ‘1600’ series for Banking, Financial Services and Insurance (BFSI) sector, and Government organisations.
Good initiative… So users will know that a regulated/genuine entity is calling and not a fraudster.
This month, TRAI has set deadline for entities to complete the migration/implementation of 1600 series
SEBI Regulated Entities: MFs and AMCs (15-Feb-2026), QSBs (15-Mar-2026)
RBI Regulated Entities: Commercial banks (1-Jan-2026), Large NBFCs, Payments Banks, SFBs (1-Feb-2026), Other NBFCs, Co-op bank, Regional Banks (1-Mar-2026)
PFRDA: CRAs and Pension Fund Managers (15-Feb-2026)
E. Draft Guidelines to simplify cross-border inward remittance
To address the delays and bring more transparency to cross-border inward remittance RBI floated draft guidelines.
Timely update to customer regarding receipt of inward transaction on the receipt of message during operating hours
Reconciliation interval of Nostro account should be less than thirty minutes
Banks should try to credit the beneficiary’s account on the same business day
Banks should take effort to provide a digital interface within a reasonable time frame for their customers to submit documents, access information and monitor transactions.
F. Fines and Penalties
This month, the RBI has imposed a total penalty of Rs.1.633 Crore on 19 entities
Rs. 1.306 Crore penalty on two banks (HDFC: Rs. 91 Lakh and TMB: Rs. 39.6 Lakh)
Rs.7.2 Lakh penalty on 3 NBFCs
Rs.25.5 Lakh penalty on 14 Co-operative banks
III. Payment Entities/FinTech Realm
Two IPOs
Two FinTech biggies did successful IPO
Pine Labs - Payment Aggregator (offline and online)
Groww - Wealth Tech and also Groww Pay holds the online PA license.
Hearty Congratulations to both companies and people who made it happen :)
PayTM Received PA-O License
After almost 2 years of embargo, PayTM had received in-principle authorization in Aug-2025 and this month received final authorization to operate as online payment aggregator (PA-O).
First Data Received Online and Physical PA authorization
Juspay received PA-CB Cross Border License.
And I am all set for my third 0-1 product launch journey in the last two years (other two are PA-Online and COU)!
That should explain why I was late in publishing this Payments Digest :)
That’s the wrap of November 2025!
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