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System Requirements

Keeping in view the resurgence of the COVID-19 pandemic and the representations received from 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 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 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:

RBI Relaxation Compliance Norms with Various Payment System Requirements

Annexure (Relaxations)

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


Instruction / Circular

Present Timeline

Revised Timeline


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 on March 31, 2020 (audited balance sheet).

Financial position as on March 31, 2021

Financial position as on September 30, 2021


Harmonisation of TAT and customer compensation for failed transactions using authorised 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


Authorised Payment System Operators (PSOs) are required to furnish System Audit Report conducted by CERT-IN empanelled 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 close of their respective financial year.

By May 31, 2021

By September 30, 2021


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.


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 to payment system operators / participants to meet the various compliance requirements. 

Source: Click Here

Disclaimer:  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.

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Category Others, Other Articles by - CS Lalit Rajput