ARTICLE
11 August 2020

A Breather For Payment Systems

J
JSA

Contributor

JSA Advocates and Solicitors is a top-tier, full-service Indian law firm. Established in 1991, at the start of India’s economic liberalisation, the firm has built a strong reputation for handling complex and high-stakes legal and commercial matters. The firm is organised around specialist practice areas and industry sectors. It works closely with leading Indian corporates, Fortune 500 companies, global financial institutions, and government and statutory bodies on important corporate, financing, and disputes mandates. JSA has a team of over 700 legal professionals, including 180+ partners, and operates from 10 offices across seven cities in India: Ahmedabad, Bengaluru, Chennai, Gurugram, Hyderabad, Mumbai, and New Delhi. The firm is consistently recognised as a top-tier practice by leading international legal directories, including Chambers & Partners (Asia-Pacific and Global), Legal 500, and AsiaLaw.
The RBI has released several notifications in relation to payment systems for compliance purposes. These notifications included the following
India Finance and Banking

RBI extends timelines for compliance with various payment systems requirements

The RBI has released several notifications in relation to payment systems for compliance purposes. These notifications included the following:

  1. Enhancement of security card transactions;
  2. Issuance and operations of Prepaid Payment Instruments ("PPI"); and
  3. Guidelines regulating payment aggregators and payment gateways.

The RBI through a notification dated June 04, 2020, decided to extend the timelines for compliance by payment systems due to the COVID-19 situation. Details of the extensions are provided below:

  1. Prior to this notification, all non-bank PPI issuers were expected to comply with the minimum positive net worth requirement of INR 15 crores for the financial position as on March 31, 2020. This has been revised to financial position as on September 30, 2020. Further, all authorised non-bank entities were required to submit a System Audit Report including cyber security audit conducted by CERT-IN empaneled auditors, by August 31, 2020. This has been revised to October 31, 2020.
  2. The timelines for implementing provisions of circular on "Enhancing Security of Card Transactions" has been extended from March 24, 2020 to December 31, 2020.
  3. Under the guidelines on regulation of payment aggregators and gateways, for activities where no specific timelines were mentioned in the guidelines, the RBI stated that the effective date of such activities would be April 01, 2020. This has now been revised to September 30, 2020

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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