Do All Roads in Fintech Lead the Same Way?
How India's payment license strategy reveals fintech ambitions — by Ambika Pande
The New Licensing Reality
In November 2025, RBI unified payment licensing into one overarching framework with functional segments, fundamentally reshaping how fintechs operate in India.
PA-O
Online payments
PA-P
Physical/offline payments
PA-CB-I
Cross-border inward remittance
PA-CB-O
Cross-border outward remittance
"Entities operating in both PA-O and PA-P need to use the same escrow for both" — reducing regulatory arbitrage and unifying entity-level risk assessment.
This replaced a previously fragmented system where companies could cherry-pick requirements, creating a more cohesive regulatory environment that forces strategic clarity.
Five Strategic Archetypes
Indian fintechs are clustering into 5 distinct license strategies, each revealing their true business ambition and competitive positioning in the evolving payments landscape.
1
License as Shield
Hold PA-O/PA-P for legitimacy, avoid core payments
2
Full-Stack Payments Elite
All four licenses, payments is the business
3
India-First Domestic
PA-O/PA-P only, no cross-border (yet)
4
Pure Cross-Border Specialists
Standalone cross-border aggregators
5
Online + Cross-Border Hybrid
Globally-oriented infrastructure players
Archetype 1: License as Shield
The Strategy
Use the license as a compliance checkbox while the real business is elsewhere — lending, identity, APIs. They avoid the crowded core payments market entirely.
Key Players
Decentro
API solutions provider
Digio
Identity and e-signature platform
Khatabook
Business payments ledger
Navi
UPI app + NBFC lending
Companies holding PA-O/PA-P primarily for regulatory legitimacy without full money movement involvement. Their licenses serve as defensive positioning rather than offensive growth strategy.
Archetype 2: Full-Stack Payments Elite
All four licenses (PA-O, PA-P, PA-CB-I, PA-CB-O). Payments IS the complete business strategy. These companies are betting that owning the full payment stack — domestic and cross-border, online and offline — creates the deepest moat.
Razorpay
PayU
Pine Labs
Paytm
Cashfree
Easebuzz
Additional players include Airpay, First Data, Lyra, Toucan, Nomisma, and MMAD — all committed to comprehensive payment infrastructure across every channel and geography.
Archetype 3: India-First Domestic
PA-O and PA-P only. No cross-border licenses. Cross-border remains a future consideration. These players are focused on winning the massive domestic market first.
PhonePe
India's #1 UPI player with dominant market share. PhonePe's absence from cross-border is notable given its scale and resources.
Zoho Payment Technologies
Enterprise-focused payment solutions integrated with broader business software suite.
CCAvenue (Infibeam)
Established payment gateway serving thousands of Indian merchants across categories.
Archetype 4: Pure Cross-Border Specialists
Standalone cross-border aggregators treating international flows as the primary business. This is an emerging segment — specialized export/import API solutions independent of domestic payments.
Current License Holders
BriskPe
PA-CB-I & PA-CB-O
Skydo
PA-CB-I only
In-Progress Applications
  • Xflow
  • Paymate
  • Payoneer
  • PayPal
  • Wise
  • TradePe
Global giants like PayPal and Wise are applying for India-specific cross-border licenses, validating the strategic importance of this specialized segment.
Archetype 5: Online + Cross-Border Hybrid
PA-O plus at least one PA-CB license. Globally-oriented infrastructure players bridging Indian merchants with global commerce — processing international card payments while routing through India's domestic rails.
Indian Merchants
Hybrid Infrastructure
Global Commerce
Adyen India
PA-O + PA-CB-O
Boku
PA-O + PA-CB-O
Juspay
PA-O + PA-CB-I & PA-CB-O
Pay10, Payglocal, Unlimit, Worldline
PA-O + PA-CB-I & PA-CB-O
How India Differs from Global Models
Unlike Singapore and UK, India's framework lacks two critical elements that create a uniquely challenging compliance environment for all players regardless of size.
No "Infrastructure-Only" License
Even companies that don't move funds (like API providers) must hold a full PA license. This creates universal high compliance burden regardless of transaction volume.
No Scale-Based Compliance Reduction
Singapore differentiates between Standard Payment Institutions (SPI) and Major Payment Institutions (MPI). India applies the same rules to a ₹1Cr processor and a ₹1L Cr processor.

Critical Impact: This forces every fintech to build heavyweight compliance infrastructure from day one, creating significant barriers to entry and operational overhead even for early-stage companies.
2026 Outlook: What to Watch
Cross-Border as Standalone Product
Specialized export/import APIs will emerge independent of domestic payments. BriskPe and Skydo are early movers in this space, creating dedicated infrastructure for international trade flows.
Regulatory Optionality as Strategy
License selection now signals business ambitions — domestic margins, global positioning, or export-first models. Watch what companies apply for next as a leading indicator of strategic direction.
Operations as Competitive Advantage
Companies building superior escrow management and compliance infrastructure will differentiate beyond pricing. The moat is in operations, not technology.
Bottom line: License positioning no longer indicates market dominance — it reveals fundamental strategic direction and product focus. The next wave of fintech winners will be defined by operational excellence and strategic clarity, not just technological innovation.
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