RBI Guidelines on Digital Payments: A Compliance Checklist for SaaS Startups

December 3, 2025

Akash Roy

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For SaaS founders in India, smooth payment flows are lifelines. Monthly and annual subscriptions fuel growth, and any disruption in billing directly impacts cash flow, customer experience, and trust.

But with RBI tightening regulations around digital payments, e-mandates, and data security, compliance is no longer optional. Non-adherence can mean blocked transactions, frozen accounts, or even regulatory action.

If your SaaS startup relies on digital collections, here’s a practical RBI compliance checklist to safeguard payments and stay ahead of the curve.

RBI Guidelines on Digital Payments: A Compliance Checklist for SaaS Startups

KYC & Onboarding Norms

The RBI mandates strict Know Your Customer (KYC) norms for onboarding merchants and users.

  • For SaaS founders: Your payment gateway/aggregator must complete your KYC before activating merchant services.
  • For your customers: If you’re offering wallet-based or prepaid instruments, full KYC must be completed within the timelines prescribed by RBI.

Why it matters: Without proper KYC, payments may be suspended. Incomplete KYC has already caused millions of digital wallet accounts to be frozen in the past.

Action step: Ensure your onboarding flow collects necessary KYC data and verify it against RBI timelines.

Recurring Payment Mandates

Subscriptions are at the heart of SaaS, but RBI’s e-mandate rules (effective since 2021) significantly changed how recurring payments work.

Key requirements:

  • Customers must provide Additional Factor Authentication (AFA) (e.g., OTP) to set up recurring payments.
  • Transactions above ₹5,000 per debit require OTP approval for every cycle.
  • Customers must receive pre-debit notifications at least 24 hours before charges.

Why it matters: If your subscription billing system isn’t aligned, recurring payments will fail, leading to churn and revenue leakage.

Action step: Integrate RBI-compliant e-mandate systems through your payment gateway (Razorpay, Cashfree, PayU, etc.) and test before scaling.

Data Storage & Tokenization

One of RBI’s most impactful regulations is the ban on merchants storing customer card details.

Instead, only RBI-certified card networks and payment aggregators can issue a tokenized version of the card.

  • Customers now authorize tokenization once.
  • Merchants store only the token, not the actual card number.
  • This applies to all recurring and one-time transactions.

Why it matters: Non-compliance can block transactions entirely. Customers may lose trust if they see failed payments due to improper storage.

Action step: Confirm your payment partner has implemented tokenization and purge any card data stored in your systems.

Settlement Timelines (T+1/T+2)

RBI requires payment aggregators to follow strict settlement timelines:

  • T+1 (Transaction date + 1 working day) → For certain categories like e-commerce and ticketing.
  • T+2 (Transaction date + 2 working days) → For most other businesses, including SaaS.

Why it matters: Delays in settlements can choke cash flow and trigger RBI penalties for your aggregator.

Action step: Monitor your settlement reports regularly. Use reconciliation tools to ensure customer payments are credited within mandated timelines.

Cybersecurity & Incident Reporting

RBI holds payment system participants accountable for data security and breach reporting.

Requirements include:

  • Regular Vulnerability Assessment & Penetration Testing (VAPT).
  • Implementation of PCI DSS compliance if handling card data.
  • Mandatory reporting of cybersecurity incidents to RBI within 6 hours of detection.

Why it matters: A data breach not only attracts RBI scrutiny but also damages customer trust, which is hard to rebuild in SaaS.

Action step: Work with certified auditors to conduct security reviews, patch vulnerabilities, and maintain compliance logs.

RBI Guidelines on Digital Payments – Closing Thoughts

For SaaS startups, RBI compliance is not just about ticking regulatory boxes. It’s about ensuring payment continuity, customer confidence, and business resilience.

Quick RBI Compliance Checklist for SaaS Founders:

  • . Complete KYC for your business and customers.
  • . Use RBI-compliant e-mandates for subscriptions.
  • . Implement tokenization — never store card data.
  • . Track settlement timelines (T+1/T+2) with payment partners.
  • . Schedule regular security audits and maintain compliance logs.

By embedding compliance into your payment systems, you not only avoid disruptions but also project credibility with investors and customers alike.👉 Want to make sure your SaaS startup is RBI-ready?
Book a FREE RBI compliance readiness review with our experts today.

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