Monday, May 12, 2025

comparison of the Payment and Settlement Systems Act, 2007 (PSS Act) with the EU’s Payment Services Directive 2 (PSD2)

 comparison of the Payment and Settlement Systems Act, 2007 (PSS Act) with the EU’s Payment Services Directive 2 (PSD2) and a note on how the RBI supervises FinTechs under the PSS Act:


📊 PSS Act (India) vs PSD2 (European Union)

AspectPSS Act, 2007 (India)PSD2 (EU Directive)
RegulatorReserve Bank of India (RBI)European Central Bank & National Competent Authorities
ScopeAll payment and settlement systems in IndiaAll electronic payment services across the EU
Authorization RequirementMandatory for any payment system operator (Section 4)Mandatory for Payment Service Providers (PSPs)
Third-party Access (TPP)Limited; controlled entry (FinTechs require RBI nod)Explicitly enables Third-Party Providers (TPPs) with strong rules
Customer ProtectionGoverned by RBI directives (e.g., grievance redressal, KYC)Very strong — includes rights to refunds, authentication rules
Data Access & SharingNo explicit open banking law; RBI controls via directionsPSD2 mandates open banking with APIs under customer consent
Strong Customer AuthenticationMandated through RBI circulars (e.g., 2FA, OTP)Mandatory through SCA (Strong Customer Authentication)
Settlement FinalityYes, legal certainty under Section 23Yes, required under EU laws
Penalty/EnforcementMonetary penalties (up to ₹10 lakh + daily fine)Administrative sanctions, fines, and revocation

👩‍💻 RBI’s Supervision of FinTechs under the PSS Act

RBI has increasingly brought FinTech companies under its regulatory umbrella, especially those involved in payment processing, digital wallets, and payment gateways.

🏛️ FinTechs regulated under PSS Act include:

  • Prepaid Payment Instruments (PPIs) like Paytm Wallet, Amazon Pay

  • Payment Aggregators (PAs) like Razorpay, PhonePe, Cashfree

  • UPI-based apps via NPCI oversight (e.g., Google Pay, PhonePe)

🛠️ RBI Oversight Involves:

  • Mandatory authorization and licensing

  • Capital adequacy requirements (₹15 crore minimum net worth for aggregators)

  • KYC/AML compliance

  • Reporting obligations to RBI and Financial Intelligence Unit (FIU)

  • Interoperability mandates for PPIs

  • Audit requirements and cybersecurity guidelines


🔮 Future Trends:

  • RBI working on Digital Public Infrastructure (DPI) like UPI, ONDC, and CBDC

  • Potential for a PSS Act amendment to address AI/ML-based payment innovations

  • Global shift toward regtech, sandbox models, and real-time supervision

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