[INDIA] RBI, SEBI and IRDAI · Source-code escrow and continuity obligations for critical applications[EU DORA] ICT third-party risk testing required · In force Jan 2025[PRA] SS2/21 UK · Vendor recovery evidence required[MAS] Singapore TRM · Independent vendor recoverability expected[APRA] CPS 230 Australia · Third-party continuity obligations in force[FFIEC] United States · Source-code access and software escrow addressed in third-party contracts[ENTERPRISE] Mission-critical software procurement increasingly requires continuity evidence before contract
[INDIA] RBI, SEBI and IRDAI · Source-code escrow and continuity obligations for critical applications[EU DORA] ICT third-party risk testing required · In force Jan 2025[PRA] SS2/21 UK · Vendor recovery evidence required[MAS] Singapore TRM · Independent vendor recoverability expected[APRA] CPS 230 Australia · Third-party continuity obligations in force[FFIEC] United States · Source-code access and software escrow addressed in third-party contracts[ENTERPRISE] Mission-critical software procurement increasingly requires continuity evidence before contract

Escrow Banking

Escrow Infrastructure Tailored for Payment Aggregators

Castler’s escrow solution helps payment aggregators comply with RBI guidelines while offering seamless fund flow management across merchants, customers, and partner banks. Built for high transaction volumes, the platform enables real-time reconciliation, automated settlements, and transparent workflows. With easy integration and robust compliance controls, Castler empowers aggregators to scale securely in a rapidly evolving payments ecosystem

Purpose-bound fundsMulti-bank visibilityRule-based settlements

Neutral control

Funds remain governed by agreed release conditions

Bank-connected

Escrow operations stay visible across the banking workflow

Audit-ready

Every movement retains a clear operational trail

THE USE CASE

A controlled escrow operating model

Castler’s escrow solution helps payment aggregators ensure RBI compliance with automated settlements, real-time reconciliation, and secure, scalable fund flows.

02

What is a Payment Aggregator?

A Payment Aggregator (PA) serves as a vital link between merchants and customers, making it easier for businesses to accept a variety of payment methods without the hassle of building their own payment systems. PAs gather payments from customers, keep them safe in a secure escrow account, and then send the funds to merchants after a specified time.

This efficient payment process lets e-commerce platforms, online businesses, and brick-and-mortar retailers concentrate on expanding their operations while also ensuring they meet regulatory requirements and maintain transaction security.

03

RBI’s Escrow Guidelines on Payment Aggregators

The Reserve Bank of India (RBI) requires all non-bank payment aggregators to set up an escrow account with a scheduled commercial bank to protect the payments they collect.

Escrow Account Requirement

Every customer payment received by payment aggregators (PAs) needs to be kept in a dedicated escrow account until it’s settled with the merchants.

Multiple Escrow Accounts

PAs have the option to open an additional escrow account with another commercial bank, which can provide extra security and better risk management.

According to Section 23A of the Payment & Settlement Systems Act (PSSA), 2015, PA operations fall under the category of ‘designated payment systems,’ which means they are subject to strict regulatory oversight.

By following RBI’s guidelines for payment aggregators, businesses can protect their transactions, avoid mismanagement of funds, and ensure smooth settlements.

04

Why is an Escrow Arrangement Essential for Payment Aggregator ?

Escrow Accounts: Making Transactions Safe

An escrow account serves as a special payment system that keeps customer funds safe until they are securely handed over to the merchant

A Legal Shield for Payment Security

The funds in an escrow account are off-limits to the payment aggregator or its creditors if they face insolvency. This means that payments are protected for both merchants and customers, as required by the Payments & Settlement Systems Act (PSS Act).

RBI’s Compliance Requirements

The regulations set by the RBI mandate that payment aggregators use escrow accounts to manage customer payments and settlements for e-commerce transactions, ensuring they stay compliant and maintain operational integrity

Building Consumer Trust & Protection

The escrow system ensures that customer payments are safe, transparent, and shielded from fraud, which boosts consumer confidence in digital payment methods.

05

Escrow Solutions That Power Payment Aggregators at Every Stage

API-Driven Escrow: Secure, Compliant & Efficient Payment Aggregation

Ensure fund security & regulatory compliance for Payment Aggregators (PAs).

Manage escrow accounts across multiple banks for seamless fund flow.

Connect effortlessly with merchants, acquirers, and banks for smooth payment processing.

Securely collect, hold, and disburse funds while adhering to RBI’s PA guidelines.

Ensure instant transaction validation & reconciliation.

Secure platform access with customized authorization for payment aggregators.

Process high-volume merchant settlements with accuracy.

Enable fast, secure, and seamless merchant settlements.

Ensure real-time tracking, audit logs, and compliance reporting.

Advanced security features to protect funds and prevent transaction risks.

06

Flow Diagram for Payment Aggregators (UPI & IMPS)

Highlighting Key Aspects:

A secure process for authorizing transactions in online merchant payments

The essential function of escrow banks in holding funds and managing settlements

Complete transparency throughout UPI and IMPS transactions

Protect Your Business with Castler

Join the ranks of leading companies around the India that rely on Castler for secure and compliant escrow solutions.

Build your next-gen pay-in and payout infrastructure with Castler’s unified API platform.

Dealer - Distributor

Merger & Acquisition

Pre-Paid Instrument

Franchisor - Franchisee

Alternative Investment

Trust & Retention account

API Banking & Integrations

Bespoke Solutions for Banks

Terms and Conditions

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ESCROW BANKING

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ESCROW BANKING

Put every release condition and settlement rule in one controlled flow

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