[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

Powering Smooth Digital Transactions: Castler’s PPI Escrow Infrastructure

Castler enables PPI issuers to meet RBI’s escrow compliance with a secure, purpose-built framework for managing prepaid funds. Supporting wallets, cards, BNPL, and gifting platforms, the solution offers real-time reconciliation, seamless partner integration, and operational continuity. Designed for scale and regulatory precision, Castler simplifies fund flows across India’s growing prepaid ecosystem ensuring speed, control, and reliability

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 helps PPI issuers stay RBI-compliant with secure fund flows, real-time reconciliation, and seamless integration.

02

What is a Pre-Paid Instrument?

Prepaid Payment Instruments (PPIs) are a convenient way for users to keep their money stored digitally and make purchases for various goods, services, remittances, and financial services. In India, PPIs are divided into three main categories:

Closed System PPIs

These can only be used within the issuer’s own ecosystem, like gift cards from a specific brand.

You can't make third-party payments or withdraw cash with these.

No approval from the RBI is needed since they aren't considered a payment system.

Semi-Closed System PPIs

These are accepted at a network of pre-approved merchants, such as digital wallets and food delivery apps.

Cash withdrawals aren't allowed, no matter if the issuer is a bank or a non-bank.

They require agreements with merchants through payment aggregators or gateways.

Only banks can issue these, and they can be used at any merchant or service provider.

They allow for cash withdrawals at ATMs, PoS, and through Business Correspondents (BCs).

This type offers more flexibility and promotes financial inclusion.

03

RBI Guidelines on PPI Escrow Accounts

To keep things secure and compliant, the Reserve Bank of India (RBI) requires that all non-bank PPI issuers hold their outstanding balances in an escrow account with a scheduled commercial bank.

Escrow Account Requirement

The balance in the escrow account should never dip below the total outstanding PPI amount by the end of each day.

Quick Fund Transfer

PPI issuers are required to deposit funds into the escrow account on the same business day to ensure transparency and security.

Regulatory Supervision

According to Section 23A of the PSS Act, 2007, non-bank PPI operations are recognized as ‘designated payment systems’, which means they are closely monitored by the RBI.

This Escrow setup safeguards consumer funds, facilitates smooth fund settlements, and bolsters the stability of the financial system.

04

Why is an Escrow Arrangement Essential for PPIs?

An Escrow account serves as a protective barrier, making sure that PPI issuers can’t misuse customer funds before any legitimate transactions take place.

Consumer Protection

By keeping user funds separate from operational funds, an Escrow system helps prevent defaults and shields users from financial risks.

Maintaining Financial Stability

Escrow arrangements help minimize risks by ensuring that PPI issuers have enough liquidity and adhere to the RBI’s regulatory standards

05

How the Escrow Process Works

The designated commercial bank serves as the escrow agent, keeping the funds safe until they're needed for payments to merchants.

The funds collected are securely held and utilized for:

Payments to merchants as per acceptance agreements

Transfers and remittance services

Regulatory Compliance

The RBI’s stringent guidelines for PPI escrow ensure that non-bank PPI issuers conduct their operations in a transparent and responsible manner.

06

Castler’s Capabilities on PPI

Castler’s Capabilities

API-Powered Escrow for Secure & Compliant PPI Transactions

Ensure fund security & regulatory compliance with RBI guidelines

Manage escrow accounts across multiple banking partners for seamless fund movement.

Connect effortlessly with PPI issuers, banks, and payment networks for smooth transactions.

Ensure instant credit to escrow accounts upon PPI issuance, load, or reload.

Track, manage, and verify PPI transactions with real-time audit trails.

Secure platform access with customized authorization levels for PPI issuers.

Enable fast & secure payments for merchants and consumers.

Protect PPI funds with automated risk checks & regulatory safeguards.

Maintain full transparency & control over PPI fund management.

07

Fund Flow Diagram for PPI Transactions

Highlighting Key Aspects:

Real-time settlement and authorization process

Safe escrow bank integration

Fund separation for better financial security

Stay Compliant & Protect with Castler

ESCROW BANKING

Continue with Castler’s full escrow platform

Explore the platform

ESCROW BANKING

Put every release condition and settlement rule in one controlled flow

Bring your escrow structure to Castler for a focused implementation briefing

Book a 15-min briefing
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