India licensing and functions
Permissions are function-specific: RBI for payment and FX perimeters, FIU-IND for VDA services, SEBI for securities, and IFSCA for IFSC venue routes.
Licensing decision tree
Function matrix
| Function | Authority / rule | Operational note |
|---|---|---|
| Issue sovereign digital rupee | RBI Act and e₹ FAQ. | Sovereign-only route. |
| Run payment system or issue PPI | PSS Act and PPI framework. | RBI authorisation required. |
| Provide VDA exchange service | PMLA notification and FIU Guidelines, 2026. | Reporting-entity registration route. |
| Provide VDA transfer or custody service | FIU Guidelines, 2026. | Travel Rule, customer due diligence, and wallet-risk controls attach. |
| Arrange INR bank payout after VDA sale | FEMA s.10 and RBI KYC. | Bank acceptance and authorised channels remain route-critical. |
| Operate online import / export payment aggregation | RBI PA-CB. | Merchant collections and payouts only; not a standalone stablecoin payment licence. |
| Issue, hold, or service securities | SCRA; Depositories Act; NCS Regulations; Custodian Regulations. | Existing securities lane is live. |
| Run IFSC pilot / FinTech Entity | FE Framework and IFSCA Sandbox. | Venue-specific only. |
| Test hybrid multi-regulator product | IoRS FAQ. | Coordination window, not a production licence. |
Licensing overlays and venue interactions
India licensing logic is additive. A VDA business can sit inside the FIU perimeter and still need bank acceptance, RBI KYC, and FEMA-compliant handling for any INR or cross-border leg. If the same structure also represents security-like rights, the route moves into SEBI and depository / custody law as well.
There is no public one-licence-covers-all result in the reviewed materials. The FIU registration circular is an AML / reporting entry point, not a payment-system authorisation under the PSS Act, not an FX authorisation under FEMA, and not a securities registration.
IFSC is the clearest venue-specific overlay. The FE Framework and IFSCA Sandbox provide structured pilot access in GIFT City IFSC, while the IoRS FAQ provides a common window for hybrid products touching more than one financial-sector regulator.