India operating obligations
India operating obligations stack across RBI payment rules, SEBI securities rules, FIU AML requirements, tax overlays, and DPDP privacy / retention rules.
RBI money, payment, and FX obligations
- Authorisation perimeter
- PSS Act authorisation is the core payment-system boundary, and the PPI framework governs stored value.
- KYC and customer acceptance
- Regulated entities apply the RBI KYC Direction and still control onboarding of crypto-adjacent flows at the bank leg.
- FX handling
- Only authorised persons under FEMA s.10 can conduct regulated foreign-exchange business.
- Payment-data storage
- The Storage of Payment System Data FAQ requires payment data to be stored only in India.
- Customer grievance route
- RBI-regulated payment entities fall into the Reserve Bank - Integrated Ombudsman Scheme, 2021.
SEBI securities and custody obligations
- Security classification
- If the instrument falls within SCRA s.2(h), SEBI and securities law apply.
- Depository layer
- The Depositories Act and DP Regulations govern demat and depository infrastructure.
- Custody controls
- The Custodian Regulations impose recordkeeping and safekeeping controls.
- Listed debt and disclosure
- The NCS Regulations govern issue and listing of non-convertible securities.
- Complaint handling
- Investor grievances route through SCORES and ODR for SEBI-regulated entities.
Financial integrity requirements
- AML perimeter
- The 7 March 2023 notification brings specified VDA activities into the PMLA perimeter.
- Registration
- The 15 September 2025 circular sets the VDA service-provider registration process.
- Customer due diligence
- The FIU Guidelines, 2026 require customer identification, beneficial-ownership review, and ongoing monitoring.
- Travel Rule
- The FIU Guidelines, 2026 apply originator and beneficiary information controls to VDA transfers.
- Higher-risk wallet patterns
- The FIU Guidelines, 2026 treat unhosted-wallet and anonymity-enhanced activity as elevated risk.
- Record retention
- The FIU Guidelines, 2026 require retention of identity and transaction records for at least five years.
Tax overlay
- Transfer-income rule
- The Income-tax Act, 2025 carries the VDA transfer-income rule in section 194.
- Withholding
- The VDA withholding rule sits in section 393 of the new Act.
- Threshold relief
- The Income Tax Department continues to publish threshold relief for VDA withholding.
- Exchange reporting
- Form 142 and transition materials support the VDA withholding reporting workflow.
Privacy and recordkeeping overlay
- General privacy law
- The DPDP Act, 2023 provides the general digital-personal-data framework.
- Rules and timing
- The DPDP Rules, 2025 phase commencement across different rule groups.
- Board process
- The Board notification establishes DPB India for the DPDP framework.
- Sectoral storage and retention
- RBI payment-data storage and FIU retention continue to apply alongside DPDP rights.