Where ZeroPay sits in the RBI framework

1. What ZeroPay is

ZeroPay Gateway is a software-as-a-service platform. It connects a merchant's Shopify store, WhatsApp Business account and payment aggregator account so that orders can be taken over chat and collected over UPI. ZeroPay is not a bank, a Payment Aggregator (PA), a Payment Gateway operator settling funds, a Prepaid Payment Instrument issuer, or a Payment System Operator authorised under the Payment and Settlement Systems Act, 2007.

2. How money actually moves

• Payment links are generated on the merchant's own PhonePe Payment Gateway account, using credentials the merchant supplies.
• Customer funds move from the customer's UPI app to the RBI-authorised payment aggregator and are settled into the merchant's designated bank account.
• ZeroPay never holds, pools, escrows or routes customer funds and does not operate a nodal or escrow account. The RBI PA/PG Guidelines dated 17 March 2020 (as amended) apply to the authorised aggregator, not to ZeroPay.

3. Merchant obligations

• KYC and onboarding: merchants must be onboarded and KYC-verified by their payment aggregator in line with the RBI Master Direction on Know Your Customer, 2016 (as amended). ZeroPay does not substitute for that process.
• AML/CFT: merchants must comply with the Prevention of Money Laundering Act, 2002 and rules made under it, and must not use the platform for layering, structuring or disguising the origin of funds.
• Legitimate goods and services: collections must relate to genuine sales of goods or services actually supplied by the merchant. Marketplace-style collection on behalf of unrelated third parties is not permitted.
• GST and taxation: merchants are responsible for invoicing, GST registration where applicable, and all tax reporting on their sales.
• Customer disclosures: merchants must publish their own terms, refund, shipping and grievance policies on their storefront.

4. Data protection and localisation

Payment transaction data is stored in India by our payment partners in accordance with the RBI circular on Storage of Payment System Data dated 6 April 2018. Personal data is processed in line with the Digital Personal Data Protection Act, 2023 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011. See our Privacy Policy.

5. Messaging and consent

Order confirmations, payment links and receipts are transactional messages sent to a customer who initiated the conversation from the merchant's storefront. Merchants must comply with WhatsApp Business Messaging Policy and TRAI regulations on commercial communication, and must not repurpose collected phone numbers for unsolicited marketing.

6. Chargebacks, refunds and disputes

Because UPI collections are push-based, disputes are handled between the customer, the merchant and the payment aggregator under NPCI UPI dispute resolution rules. Refunds are initiated by the merchant from their aggregator dashboard. Unresolved complaints may be escalated under the RBI Integrated Ombudsman Scheme, 2021 against the regulated entity concerned.

7. Grievance redressal

Complaints about the ZeroPay platform are handled by our Grievance Officer appointed under the Information Technology Act, 2000 and the applicable intermediary rules. See Grievance Redressal for timelines and escalation levels.

8. Nothing here is legal advice

This page summarises how the platform is designed to operate. It is not legal or regulatory advice. Merchants should obtain their own advice on the licences, registrations and disclosures applicable to their business.