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The Silent Gating Function: Why Merchant Category Codes Are Your First Compliance Checkpoint Bastyr is a pharmacy. Amul is a dairy retailer. Gymshark is sports apparel. These aren’t opinions. They’re Merchant Category Codes—three-digit classifications that sit between your merchant onboarding and your compliance framework. They determine almost everything about how a payment aggregator regulates that merchant. Get the MCC right, and your compliance team operates with clarity. Every downstream decision—transaction monitoring, KYC depth, policy checks, regulatory reporting—stands on solid ground. ...

On September 15, 2025, the Reserve Bank of India issued its comprehensive Master Direction on Regulation of Payment Aggregators. It replaced every previous guideline on PA regulation with a single, binding document. Most of the industry commentary focused on one thing: the January 1, 2026 onboarding deadline. From that date, every new merchant must be onboarded under full due diligence requirements without exception. That deadline has passed. What has received considerably less attention is what the document actually requires from a payment aggregator’s merchant compliance infrastructure — not just at onboarding, but continuously, at scale, and in a form that a CERT-In empanelled auditor can evaluate. ...