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A customer applying for a business loan may have accounts with several banks, investments in mutual funds and insurance policies with different providers. Traditionally, collecting and verifying this information involves multiple statements, documents and follow-ups. An Account Aggregator (AA) changes this process by enabling customers to share their financial information digitally with authorised financial institutions through an explicit consent mechanism.

For fintech companies and businesses planning to enter this segment, the opportunity is not simply to build another financial technology platform. Account Aggregation is a regulated activity in India. A company intending to operate as an Account Aggregator must understand the Reserve Bank of India's registration requirements, capital conditions, technology expectations and restrictions on handling financial information.

An NBFC Account Aggregator License is therefore a necessary regulatory approval for eligible companies planning to undertake this business.

What Is an Account Aggregator and How Does It Work?

An Account Aggregator is a regulated financial intermediary that enables the secure transfer of a customer's financial information between authorised institutions. It operates through a consent-based digital framework rather than collecting financial information for its own commercial use.

The RBI framework recognises two important participants:

• Financial Information Provider (FIP): An institution that holds financial information, such as a bank, NBFC, insurance company, mutual fund or depository.

• Financial Information User (FIU): An entity regulated by a financial sector regulator that requests financial information for an authorised purpose.

Consider a small business owner applying for working capital. The lending institution may need bank transaction details to assess the business's financial position. Instead of asking the applicant to download and upload several bank statements, the lender can request the relevant information through the Account Aggregator network.

The customer reviews the consent request and authorises the transfer. The Account Aggregator facilitates the exchange between the participating institutions.

The framework can cover several categories of information, including bank deposits, mutual fund holdings, insurance policies, securities, pension information and specified GST returns.

The distinction is important: an Account Aggregator facilitates data sharing; it does not independently assess creditworthiness, sanction loans or execute financial transactions.

Regulatory Framework Governing NBFC Account Aggregators in India

The Reserve Bank of India regulates Account Aggregators under the RBI Act, 1934. Section 45-IA provides the broader NBFC registration framework, while the specific regulatory requirements for this business are contained in the Account Aggregator Directions.

There is an important regulatory update that prospective applicants should consider. The RBI issued the Reserve Bank of India (Non-Banking Financial Companies – Account Aggregator) Directions, 2025, dated November 28, 2025. These directions replaced the earlier 2016 framework and should be used when evaluating a fresh registration application.

The 2025 Directions cover registration, the responsibilities of the board, permitted activities, customer consent, technology arrangements and operational compliance. They also place NBFC-Account Aggregators in the Base Layer under the Scale Based Regulation framework.

The registration requirement is straightforward: a company cannot commence or carry on the business of an Account Aggregator without obtaining a Certificate of Registration (CoR) from the RBI, subject to the specific regulatory exemption for certain entities regulated by other financial sector regulators.

This means that developing an application or establishing arrangements with financial institutions does not, by itself, authorise a company to operate as an Account Aggregator.

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Eligibility Criteria for an NBFC Account Aggregator License

A business planning to apply should evaluate its corporate structure, capital position, management background and technology readiness before submitting an application.

1. Company Incorporation

Only a company registered under the Companies Act can undertake the business of an Account Aggregator. A proprietorship, partnership firm or LLP cannot directly obtain the registration as an NBFC-AA.

A startup planning to enter this segment should therefore establish an appropriate company structure before proceeding.

2. Minimum Net Owned Fund of ₹2 Crore

The RBI requires an applicant to maintain a Net Owned Fund (NOF) of at least ₹2 crore, or such higher amount as the RBI may specify.

The 2025 Directions provide an important flexibility: a company that does not have the minimum NOF when applying may meet the requirement during the validity period of its in-principle approval.

However, this should not be treated as an automatic relaxation. The applicant must satisfy the capital requirement within the permitted period and comply with the conditions imposed by the RBI.

3. Fit and Proper Promoters

The RBI examines the background and suitability of the promoters and the proposed management. Their financial standing, professional background, integrity and overall suitability may be relevant to the assessment.

4. Adequate Capital and Financial Resources

The company must demonstrate that it has sufficient financial resources to establish and operate the proposed Account Aggregator business. Its financial projections should reflect realistic technology, staffing, security and operational costs.

5. Robust Information Technology Infrastructure

Technology readiness is a significant part of the application. The company should have a credible plan for secure data exchange, customer authentication, consent management and protection of financial information.

6. Leverage Ratio

Under the 2025 Directions, the company's leverage ratio must not exceed seven. The ratio is calculated as outside liabilities, excluding borrowings or loans from group entities, divided by owned funds.

These requirements are assessed together. Meeting the minimum capital requirement alone does not guarantee RBI approval.

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Documents Required for NBFC Account Aggregator Registration

The applicant should prepare a comprehensive documentation set before filing the application. The exact documents may depend on the company's structure, ownership, business model and the RBI's requirements.

The following are important categories to prepare:

The applicant should also be prepared to explain how the proposed platform will interact with Financial Information Providers and Financial Information Users.

One practical recommendation is to reconcile the shareholding information, financial statements and promoter declarations before filing. Inconsistencies between corporate records and the application can lead to additional regulatory queries.

NBFC Account Aggregator Registration Process: Step-by-Step

The RBI registration process involves more than submitting a form. The applicant must demonstrate that it has the financial, managerial and technical capacity to operate a regulated financial data-sharing platform.

Step 1: Incorporate the Company

The first step is to establish a company under the Companies Act, 2013. Its constitutional documents and proposed business activities should be reviewed to ensure that they are appropriate for the intended Account Aggregator business.

Step 2: Assess Capital and Promoter Eligibility

The company should examine its NOF position, ownership structure, financial resources and promoter credentials.

It should also calculate the leverage ratio and assess whether the proposed capital structure can support the business.

Step 3: Prepare the Business and Technology Plan

The application should clearly explain the proposed services, operational model, technology architecture, information security arrangements and customer consent mechanism.

A generic fintech business plan may not adequately explain the specific responsibilities and restrictions applicable to an Account Aggregator.

Step 4: File the Application Through the PRAVAAH Portal

The application for NBFC-AA registration must be submitted through the RBI's PRAVAAH portal to the Department of Regulation, Mumbai, in the prescribed format.

The company must provide the required corporate, financial, management and business-related information.

Step 5: Obtain In-Principle Approval

The RBI evaluates the application against the applicable eligibility and regulatory conditions. It may grant in-principle approval subject to conditions.

The validity of this approval is 12 months from the date it is granted.

Step 6: Establish the Technology Platform and Complete Legal Arrangements

During the in-principle approval period, the company must put the technology platform in place, complete the required legal documentation and report its compliance with the conditions imposed by the RBI.

This stage requires careful coordination between the company's management, legal advisers and technology team.

Step 7: Obtain the Certificate of Registration

Once the RBI is satisfied that the company has completed the required arrangements and is ready to commence operations, it may grant the Certificate of Registration as an NBFC-AA.

The company should commence regulated operations only after obtaining the necessary approval.

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Fees and Cost of Obtaining an NBFC Account Aggregator License

One of the common questions from prospective applicants is how much capital is required and what the RBI registration will cost.

The regulatory minimum is a Net Owned Fund of ₹2 crore. This is a capital eligibility requirement, not an application fee payable to the RBI.

The overall project cost will depend on the company's requirements, including:

• Company incorporation and corporate documentation.

• Legal and regulatory advisory.

• Technology platform development and integration.

• Cybersecurity and information security arrangements.

• Professional, audit and operational expenses.

• Employee recruitment and ongoing administration.

The 2025 RBI Directions do not specify a fixed application fee for NBFC-AA registration. Applicants should verify any applicable charges through the RBI's current application process rather than rely on unofficial fee estimates.

It is also important to distinguish between the capital requirement and the actual cost of establishing the business. A company may satisfy the ₹2 crore NOF requirement but still need additional funding to develop and maintain its technology infrastructure.

Compliance Requirements After Obtaining RBI Registration

Receiving the Certificate of Registration is the beginning of regulatory responsibility, not the end of the process. An NBFC-AA must maintain the conditions under which approval was granted and follow the ongoing requirements of the RBI.

Some important compliance areas include:

Customer consent and data protection: Financial information must be retrieved and shared only with explicit customer consent. The consent mechanism should clearly identify the information requested, its purpose, the recipient and the applicable validity period.

Restrictions on business activities: An NBFC-AA cannot undertake unrelated business activities. It cannot support customer transactions or use financial information for purposes other than those permitted under the regulatory framework.

No storage of customer financial information: Financial information accessed from Financial Information Providers must not reside with the Account Aggregator. The platform must also avoid accessing customers' authentication credentials, such as bank passwords and PINs.

Board-approved policies: The company must maintain appropriate policies covering customer grievances, service pricing and fit-and-proper assessments of directors and senior management.

Technology and security: The business requires secure interfaces, appropriate authentication, access controls and operational safeguards. RBI's technical specifications published through ReBIT are relevant to the Account Aggregator ecosystem.

Audit and regulatory reporting: The company must comply with applicable audit, reporting, financial disclosure and inspection requirements. The RBI may prescribe returns and inspect the company's operations.

For a business handling sensitive financial information, these obligations should be incorporated into its operating model from the beginning rather than addressed only when an inspection or compliance review arises.

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Common Challenges Faced by Applicants

Even companies with adequate funding may encounter difficulties during the registration process.

One recurring issue is treating an Account Aggregator as an ordinary fintech application. The RBI expects a regulated business with defined responsibilities, not simply a platform that connects financial accounts.

Another challenge is the proposed business model. Applicants sometimes plan to combine account aggregation with lending, financial product distribution or other commercial services. However, NBFC-AAs are subject to restrictions on undertaking other business activities.

Technology readiness is equally important. A platform must be designed around consent-based information exchange, secure interfaces and the applicable technical standards. A presentation describing future technology plans may not be sufficient if the company cannot demonstrate how those plans will be implemented.

Finally, capital planning should consider both the minimum NOF and the resources needed to operate the platform. Underestimating these expenses can create difficulties during the implementation stage following in-principle approval.

How Enterslice Can Assist With NBFC Account Aggregator Registration

Planning an Account Aggregator business requires coordination between corporate structuring, RBI regulations, financial documentation and technology readiness.

Enterslice provides regulatory and corporate advisory services for businesses operating in the financial services sector. Its assistance can be relevant when evaluating the proposed business structure, reviewing eligibility, preparing registration documentation and understanding ongoing NBFC compliance responsibilities.

Frequently Asked Questions

1. What is an NBFC Account Aggregator License?

It is an RBI Certificate of Registration that authorises an eligible company to operate as an Account Aggregator. The entity facilitates the transfer of customers' financial information between authorised financial institutions based on explicit customer consent.

2. What is the minimum capital requirement for NBFC-AA registration?

The RBI requires a minimum Net Owned Fund of ₹2 crore. An applicant that does not meet this requirement initially may fulfil it within the validity period of its in-principle approval, subject to RBI conditions.

3. Can an LLP apply for an Account Aggregator License?

No. The RBI framework requires the applicant to be a company registered under the applicable Companies Act provisions. An LLP cannot directly obtain NBFC-AA registration.

4. How long does the NBFC Account Aggregator registration process take?

The RBI Directions do not prescribe a guaranteed overall processing timeline. However, once in-principle approval is granted, the company receives 12 months to establish its technology platform, complete legal documentation and satisfy the applicable conditions.

5. Can an Account Aggregator provide lending services?

No. An NBFC-AA cannot undertake unrelated business activities or support customer transactions. Its permitted role is to facilitate financial information sharing under the RBI framework.

6. Is customer consent mandatory for financial data sharing?

Yes. An Account Aggregator must obtain explicit customer consent before retrieving, sharing or transferring financial information. Customers must also have appropriate consent management and revocation facilities.

7. Does an NBFC Account Aggregator need to comply with RBI regulations after registration?

Yes. It must comply with applicable RBI directions covering customer consent, information security, governance, audits, reporting, customer grievance handling and restrictions on business activities.