Merchant On-Boarding Policy

(“Policy”)

Last Updated: February 17, 2026

Policy Statement

Google India Digital Services Private Limited (“Google”) as a Payment Aggregator (“PA”) has set out its policy for onboarding merchants for payment aggregator services as required under the Master Direction on Regulation of Payment Aggregator (PA) issued by the Reserve Bank of India (“RBI”) on September 15, 2025 (“PA Guidelines”), to the extent applicable.

Scope and Objectives

  • The scope and objectives of this Policy is as follows:

    • to comply with the requirement of PA Guidelines and other Applicable Laws, and adopt appropriate KYC and Merchant on-boarding process for Merchants (as applicable) that have an existing banking relationship & maintain a bank account for settlement purposes;

    • to adopt a simple, secure, and robust process for appropriate identification, due diligence and evaluation of prospective Merchants to be on-boarded by Google;

    • to provide a clear delineation of roles and responsibilities as well as information on the PA onboarding process; and

    • ensure transparency with relevant stakeholders.

  • This Policy must be read & complied in conjunction with Google Pay for Business Program Additional Terms of Service (“ToS”), Merchant Service Agreement (“MSA”) and other policies, as applicable.

Governance

Google’s Board of Directors (also referred to as the “Board”), bears overall responsibility for ensuring that the said Policy, Applicable Laws and regulations are adhered to, and are consistent with sound and prudent practices.

Definitions

All capitalized terms in this Policy, unless defined in-line, shall have the meanings set out below:

  • “Applicable Laws” means all statutes, regulations, rules, guidelines and circulars (as amended) to the extent applicable to PA services undertaken by Google, the foremost of which are directions, circulars and guidelines issued by the RBI or any other regulatory authority, or rules, guidelines, directions, instructions, requests issued by acquiring bank, or the card network organisation as applicable.

  • “Equivalent e-Document” has the meaning as defined under the RBI (Commercial Banks - Know Your Customer) Directions, 2025 (“RBI KYC MD”), to the extent applicable.

  • “Merchant” means: an entity (including a marketplace), selling goods and providing services, who uses Google Pay to collect payments from its customers for such goods and services purchased from the entity through offline (physical) or online platforms.

  • “Contact Point Verification (CPV)” has the meaning as defined under Master Direction on Regulation of Payment Aggregator (PA) issued by the Reserve Bank of India (“RBI”) on September 15, 2025 (“PA Guidelines”), to the extent applicable.

  • “Payment Participants” means all parties involved in the payment system including acquiring bank, issuer or card associations (as applicable) as defined and specified under the Applicable Law.

Merchant on-boarding phases

Google has formulated the process to on-board Merchants that is carried out in the following phases:

  • Phase – 1: Information Collection: Google collects information along with relevant documents of a Merchant as captured in Annexure A (“KYC Documentation & Information”) to conduct necessary onboarding checks to its satisfaction and to ensure that Google is able to satisfy competent authorities that the onboarding checks have been carried in compliance with the Applicable Laws. If necessary, Google will seek additional information, undertaking(s), reports or declaration(s) from the Merchant.

  • Phase – 2: Assessment and Evaluation: Google, before enrolling a Merchant for PA services, undertakes a simplified process of appropriate Merchant identification in accordance with the requirements under the Applicable Law, based on the Merchant business entity types (such as Individual, Sole Proprietorship, Partnership, Company etc), category (online or offline), and Merchant size (small or large), including basic assessment, evaluation and validation of the information collected from the Merchant. Google may adopt appropriate methods prescribed under Applicable Laws to conduct merchant identification and due diligence. This exercise covers, but is not limited to the below:

    • Onboarding checks based on the information collected from Merchants in accordance with the measures prescribed under the applicable law, identification of beneficial owner(s), sanctions and Politically Exposed Person (“PEP”) screening, and other appropriate checks.

    • Due diligence including background and antecedent checks on the Merchant.

    • CPV/ In person visitation where applicable.

    • Confirmation from the Merchant that it is not engaged in and will not use the PA services for prohibited products and services notified by Google.

    • Confirmation from the Merchant that its infrastructure is Payment Card Industry-Data Security Standard (“PCI-DSS”) and Payment Card Industry-Software Security Framework (“PCI-SSF”) infrastructure compliant (where applicable).

    • Confirmation from the Merchant that its website (where applicable in case of online merchants) clearly indicates the terms and conditions of the service and details on processing returns and refunds.

    • Confirmation from the Merchant that its site, database or server shall not save customer card credentials and such related data.

    • For a marketplace merchant, confirmation that the merchant does not accept payments for any seller not onboarded onto such marketplace’s platform.

    • Google undertakes a comprehensive security assessment (where applicable) during the merchant onboarding process and at periodic KYC refresh.

    • Google may also provide such information to a Payment Participant, and any regulator or law enforcement authority as required under Applicable Law.

  • Phase-3: PA Service Commencement: Upon completion of the aforementioned steps to the satisfaction of Google, the Merchant will be able to receive PA services in line with Applicable Laws. To commence the PA services, a Google Pay for Business Terms of Service “ToS”/ service agreement will also be executed by Google with the Merchant.

  • Google reserves the right to reject or cancel onboarding a Merchant to the PA services, at any time and where Google is unable to apply appropriate checks, either due to non-cooperation of such Merchant, non-reliability of the information furnished by them or if required under Applicable Laws.

  • Support for merchant onboarding: Merchants can reach out to Google Pay India Customer Care through Help Center (Offline and Online Businesses) for any support required during the onboarding process.

Policy Review and Approval

  • The Policy is reviewed annually and duly approved by the Board, to effect- any changes in Applicable Laws and need for revision in internal processes.

  • Till such review of the Policy, the contents of the Policy will always be read in tandem with modifications which may be advised by the RBI, NPCI and/ or by any regulators as applicable and/ or by Google from time to time. The relevant provisions of the Policy would be amended/ modified in due course to make it consistent with the Applicable Laws.

Annexure A
KYC Documentation & Information

KYC documents or equivalent e-documents and information listed below basis Merchant business entity types such as Individual, Sole Proprietorship, Partnership, Company etc, category (online or offline), and Merchant size (small or large), will be collected by Google at the time of onboarding Merchants, as applicable. Google, with Merchants’ consent (in MSA or ToS etc.), may seek additional information and documents, as the case may be, to satisfy the onboarding checks.

KYC Documents from:

  • Constitution/ incorporation/ registration documents, Board Resolution, Power of Attorney, Shareholding pattern, PAN, GST Registration Certificate, in case of legal entities/ firms (to the extent applicable and required as the case may be).

  • Documents related to identification and address in case of Individuals (relevant associated individuals in case of legal entities like Proprietor, Beneficial Owner, Authorised Signatory/ Power of Attorney holder, as applicable based on the merchant type).

  • Supporting documents to verify annual turnover like GST returns, or Income Tax returns, financial statements, bank statements, etc. where applicable/ required.

Merchant Information such as:

  • Name

  • Address

  • Business entity type

  • Line of business/ Merchant Category Code (MCC)

  • Settlement Bank Account details

  • Annual turnover

  • Names of relevant associated individuals in case of legal entities (like Proprietor, Partner, Beneficial Owner, Authorised Signatory, Senior Management Official / Director etc.) as applicable based on the merchant business entity type

  • Other business information like website (online business), email, phone number, etc. as required

The extent of applicability will depend on the business entity type of Merchants.

In case of an individual Merchant or associated beneficial owner of a legal entity Merchant, is identified a PEP/ close associate or family member of a PEP, Google will apply reasonable measures such as establishing source of funds/ wealth, identity, etc. as required and applicable, to take a decision whether to establish or maintain a business relationship with such Merchant.