India Merchant Onboarding Policy
Adyen India Technology Services Private Limited
Scope and objectives
This policy has been designed to ensure that merchants (domestic and foreign) are onboarded and reviewed in accordance with the applicable laws. This policy should be read in conjunction with Adyen’s Global AML/CFT Policy.
Merchant on-boarding team
Based on policy and procedure determined by Adyen’s compliance function, Adyen’s merchant operations teams (the “Teams”) are responsible for undertaking an assessment of the potential merchant based on the information collected from the said merchant and/or obtained from reliable and independent sources, with oversight of the compliance function and Adyen’s management board. The policy and procedures that set out the criteria and standards for assessing the merchant are reviewed and updated at least annually, in accordance with the applicable law.
Merchant onboarding process
Step – 1: Collection of Information: For the Teams to conduct its background and antecedent check of the merchant, necessary information shall be collected, including the completed onboarding application, KYC identification documents, address proof, description of business model, business related documents/ certifications, bank details, PCI-DSS compliance, and other documents required to verify the credibility of the merchant. For further details, please refer to the following Procedures:
1. Adyen’s Legal Entity Screening Procedure;
2. Adyen’s Natural Person Screening Procedure;
3. Adyen’s Legal Arrangement Screening Procedure;
4. Adyen’s External Account Screening Procedure;
5. Adyen’s PCI-DSS Procedure;
6. Adyen’s Watchlist Screening Procedure; and
7. Adyen’s Business Model Screening Procedure (together, the Procedures)
Adyen India shall, at the time of customer onboarding, perform a search on the Central Know Your Customer Registry (CKYCR) and collect only such incremental or additional documentation as deemed necessary in accordance with its requirements.
In accordance with the above-mentioned Procedures and the guidelines contained herein, Adyen India Technology Services Private Limited (“Adyen India”) shall collect documents from its customers (merchant’s legal entity) and their authorised signatories and beneficial owners.
The documents collected from merchants legal entity as part of the Legal Entity and Natural Person Screening Procedure are listed below:
Documents from Legal Entities
A. Legal Entity Charter Documents
i) Certificate of Incorporation
ii) Memorandum of Association (MoA)
iii) Articles of Association (AoA); or
iv) in case of a Limited Liability Partnership (LLP) - the partnership deed/LLP agreement
B. Permanent Account Number or PAN Card (Tax ID) of merchant’s legal entity
C. Goods and Services Tax (GST) Certificate
D. List of Directors (on the letterhead of the merchant’s legal entity and executed by an authorised signatory) or in case of an LLP list of designated partners
E. Declaration of Ultimate Beneficial Owners
F. Resolution by the Board of Directors or designated partners or such other corporate governance document (as applicable) identifying signatories authorised to execute contracts including the merchant agreement with Adyen India.
G. Security Questionnaire
H. Proof for identification/ verification of settlement bank account (Bank Account Statement)
Documents collected from Ultimate Beneficial Owners and Authorised Signatories of the merchant
A. PAN Card;
B. Passport or Voter’s ID or Drivers License (any one)
In case of a foreign national (not required to have a PAN), Adyen India will collect and rely on Passport issued by their respective country.
Step – 2: Assessment and Evaluation: As part of this check, the Teams shall evaluate, seek additional information and clarifications as may be required, to satisfy itself that:
The merchant does not have any dupious or malafide intention;
The merchant does not sell or engage in fake/ counterfeit, prohibited or restricted products and services. For further details, please refer to Adyen’s Prohibited and Restricted Products and Services List.
The merchant is PCI-DSS compliant.For further information, please refer specifically to Adyen’s PCI Screening Procedure.
Step – 3: Execution of Legal Agreement: On completion of scrutiny, and satisfaction of compliance with applicable laws and Adyen’s internal standards, the merchant shall be required to execute an agreement with Adyen India and its partners which shall include suitable obligations on the merchant with respect to maintaining security/ privacy of customer data, continuous compliance with PCI-DSS standards, requirement to report incidents promptly and in the prescribed manner, amongst other responsibilities on the parties. This agreement shall also ensure that the merchant provides a periodic security assessment report, in the prescribed manner. Agreements between Adyen India, its merchants, its acquiring banks, and all other stakeholders shall clearly delineate the roles and responsibilities of the involved parties, inter alia covering manner of refunds, treatment of failed transactions, return policy, grievance redressal, reconciliation, etc. As part of the agreement, Adyen shall also obtain necessary undertakings/ certifications regarding the merchant’s compliance with applicable law.
Step – 4: Assignment of Merchant Category Code: The Underwriting Team shall assign a Merchant Category Code (MCC) based on applicable business model and industry specific requirements. Further information is set out in Adyen’s Business Model Screening Procedure.
Ongoing compliance
A security audit of the merchant may be carried out to check compliance with applicable law, as and when required.
Adyen India will obtain periodic security assessment reports from the merchant either based on the risk assessment and/or at the time of renewal of contracts.
Periodic review of all merchant files, including KYC data as collected and verified in accordance with the Procedures during on-boarding, will be performed per a risk-based review cycle to ensure all data on file remains up-to-date and accurate.
Onboarding of Domestic Merchants
Adyen India shall comply with applicable provisions of the Reserve Bank of India (Commercial Banks – Know Your Customer) Amendment Directions, 2025 (“KYC Master Direction”), as amended, replaced, or supplemented from time to time, and any guidelines, directions, or circulars issued in relation to in connection therewith. Adyen India will carry out the on-boarding process of domestic merchants in compliance with applicable laws in India including the relevant provisions stipulated under the KYC Master Direction, the RBI Master Direction on Regulation of Payment Aggregator (“PA Guidelines”) and the Prevention of Money Laundering Act, 2002 (the ‘PMLA’), as amended and updated from time to time (among others) and this merchant on-boarding policy that has been approved by its Board of Directors.
Incremental Due Diligence - Onboarding of Foreign Merchant – for Payment Aggregator Cross Border Import Business of Adyen India
Adyen India will carry out the on-boarding process of foreign merchants/e-commerce marketplaces/ entities providing payment aggregator services abroad in compliance with the RBI’s PA-CB Circular and this merchant on-boarding policy that has been approved by its Board of Directors.
In addition to the standard process for onboarding that is followed by Adyen India for its domestic merchants in India, for the foreign merchants/e-commerce marketplaces/ entities providing payment aggregator services abroad that wish to avail the Payment Aggregator Cross Border Import (PA-CB-I) solution from Adyen India, the following onboarding process shall apply:
Adyen will consider the country risk attributable to the domicile of the foreign entity and India’s foreign trade policies and trade sanctions at the time of on boarding.
Adyen will collect and validate documents, subject to local laws and regulations of the country of domicile of the foreign entity, and in accordance with the Master Directions on KYC issued by the Reserve Bank of India.
In case documents as provided in the KYC Master Directions are not available for legitimate reasons as the entity is located outside India, alternative equivalent documents shall be obtained and process (including relying on KYC documents stipulated or collected by other group entities that are regulated outside India) to identify, verify and screen the foreign entity, authorized signatories and ultimate beneficial ownership shall be undertaken.
Adyen will restrict the foreign entity availing the PA-CB-I product from selling goods/services that have a transaction price exceeding INR 25,00,000 (Indian Rupees twenty-five lakhs). As an additional measure, Adyen India will consider imposing transaction limits to ensure compliance as stipulated by the RBI from time to time.
Adyen India will collect the below documents from the foreign entity;
Tax-Residency Certificate (to the extent relevant) to ascertain the merchant’s tax residency status.
No Permanent Establishment (PE) Certificate to confirm that the merchant does not have any PE in India.
Form 10-F which is a self declaration form which may be collected in case the foreign merchant is desirous of availing benefits under any tax treaty.
Risk Categorisation of Customers onboarded through non-face-to-face KYC Adyen India currently follows a non-face-to-face KYC onboarding where it leverages the CKYCR, to fetch customer KYC data during the onboarding and collect additional documents (as the case may be) from its customers in accordance with this policy and related customer onboarding procedures. In light of the foregoing and in compliance with the requirements stipulated in the KYC Master Direction, Adyen India shall classify all customers onboarded via non-face-to-face KYC mode as “High Risk” customers. The risk classification can only be altered once the customers identity has been verified through a face-to-face KYC by either an in-person KYC verification or a Video KYC (live audio-video interaction with the customer).
Adyen India may additionally take such other risk based action at its sole discretion including but not limited withhold settlements to mitigate risk in case of non compliance or non delivery of information/documents required by Adyen India, by the merchant.
Enhanced Due-Diligence (EDD)
Adyen India shall conduct Enhanced Due Diligence (EDD) by ensuring that periodic reviews are performed at least annually, calculated from the effective date of classification as High Risk or the date of onboarding, as applicable.
Review of Policy
The Board of Directors of Adyen India would be responsible for reviewing and monitoring compliance with this Policy on a periodic basis, assisted by the Principal Officer and the Adyen Compliance Function.
This Policy shall be reviewed at least annually, or if significant regulatory changes occur to ensure its continuing suitability, adequacy, and effectiveness.
In the event of any conflict between the provisions of this Policy and applicable RBI guidelines or any other statutory enactments, rules, the provisions of the applicable RBI guidelines or statutory enactments, rules shall prevail over and automatically be applicable to this Policy and should be read in tandem with the provisions of the Policy. The relevant provisions of the Policy would be amended/modified in due course to make it consistent with the applicable law.
Any deviations from the procedures specified in this Policy shall be permitted only with the approval of the Principal Officer and/or Regulatory Compliance Counsel. However, no approvals shall be granted where such a deviation results in breach of any circular, direction, order or guidelines issued by any regulatory authority including the Reserve Bank of India.
Version Management
Version 1.0
Drafted/updated by
Regulatory (India)
Approved by
Adyen India Technology Services Private Limited Board (“Adyen India”)
Date of approval
June 1, 2021
Version 1.0
Drafted/updated by
Regulatory (India)
Approved by
Adyen India Board
Date of approval
May 17, 2022
Version 1.1
Drafted/updated by
Regulatory (India)
Approved by
Adyen India Board
Date of approval
May 08, 2023
Version 1.2
Drafted/updated by
Regulatory (India)
Approved by
Adyen India Board
Date of approval
April 22, 2024
Version 1.3
Drafted/updated by
Regulatory (India)
Approved by
Adyen India Board
Date of approval
June 6, 2025
Version 1.4
Drafted/updated by
Regulatory (India)
Approved by
Adyen India Board
Date of approval
November 20, 2025
Version 1.5
Drafted/updated by
Regulatory (India)
Approved by
Adyen India Board
Date of approval
June 09, 2026