The licensing challenge
For a fintech or BFSI business, licensing shapes business strategy. The choice of license can determine which products it offers, how it earns revenue, how directly it serves customers and how much it depends on regulated partners. It can open new markets or constrain growth.
Choosing the right route means looking beyond the immediate launch. A payments business may need RBI authorization, an investment platform SEBI registration, and an insurance intermediary IRDAI registration. Each comes with permissions, restrictions and ongoing obligations that must fit the business’s plans.
The key is to establish early whether the business needs its own license, which license supports its ambitions and where partnerships make sense. Getting this right before filing can prevent regulatory delays and costly restructuring.
Our framework
Ikigai Law guides fintechs through four stages of licensing across RBI, SEBI and IRDAI:
License fit: We identify the licenses the business needs and compare the available routes, including partnerships with licensed entities. We weigh each route’s permissions, restrictions, capital requirements and ongoing costs against the control and growth opportunities it offers.
Entity readiness: Once the route is chosen, we assess whether the applicant is ready to apply. We review its net worth, ownership, governance, management, infrastructure and operational capabilities, and help address gaps before filing.
Application readiness: We help build a clear, credible case for approval. We identify what the application should contain and how it should explain the business model, customer need, management capabilities and approach to risk. The narrative and supporting documents work together to demonstrate readiness to undertake the proposed activities.
Regulatory engagement: We advise on when to approach the regulator, what to put forward and how to frame the discussion. From initial engagement to application queries, meetings and inspections, we help clients explain their model, address concerns and respond consistently.
Applying the framework in practice
We have used this framework to help early-stage fintechs and established platforms choose licensing routes, prepare applications and plan for expansion.
RBI authorizations: Our work spans the lifecycle of a payments business. We guided a young fintech from launch to payment aggregator (PA) authorization. When it later expanded into a UPI-linked wallet and prepaid cards, it returned to us for support with PPI licensing. We also advised one of India’s highest-traffic consumer platforms on applying for a PA license, and a venture-backed platform serving small and mid-sized businesses on adding PPIs to its offering. Across these mandates, we assessed license fit and eligibility, prepared or reviewed applications, and developed policies aligned with the proposed operations and applicable RBI requirements.
SEBI registrations: We advised a growing investment platform on which products required SEBI registration and how to structure its business lines around those requirements. Our advice addressed the separation of regulated activities and the scope for launching new offerings within the boundaries of its registrations.
IRDAI registrations: We advised a global automotive business on the licensing options for offering insurance through its digital platform. We compared the insurance web aggregator and corporate agent routes, including their implications for entity structure, insurer partnerships and future expansion. This gave the client a clear basis for choosing the route that best supported its plans.
One framework, different regulatory routes
Across RBI, SEBI and IRDAI, the rules differ but the strategic questions remain: which license fits the business, whether the applicant is ready, how to present its case and when to engage the regulator. Addressing these questions early helps clients anticipate concerns, reduce avoidable queries and build a licensing strategy that supports growth.
Client-specific assessments remain confidential. The Ikigai Law team on these matters comprised Aparajita Srivastava, Astha Srivastava, Pallavi Sondhi, Akshat Tenneti and Samyukta Iyer.
For any queries, reach out to us at contact@ikigailaw.com
“Licensing decisions shape a business long after approval. We help clients choose a route that supports the product they are building today and leaves room for what comes next.”
— Astha Srivastava, Associate Partner
