Merchant Onboarding Policy (Payments)

Last Updated On: 25th August 2025

1. Introduction

Nehat Tech Solutions Private Limited (the ‘Company’ or ‘our’ or ‘we’ or ‘us’) has put in place this Merchant onboarding Policy (the ‘Policy’) to ensure adequate due diligence is performed on the Merchants that intend to avail the services of the Company.

The Policy is to be read in conjunction with the KYC AML CFT Policy adopted by the Company.

2. Definitions

1. Merchant means individuals or legal entities with whom the Company has entered into a contract for the purpose of providing payment solutions.
2. Officially Valid Document (OVD) means the passport, the driving license, proof of possession of Aadhaar number, the Voter's Identity Card issued by the Election Commission of India, job card issued by NREGA duly signed by an officer of the State Government and letter issued by the National Population Register containing details of name and address.
3. Politically Exposed Persons (PEPs)means individuals who are or have been entrusted with prominent public functions in a foreign country e.g., Heads of States / Governments, senior politicians, senior government / judicial / military officers, senior executives of state-owned corporations, important political party officials, etc.
4. Equivalent e-document means an electronic equivalent of a document, issued by the issuing authority of such document with its valid digital signature including documents issued to the digital locker account of the customer as per rule 9 of the Information Technology (Preservation and Retention of Information by Intermediaries Providing Digital Locker Facilities) Rules, 2016.
5. Video based Customer Identification Process (V-CIP)”:A method of customer identification with facial recognition and customer due diligence by an authorised official of the Company by undertaking seamless, secure, live, informed-consent based audio-visual interaction with the customer to obtain identification information required for customer due diligence purpose, and to ascertain the veracity of the information furnished by the customer through independent verification and maintaining audit trail of the process

3. Merchant Onboarding Process

The Company will ensure the proposed process flow for facilitating its Receivable/ Payment Collection Services for existing Merchants as well as new Merchants:

1. Merchant managementMerchant Onboarding will entail a three-step process during the life cycle of the Merchant and will comprise of the following steps therein:
2. Onboarding / registration
   • Obtaining of the requisite business and website details from the Merchant either with self attested scanned copies of merchant documents via web/mobile interface or digitally verifying/obtaining equivalent e-documents with Aadhar based validation and e-signing by the merchant. (Refer to Annexure 1)
   • Verification and scrutinization of the information received and the requisite documents by the onboarding team and validation of authorized person(s) as prescribed standards and procedures including non face-to-face or V-CIP verifications.
   • Undertaking of various checks such as background, negative business list, PEP, restricted business list (Refer to Annexure 3), UN sanctions list, etc. using the information and documents provided
   • Granting of approval for onboarding of the Merchant by the Company upon satisfaction of checks and authenticity of the information / documents provided by the Merchant.
   • Agreement of the terms and conditions between both the parties i.e., the Company and the Merchant, and finalization of the commercials by way of executing a Merchant agreement.
   • Undertaking of the risk categorization of the Merchant onboarded (either low / medium / high category depending upon the type of business, any adverse / discouraging feedback etc.) post signing of the agreement
   • Registration of the Merchant upon successful completion of all the above steps and sharing of the activation details / credentials for login.
3. Continuous monitoring

   A registered Merchant will be continuously monitored and supervised by the Company in order to prevent any unlawful or malicious activity. Such evaluation and ongoing due diligence is typically based on risk categorization assigned to any Merchant or its business model, etc. and include checking the transaction history, refunds initiated, transaction volumes in line of business, transaction amount of the Merchant, scrutinizing the Merchant’s disputes, verifying Merchant URL from where the transactions are undertaken, detecting any spike in transactions, total chargebacks, monitoring the Merchant website for any unwarranted business, checking social media for any adverse comments on the Merchants, etc. These business rules for monitoring / identification vary depending on the risk category of the Merchant.

   Based on the indications/ alerts received as part of the monitoring activity, risk categorisation of the Merchant may be changed from low to medium or medium to high as the case may be if there is a need. This will also follow up with obtaining additional documents/ information from the Merchant. In some cases, the Company may also decide to terminate the agreement with the Merchant.

4. Exit / termination process of the Merchant agreement

Termination of the agreement with the Merchant can be initiated by either of the parties i.e., the Company or the Merchant upon giving prior notice to the other party. The exit / termination process of the Merchant can occur in two scenarios:

1. Termination requested by the Merchant
2. Company chooses to terminate the Merchant

1. Termination requested by the Merchant

   In case the Merchant wishes to culminate his contract with the Company, the same may be done by giving a notice to the Company. The Company assesses the account of the said Merchant and checks for any pending / outstanding dues. The Company also verifies any chargebacks / refunds pending on the Merchant’s account. Successful verification of the termination notice and the account of the Merchant will entail settlements of due with the Merchant and subsequent termination of the Merchant id.

2. The Company chooses to terminate the Merchant

   The Company at its own discretion can terminate the Merchant agreement with immediate effect in certain scenarios (listed below) and as deemed fit.

   • Merchant has indulged in a fraudulent activity; or
   • Merchant is involved in criminal or illegal activity; or
   • Merchant has misused the platform for collecting payments for any illegal / prohibited goods.

5. Review of Policy

The Company will periodically review and assess the Policy in light of any material changes in regulatory framework or for business or operational reasons and recommend changes, if any, to the Board. Any such updates/ changes to this Policy will be approved by the Board and communicated to the relevant Merchants/ staff/ stakeholders.

6. Annexure 1

General Information:

• Personal details: Name, email id, phone number, address;
• Business details: Legal business name, registered address, business address, website address, constitution, etc.;
• Banking details: Bank Name and address, Type of account and account no. etc.
• Tech related information;
• Financial information; and
• Declarations; if any.

List of KYC documents:

Below listed are the set of documents or *equivalent e-document and information collected and validated from the merchants.

*For collection of electronic equivalent of documents including ID Proof & Address Proof (PAN Account number, Aadhaar Number or any OVD), the company has opted for non-face-to-face OTP verification process where Merchants will receive a unique link via email channel on registered email id to authorize the company or technology partner.

Using the link, merchants will login to digilocker account using registered mobile or username or aadhar number followed by OTP generated on registered number and secret pin. On successful authorization, valid documents will be collected, issued by the issuing authority of such a document with its valid digital signature as per rule 9 of the Information Technology Rules, 2016. Alternatively customers will opt for V-CIP procedures for verification wherever applicable.

SOCIETY / TRUST / NGO
ID Proof & Address Proof	ID PROOF – PAN Account Number Certified copy of the Proof of possession of Aadhaar number or any OVD or the equivalent e-document thereof containing the details of identity and address
Business Proof	Any one document from the below list: Registration Certificate Trust Deed Bye Laws Affiliation of Entity in case of Health & Education sector
Bank Details	Bank Account Number and IFSC code
Other Documents	Any other documents including in respect of the nature of work/business/profession, financial status of the Merchant, or the equivalent e-documents thereof as may be required by the Company

Where the OVD furnished by the merchant does not have updated address, the following documents or the equivalent e-documents thereof will be deemed to be OVDs for the limited purpose of proof of address:

• Utility bill which is not more than two months old of any service provider (electricity, telephone, post-paid mobile phone, piped gas, water bill)
• Property or Municipal tax receipt
• Pension or family pension payment orders (PPOs) issued to retired employees by Government Departments or Public Sector Undertakings, if they contain the address
• Letter of allotment of accommodation from employer issued by State Government or Central Government Departments, statutory or regulatory bodies, public sector undertakings, scheduled commercial banks, financial institutions and listed companies and leave and license agreements with such employers allotting official accommodation

Note – The Company will ensure to obtain the OVD with current address updated within a period of three months of receiving the above documents.

7. Annexure 2

List of documents including in respect of the nature of work/business/profession of the merchant

Industry Type	Regulated Bodies
International Travel & Hotel	IATA (International Air Transport Association)
Education institutes	Board Grant Certificates
University / Education Sector	UGC Certificate / ICSC / CBSC / AICTE
Pharmacy	Drug License
Herbal/Ayurvedic medicines	Drug Comptroller of India
OTC Products (Ayurveda, Health Supplements)	FSSAI License
International delivery	Merchant should have a valid regulatory license for international deliveries
Advisory Firm (Stock Market) Venture Capital Fund Co Merchant Banking Co	SEBI Certificate
Food & Beverages Industry	FDA (Food and Drug Administration) / FSSAI Certificate
University / Education Sector	UGC Certificate / ICSC / CBSC / AICTE
Airlines & Aircraft Maintenance related services	DGCA Certification (Directorate General of Civil Aviation)
Internet Service Provider	DOT (Department of Telecommunications)
Web Host / Domain Seller	PCI-DSS
Paper / Gift Vouchers Bank / NBFCs or Money Lending Prepaid / e-wallet, Cash / Smart card	RBI Certification
FOREX	FEMA Registration, FFMC Certificate
NGO	12A, 80G Certificate
12A, 80G Certificate	Finance Support for Society
Gold, Silver Merchants	Finance Support for Society
Insurance	IRDA
Mutual Fund Broker	AMFI
Internet Service Provider	FDOT
SMS/Email/Telemarketing	TRAI
Utility Services	BBPS License
Builders/Construction/Contractor/ Brokers (Real Estate)	RERA Registration certificate

8. Annexure 3

List of Restricted businesses:

1. Adult Goods & Services - Pornography, other sexually suggestive materials; Escort/Prostitution services. Personal Massagers/sex toys.
2. Alcohol or Alcoholic beverages.
3. Body Parts, including organs - Live, cultured, preserved or from cadaver. This Prohibited Products And Activities List Is Not Exhaustive And Finite And Enkash May At Any Time Include Other Products Into This List Or Change The List Without Your Consent.
4. Bulk marketing tools - email lists, software or other products enabling unsolicited emails/sms.
5. Cable TV descramblers & black boxes intended to obtain cable & satellite signals for free.
6. Child Pornography in any form.
7. Copyright unlocking devices - Mod chips or other products designed to circumvent copyright protection.
8. Copyrighted Media - unauthorized copies of books, music, movies and other licensed or protected materials.
9. Copyrighted Software which includes unauthorized copies of software, videogames and other licensed or protected materials including OEM or bundled software.
10. Counterfeit and unauthorized goods - replica or imitation of designer goods; fake autographs; counterfeit stamps.
11. Drugs & Drug paraphernalia which includes illegal drugs and drug accessories including herbal drugs.
12. Drug test circumvention aids, includes drug cleansing shakes, urine test additives and related items.
13. Endangered species - includes plants, animals or other organisms.
14. Gambling/Betting - lottery tickets, sports bets, enrolments in online gambling sites.
15. Government ID or documents which includes fake IDs, passports.
16. Hacking & Cracking materials which includes manual, how-to-guides, equipment enabling illegal access to software servers or protected property.
17. Illegal goods and goods/services promoting/enabling illegal acts.
18. Miracle cures, which are marketed as quick health fixes.
19. Offensive goods, which includes literature, products and other materials that defame or slander any person or group of person, encourage violent acts, promote intolerance or hatred.
20. Offensive goods, crime which includes crime scene photos or items, such as personal belongings associated with criminals.
21. Prescription drugs or herbal drugs of any kind of online pharmacies which includes drugs / other products requiring a prescription by a recognised & licensed medical practitioner in India or anywhere else.
22. Pyrothenic devices & hazardous materials which includes firework & other toxic/radioactive goods.
23. Regulated goods, regulated by government agency.
24. Securities, which includes stocks, bonds, mutual funds or related financial products or investments.
25. Tobacco & cigarettes, chewing tobacco and related products.
26. Traffic devices which includes radar detectors / jammers, license plate cover, traffic signal changers and related products.
27. Weapons which include knives, brass knuckles, gun parts and other armaments.
28. Wholesale currency which includes discounted currencies or currency.
29. Live animals or animal parts / products.
30. Multi-level Marketing schemes / Pyramid / sites using matrix scheme approach.
31. Any intangible goods and services or aggregation/consolidation business.
32. Drop-Shipped Merchant.
33. Web based telephony/e-mail/sms/fax/calling cards/bandwidth/data transfer or allied services.
34. Crypto or Crypto based services.
35. Any act services product people entity place country defined illegal/Sanctioned or in negative list by RBI or other regulators.
36. DMT
37. Money Transfer Services/Card To Cash
38. Any other service product activity described as illegal as per RBI or other regulators.
39. Violation of any of the Enkash terms of use.
40. WMD (Weapon of mass destruction)
41. Drop Shipping
42. Illegal arms trading
43. Smuggling
44. Child abuse
45. Human trafficking
46. Pornography
47. Hawala
48. Organs trading
49. Extortion
50. Illegal trading of animals
51. Illegal drugs supply and handling
52. Mystery Boxes/Get Risk Schemes/Betting
53. Gaming LOB where company type is Individual or Sole proprietor.