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RBI readiness check for bank apps

Eight controls Indian banks are asked about, from SIM binding to the reasons that reach the FRM. Mark the ones your bank runs today; each gap shows the rule it touches, with its date, status and source, and the DeepID module that supports it. A gap is not a breach.

4 min read7 sources

In this guide

The check

Mark each control “In place” or “Gap”. Nothing is scored, counted or sent anywhere; the check runs in your browser. The full register below carries the same facts for reading without it.

  1. SIM binding

    The account works only from the SIM it was registered on.

    Not marked
  2. Device binding

    One registered phone per customer, checked in every session.

    Not marked
  3. Factors beyond SMS OTP

    SMS codes can be phished, forwarded or read by APK malware.

    Not marked
  4. Risk-based checks at payee and payment

    Checks at the new payee and the payment, not only at login.

    Not marked
  5. Cooling period after a new device or payee

    Lower limits for a while after a new phone, SIM or payee.

    Not marked
  6. Scam signals in the session

    An active call, a shared screen or a dictated payee while money moves.

    Not marked
  7. Mule detection

    Spotting accounts that receive stolen money and pass it on.

    Not marked
  8. Reasons sent to the FRM

    Every hold, step-up or allow arrives with its reasons.

    Not marked

Nothing is submitted or counted. The check runs in your browser, and a gap is not a breach.

How the check is built

Each control is something an Indian bank is asked about by a regulator, a payments body or an auditor. Each is mapped to the rule it touches most directly, with its date, its status and a public source, and to the DeepID module that supports it.

The status matters. Five of the rules are in force, one applies from 1 January 2027, one is a discussion paper that is not final, and one is an initiative banks are asked to adopt rather than a direction. A gap against a proposal is a question for your roadmap, not a finding.

The full register

ControlRule it touchesStatusDeepID module
SIM bindingThe account works only from the SIM it was registered on.UPI device and SIM bindingNPCICurrentUPI onboarding needs an active SIM linked to the bank account.NPCI (UPI user onboarding: product overview, opens in a new tab), as of Oct 2026In forceSIM and device binding
Device bindingOne registered phone per customer, checked in every session.UPI device bindingNPCICurrentUPI onboarding binds the app to the device.NPCI (UPI user onboarding: product overview, opens in a new tab), as of Oct 2026In forceDevice intelligence
Factors beyond SMS OTPSMS codes can be phished, forwarded or read by APK malware.Authentication Directions, 2025RBIIn force 1 Apr 2026SMS OTP remains valid; newer factors are encouraged.RBI (Press release: directions on authentication mechanisms for digital payment transactions, opens in a new tab), Sep 2025In forceSilent network verification
Risk-based checks at payee and paymentChecks at the new payee and the payment, not only at login.Authentication Directions, 2025RBIIn force 1 Apr 2026Issuers may add risk-based checks beyond two factors.RBI (Press release: directions on authentication mechanisms for digital payment transactions, opens in a new tab), Sep 2025In forceOne decision, with reasons
Cooling period after a new device or payeeLower limits for a while after a new phone, SIM or payee.Discussion paper on payment safeguardsRBIApr 2026, not finalFloats a one-hour hold on payments of ₹10,000 or more. A proposal, not a rule.The Paypers (RBI proposes transaction delays and senior-citizen protections to combat digital payment fraud, opens in a new tab), Apr 2026, press reportProposalSIM and device binding
Scam signals in the sessionAn active call, a shared screen or a dictated payee while money moves.Amendment directions on customer liabilityRBIApplies 1 Jan 2027Zero customer liability where the bank was negligent, as reported.RBI (Press release: amendment directions on the review of the framework of limiting customer liability in digital transactions, effective 1 January 2027, opens in a new tab), Jun 2026; MediaNama (RBI’s final amendment directions on limiting customer liability in digital transactions, in effect from 2027, opens in a new tab), Jun 2026, press reportApplies laterScam signals
Mule detectionSpotting accounts that receive stolen money and pass it on.MuleHunter.AI adoptionRBIH and the Ministry of FinanceAsked of banks since Dec 2024Banks are asked to adopt RBIH’s mule-detection model. An initiative, not a direction.Outlook Business (Finance Ministry asks banks to use MuleHunter.AI to check digital fraud, opens in a new tab), Dec 2024, press reportGuidance or initiativePayee and mule graph
Reasons sent to the FRMEvery hold, step-up or allow arrives with its reasons.Customer-liability circular, 2017RBISince Jul 2017The burden of proving customer liability lies with the bank.RBI (Customer protection: limiting liability of customers in unauthorised electronic banking transactions, opens in a new tab), Jul 2017In forceOne decision, with reasons

DeepID supports compliance with these rules. It never guarantees it, and claims no regulator approval.

What to do with a gap

  • Read the rule’s own text first. The sources above link to the regulator where a primary text exists, and mark the rest as secondary.
  • For a control in force, decide what your record of a decision must show: the signals, the action, the reasons and the message the customer saw.
  • For the control that applies from 1 January 2027, see what changes for banks and the checklist for the weeks before.
  • Bring the gaps to a demo with the journey you would start with, or begin with a free retrospective on your own closed cases.

Sources

Secondary sources are news or trade reporting of a rule or figure. Check the regulator’s own text before relying on them. Nothing in this guide is legal advice.

  1. NPCI (opens in a new tab), as of Oct 2026UPI user onboarding: product overview
  2. RBI (opens in a new tab), Sep 2025Press release: directions on authentication mechanisms for digital payment transactions
  3. The Paypers (opens in a new tab), Apr 2026, press reportRBI proposes transaction delays and senior-citizen protections to combat digital payment fraud
  4. RBI (opens in a new tab), Jun 2026Press release: amendment directions on the review of the framework of limiting customer liability in digital transactions, effective 1 January 2027
  5. MediaNama (opens in a new tab), Jun 2026, press reportRBI’s final amendment directions on limiting customer liability in digital transactions, in effect from 2027
  6. Outlook Business (opens in a new tab), Dec 2024, press reportFinance Ministry asks banks to use MuleHunter.AI to check digital fraud
  7. RBI (opens in a new tab), Jul 2017Customer protection: limiting liability of customers in unauthorised electronic banking transactions

More guides.

Each one dated, with every rule and figure cited to its source.

Start with sign-up, login or payments.

Pick one, test it on your own traffic before you commit, and add the others on the same SDK when you’re ready.