Instrument 85 | E. RBI - Banking / Fintech / Payments / Financial AI

DIRECTIONIN FORCE

Reserve Bank of India (Authentication Mechanisms for Digital Payment Transactions) Directions, 2025

Reserve Bank of India, Department of Payment and Settlement Systems, under Section 18 read with Section 10(2) of the Payment and Settlement Systems Act, 20072025Banking

AI / PRIVACY / CYBER RELEVANCE

Core RBI payment-security control; it expressly ties authentication and risk-based profiling to DPDP Act compliance.

AI: ModeratePrivacy: HighCybersecurity: Very High

READ FIRST

  • Paras 4 and 6(a), Annexure-1 - domestic scope, two distinct factors and exemptions
  • Para 6(b)-(c) - dynamic factor except for card-present transactions, and factor independence
  • Para 7 - open access to authentication and tokenisation
  • Para 8 - risk-based additional checks
  • Para 9(b)-(c) - full compensation for non-compliant losses and DPDP adherence
  • Para 10(a) - non-recurring cross-border CNP validation when overseas merchant or acquirer requests authentication, plus BIN registration
  • Para 10(b) - risk-based mechanism for all cross-border CNP transactions
  • Para 3 - domestic compliance by 1 April 2026, cross-border provisions by 1 October 2026

PURVIEW

Sets principles for domestic digital payment authentication, with the exemptions in Annexure-1. Paragraph 6 requires at least two distinct factors, independence of factors, and a transaction-unique dynamic factor except for card-present transactions. Paragraph 7 requires open access to authentication and tokenisation services. Paragraph 8 permits risk-based additional checks using behavioural and contextual signals and exploration of DigiLocker for high-risk confirmations. Paragraph 9 requires robust deployment, full compensation for losses from non-compliant transactions and adherence to the DPDP Act, 2023. The domestic requirements do not generally apply to cross-border payments. Under paragraph 10(a), by 1 October 2026 card issuers must validate non-recurring cross-border card-not-present transactions where an overseas merchant or acquirer raises an authentication request, and register BINs with card networks. Paragraph 10(b) separately requires a risk-based mechanism for all cross-border CNP transactions by that date. Annexure-2 lists repealed circulars.

Classification and legal status. Directions RBI/2025-26/79, CO.DPSS.POLC.No. S 668/02-14-015/2025-2026 dated 25 September 2025; compliance due by 1 April 2026, and cross-border card provisions by 1 October 2026.

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Keywords

two factor authenticationadditional factor of authenticationOTPbiometricrisk based authenticationdigital paymenttokenisationcross-border card not present

Source note

RBI Directions dated 25 September 2025 reviewed (eight pages including Annexures 1 and 2).

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