Beyond SMS OTP: What RBI’s 2025 Authentication Directions Mean for Fintechs

RBI’s Authentication Mechanisms for Digital Payment Transactions Directions, 2025 mark the biggest change to Indian payment authentication since the card “additional factor of authentication” rules. The general compliance date was 1 April 2026, and the cross-border card-not-present requirement applies from 1 October 2026. If your stack still treats SMS OTP as the only second factor, it is time to revisit it.

What the directions require

  • Two distinct factors for every domestic digital payment, drawn from something you know, something you have and something you are
  • At least one dynamic factor that is unique to each transaction
  • Technology neutrality: SMS OTP is still allowed, but it is no longer assumed. Issuers can use app-based tokens, device binding, biometrics, passkeys and similar
  • Risk-based authentication: issuers may use behaviour, device and location signals to decide when to step up
  • Liability on the issuer if non-compliance leads to customer loss
  • Cross-border CNP: issuers must be able to validate non-recurring cross-border card-not-present transactions when the merchant or acquirer asks

Practical implications

For issuers and wallet providers

  • Map every payment journey (cards, UPI, net banking, wallets) to the factors it uses today, and flag any journey that relies only on SMS OTP
  • Prioritise device binding with in-app cryptographic signing or push approval. It is stronger and cheaper than SMS over time
  • Document your risk-based authentication logic, because auditors will ask how step-up decisions are made

For payment aggregators and merchants

  • Expect more frictionless-but-risk-scored flows and more step-up challenges on risky transactions. Test conversion impact early
  • Make sure your checkout handles issuer step-up gracefully, including timeouts and retries

For security teams

  • Threat-model the new factors: device binding can be undermined by rooted devices, overlay malware and screen sharing
  • Log authentication decisions in enough detail to reconstruct a disputed transaction, and keep them for at least 180 days in India per CERT-In

Bottom line

The directions reward investment in strong, app-based authentication and penalise inaction through liability. Treat them as a security upgrade programme, not a checkbox.

This article is a practitioner’s summary, not legal advice. Refer to the RBI directions for the authoritative text.


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