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RBI Digital Payment Security Controls (DPSC): Compliance Guide

10 min read·CISO · Payment Operations · DPO·March 2026

What the RBI DPSC Requires

The Reserve Bank of India’s Master Direction on Digital Payment Security Controls was issued in February 2021 and applies to:

  • Scheduled Commercial Banks
  • Small Finance Banks
  • Payment Banks
  • Credit Card issuing NBFCs
  • Prepaid Payment Instrument issuers

The DPSC establishes six control areas specifically addressing the security of digital payment systems and the personal financial data they process.

The Six Control Areas

§1 — Governance and Oversight

Payment entities must have:

  • A dedicated Board-level oversight mechanism for digital payment security
  • An executive responsible for digital payment security
  • Documented security policies for all digital payment channels
  • Annual review of security posture by independent assurance

§2 — General Controls for Digital Payments

Baseline security controls applicable across all payment channels:

  • Customer authentication: Minimum two-factor authentication for all transactions above prescribed limits
  • Transaction monitoring: Real-time monitoring with anomaly detection
  • Fraud management: Documented fraud detection, investigation, and resolution procedures
  • Customer notification: Real-time alerts for all transactions
  • Dispute resolution: Time-bound dispute resolution with documented procedures

§3 — Internet and Mobile Banking

For internet and mobile banking channels:

  • HTTPS/TLS 1.2 or higher for all sessions
  • Session timeout and re-authentication for idle sessions
  • Certificate pinning for mobile applications
  • Protection against common web vulnerabilities (OWASP Top 10)
  • Device binding and anomaly detection for mobile banking

§4 — Card Payments

PCI-DSS compliance is mandatory for all card-processing entities. Additionally:

  • EMV chip mandate for all new card issuances
  • Tokenisation for card-on-file storage
  • Dynamic CVV for high-value transactions
  • Geolocation-based fraud controls

§5 — AEPS and UPI

For Aadhaar Enabled Payment Systems and UPI:

  • UIDAI-prescribed biometric data handling protocols
  • Consent artefact storage for all AEPS transactions
  • Daily transaction velocity limits
  • Merchant risk categorisation

§6 — Prepaid Payment Instruments

For PPI issuers:

  • KYC documentation and verification standards
  • AML/CFT transaction monitoring
  • Expiry and dormancy management
  • Cross-border transaction controls

Intersection with DPDP Act

The DPSC’s data protection requirements directly overlap with DPDP Act obligations:

DPSC ControlDPDP Act ObligationOverlap
Customer authentication logs§8 — Security safeguardsShared control evidence
Transaction data retention§8(7) — Storage limitationRetention schedule alignment
AEPS consent records§6 — Consent frameworkConsent artefact requirement
Fraud investigation data§12 — Data principal access rightSubject access request scope
KYC data handling§8(2) — Data accuracyAccuracy and update obligations
Breach notification to RBI§8(6) — DPDP breach notificationCoordinated notification required

The CreativeCyber DPDP Assurance Platform’s native RBI DPSC control pack maps these six domains against DPDP Act obligations, allowing payment entities to conduct a unified gap assessment rather than two parallel exercises.

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