Digital Threat Report 2024

Digital Threat Report 2024 For The BFSI Sector: Key Highlights

Introduction To The Digital Threat Report 2024

The financial sector in India is changing fast. With digital payments, embedded finance, and cloud-based systems becoming the norm, banks and financial institutions are moving quickly to adopt new technologies. But that progress comes with risk.

The Digital Threat Report 2024, produced jointly by the Indian Computer Emergency Response Team (CERT-In), Cyber Security Incident Response Teams (CSIRT-Fin), and SISA, clearly outlines the scale of those risks. It offers a detailed look at how cybercriminals are adapting their tactics, the vulnerabilities most commonly exploited, and where organisations continue to fall short, often despite significant investment in cybersecurity.

The Digital Threat Report 2024 was launched by Secretary, Department of Financial Services, Ministry of Finance, Shri M Nagaraju and Secretary, Ministry of Electronics and Information Technology, Shri S Krishnan, along with the Director General, Computer Emergency Response Team (CERT-In), Dr Sanjay Bahl and the Founder and CEO, SISA, Dharshan Shanthamurthy.

This first-of-its-kind report arrives with some striking numbers. The average cost of a data breach globally in 2024 has hit $4.88 million, with the figure in India at $2.18 million, up 10% from last year. In just the first six months of the year, phishing attacks in India alone rose by 175%.

The report also makes clear that the most serious risks no longer come from brute-force attacks. Instead, cybercriminals are finding their way into supply chains, cloud misconfigurations, weak API security, and, in some cases, deepfake-based impersonations of senior staff. Identity theft and session hijacking have become more precise and convincing.

Understanding The Urgency For Cybersecurity In The BFSI Sector

Cyber threats in the BFSI sector are no longer theoretical or edge-case scenarios. They are real, frequent, and often quietly destructive. The Digital Threat Report 2024 opens with a stark reminder—this is not a future problem. It’s already happening.

Banks, insurers, payment platforms, and fintech companies are under continuous pressure to deliver seamless digital experiences. That shift has brought significant operational gains, but it has also widened the attack surface dramatically. Every API call, every third-party plugin, every cloud-hosted data lake has become a potential point of entry.

Crucially, these incidents are not the result of wildly sophisticated zero-day exploits. In many cases, they stem from basic, preventable lapses. Misconfigured cloud storage, hardcoded credentials, poor session management, and lax controls around dormant accounts continue to give attackers an easy way in. The use of MFA, often seen as a silver bullet, is being actively circumvented through session hijacking, deepfake-enabled impersonation, and brute-force attacks on push notifications.

The sector’s complexity adds another layer of risk. A payment gateway depends on a network of vendors, infrastructure partners, and service APIs. A breach at any point in that chain can ripple outwards. The Digital Threat Report illustrates this with case studies where supply chain compromises and insider manipulation went undetected for months, in some instances resulting in reputational damage and silent financial loss.

There’s also the issue of visibility. Many institutions are running dozens of cybersecurity tools, yet still struggle to see what’s happening in real time. According to the report, the average organisation globally now uses between 64 and 76 security products, but breaches remain common. Tools, without coordination and clarity, aren’t enough.

Perhaps the most telling insight in the report is this: some of the hardest-hit institutions were considered mature from a compliance standpoint. They had policies, frameworks, even certifications—but they lacked operational readiness. Threats moved faster than internal processes could respond.

In short, the problem is not a lack of effort—it’s a misalignment of effort. Security has often been treated as a technical function when in fact it cuts across governance, culture, technology, and accountability. What the Digital Threat Report calls for is not just better tools, but a sharper focus. Awareness that cyber resilience isn’t about blocking every attack. It’s about ensuring that when something does go wrong—and it will—the organisation can detect it quickly, contain it effectively, and recover without losing trust.

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Key Takeaways From The Threat Scenario

1. Breaches Are Becoming More Expensive, And More Routine

The average cost of a data breach globally in 2024 is now estimated at $4.88 million, while in India, it stands at $2.18 million—a 10% increase over the previous year. These figures reflect not only rising attacker sophistication but also systemic delays in detection, response, and recovery.

The report notes that while many institutions have invested in advanced tooling, a lack of integration, coordination, and clarity in response planning continues to compound post-breach damage.

2. Phishing, BEC, And Identity Theft Have Grown Sharper And More Scalable

  • India experienced a 175% surge in phishing attacks in H1 2024 compared to the same period last year.
  • Phishing remains the initial infection vector in 25% of recorded incidents in the BFSI sector.
  • 54% of BEC (Business Email Compromise) cases investigated involved pretexting, a technique where attackers construct plausible backstories to deceive employees.
  • Generative AI is enabling attackers to craft grammatically flawless phishing emails, removing traditional red flags.
  • Deepfake-enhanced impersonations have enabled executive-level fraud, bypassing manual verification protocols.

The report cites the growing availability of “deepfake-as-a-service” platforms and malicious LLMs such as WormGPT and FraudGPT, which are being used to automate social engineering, write malware, and impersonate decision-makers with startling realism.

3. Credential Theft Remains A Central Strategy

  • Attackers are acquiring credentials through a combination of phishing, information-stealing malware, and dark web purchases.
  • Once acquired, credentials are being used to compromise SSO platforms, VPNs, SaaS applications, and email systems.
  • Many attacks bypass multi-factor authentication through session hijacking or exploiting broken object-level authorisation (BOLA) flaws in APIs.

One critical observation from the report: SaaS platforms often include sensitive customer information in URLs, which, when paired with stolen session tokens, can lead to broad data exposure with minimal effort.

4. Cloud Infrastructure Is Misconfigured And Actively Targeted

Cloud misconfigurations are listed as a recurring point of failure:

  • Exposed storage buckets, default passwords, and poor IAM (Identity and Access Management) policies are frequently observed.
  • Threat actors are exploiting cloud tokens exposed in web source code, targeting AWS, Azure, and GCP environments.
  • The average time to exploit a known cloud vulnerability post-disclosure is less than eight days, in some cases just hours.

The report features multiple cases, including one where a fintech’s XSS vulnerability in a rich text editor allowed the injection of webshells, ultimately giving attackers access to cloud-stored client data via Amazon S3 buckets.

5. API Weaknesses Are Enabling Payment Fraud

The BFSI sector’s rapid API adoption has created efficiency, but also exposure.

  • Hardcoded API keys, reused credentials across environments, and predictable authorisation patterns are key issues.
  • One documented case saw attackers conduct a replay attack, where they successfully mimicked legitimate bank transfer requests through APIs, executing unauthorised payments while leaving wallet balances untouched.
  • Cross-Origin Resource Sharing (CORS) misconfigurations were also cited as enabling unauthorised access from untrusted domains.

6. Supply Chain Attacks Are Multiplying

The MOVEit and GoAnywhere breaches are referenced in the report to illustrate the rising threat posed by third-party software providers:

  • CL0P ransomware group targeted these platforms, impacting thousands of organisations globally.
  • Open-source libraries like XZ Utils were compromised, with attackers introducing a backdoor affecting multiple Linux distributions.
  • Malicious libraries were uploaded to repositories such as PyPI and GitHub, disguised as legitimate tools to gain developer trust.

These attacks allowed adversaries to introduce vulnerabilities into production systems during routine updates, without direct access to the target institution.

7. Vulnerability Exploitation Has Become Time-Critical

  • The average time from vulnerability disclosure to exploitation has dropped to under 8 days, with some exploits observed within a few hours of public release.
  • The report notes a 180% increase in incidents involving known vulnerabilities, particularly those affecting internet-facing applications and services.

8. Attacks Are Now Systemic, Interlinked, And Often Undetected

Modern cyberattacks no longer rely on a single point of failure. They are orchestrated across:

  • Cloud misconfigurations (e.g., S3 exposure),
  • Insider manipulation (e.g., of dormant accounts and card systems),
  • APIs with BOLA flaws, and
  • Phishing via AI-generated content.

Each vector reinforces the next. In several cases, the attackers moved laterally from one subsystem to another, remaining undetected for extended periods, at times over two years, as in the insider threat case cited in the report.

The Rise Of Social Engineering And Credential Theft

Social engineering, once the domain of crude phishing emails and low-effort impersonations, has become one of the most sophisticated and effective cyberattack strategies used against the BFSI sector. According to the report, its impact is now amplified by automation, AI-generated content, and deepfake technologies, turning what was once a manual con into a scalable, almost industrialised method of breach.

Social Engineering Is Now Personalised And Scalable

The report identifies Business Email Compromise (BEC) and phishing as the most persistent forms of social engineering in financial services:

  • 54% of BEC incidents analysed involved some form of pretexting—that is, attackers creating plausible narratives to coax employees into taking action.
  • These attacks are often backed by data scraped from social media, public records, or even prior breaches, allowing adversaries to mimic tone, internal language, and relationship dynamics.

The role of AI and Large Language Models (LLMs) is critical here. Attackers are now generating context-aware phishing messages that are grammatically correct, free of typographical cues, and virtually indistinguishable from legitimate internal communication.

Moreover, AI-generated phishing is no longer limited to email. The report cites a worrying rise in the use of NLP-driven chatbots deployed via SMS, social media, and browser-based applications. These chatbots simulate real customer service agents and extract information in real time, without the need for malware or code injection.

Deepfakes Have Moved From Novelty To Threat

The convergence of social engineering with deepfake technology represents a substantial risk for the BFSI sector. The report details cases in which:

  • Synthetic audio and video were used to impersonate executives, authorise fund transfers, or approve system access.
  • “Deepfake-as-a-service” platforms made such attacks more accessible, reducing the technical barrier for cybercriminals.
  • MFA protections were bypassed not through code, but by convincing a human to approve a fraudulent request, based on a realistic video or voice prompt.

Credential Theft: Still Central, But Smarter

Credential theft continues to be a key enabler of more complex attacks. The report outlines three primary sources:

  1. Phishing, enhanced by AI and social engineering
  2. Information-stealing malware, often distributed via seemingly benign documents
  3. Dark web marketplaces, where stolen credentials are sold or traded

Once obtained, these credentials are used to access:

  • Single Sign-On (SSO) platforms
  • VPNs
  • Email accounts
  • SaaS applications
  • Internal admin dashboards

A recurring issue flagged in the report is the lack of session control and token invalidation. Many systems allow sessions to persist even after logout or inactivity, making them vulnerable to token theft and reuse.

The report also details how SaaS applications often include customer-specific information in URLs, which, when paired with valid session cookies, gives attackers unfettered access to highly sensitive data, without triggering any alerts.

Multi-Factor Authentication Is Being Circumvented

While MFA adoption has grown, attackers have adapted accordingly. Common techniques now include:

  • Session hijacking: Stealing cookies or tokens to bypass the need for real-time authentication
  • Push notification fatigue: Bombarding users with repeated MFA prompts until they approve one out of frustration
  • Deepfake impersonation: Tricking users into handing over OTPs or approvals based on fake authority figures
  • Broken Object-Level Authorisation (BOLA): Exploiting flaws in how APIs validate user roles, often enabling bypasses of OTP flows entirely

In one documented case, attackers used BOLA to access an OTP-protected endpoint on a payments platform, rendering the OTP process effectively meaningless.

Tactics Are Evolving Faster Than Controls

The report makes it clear: defensive strategies based on known tactics are no longer sufficient. The line between technical breach and psychological manipulation is now blurred. Attacks increasingly combine:

  • Technical vulnerabilities (e.g., cloud misconfigurations),
  • Behavioural exploitation (e.g., urgency emails from fake CEOs), and
  • Credential reuse or session replay techniques

The implication for financial institutions is twofold: first, they must monitor who is accessing systems just as closely as what is being accessed. Second, they must anticipate that some attacks will look entirely legitimate at the surface level.

AI As An Enabler And Exploiter

Artificial Intelligence has become a tool of contradiction in cybersecurity—empowering defenders while simultaneously equipping attackers with speed, precision, and scale previously out of reach. What emerges in the Digital Threat Report 2024 is not just concern about AI’s misuse, but clear evidence of how it’s already being exploited in live incidents—some targeting high-trust systems within India’s BFSI sector.

For banks, insurers, fintechs and their customers, this dual use of AI means two things: the line between genuine and malicious interaction is fading, and the time window to detect deception is narrowing.

AI Is Being Used To Bypass Traditional Security Layers—Not Just Humans

While much attention has been paid to AI-generated phishing emails, the report highlights a more technical and immediate threat: AI-generated code that exploits cloud, API, and application vulnerabilities in real-time.

  • The rise of LLM-assisted vulnerability discovery has allowed attackers to scan large codebases and uncover exploitable endpoints faster than ever before.
  • Tools such as FraudGPT and WormGPT are now trained specifically on software documentation and vulnerability databases like CVE and OWASP, helping attackers generate tailor-made payloads against exposed infrastructure.
  • These models are even capable of modifying exploit scripts on the fly based on target environment responses, replicating what once took hours of manual testing.

For customers, this means that attacks now require less reconnaissance and less trial-and-error. A small oversight—an outdated web application firewall, or a misconfigured API—can now be exploited at scale using a few lines of automated LLM-generated logic.

Threat Actors Are Training AI On Organisational Structures

One of the more subtle, but significant developments outlined in the report is that attackers are increasingly feeding AI systems with organisational metadata to model trust relationships and simulate internal authority.

  • Public data from LinkedIn, Glassdoor, company websites, and press releases is being used to construct synthetic internal maps of organisations.
  • These are then used to inform phishing campaigns, fake escalations, or impersonation attempts that mirror actual chains of command.
  • In one reported incident, attackers impersonated an AVP in a lending institution using accurate job history and internal jargon gathered from social data and insider leaks. The deception wasn’t flagged for three days.

Model Poisoning And AI-Driven Surveillance Are Underestimated Risks

The report flags the emerging threat of AI model poisoning, particularly in BFSI environments where machine learning is increasingly used to detect fraud or assess creditworthiness.

  • Adversaries are actively testing the limits of feedback loops in ML systems—injecting false behavioural signals to train fraud detection models into underestimating real risk.
  • In open feedback environments (e.g., customer sentiment models, behavioural risk engines), a well-orchestrated campaign could allow malicious inputs to bias the model toward false negatives.
  • The report draws attention to this in the context of AI-based onboarding systems and alternative credit scoring platforms, where model trust is silently eroded over time.

For customers, this means decisions about loan approval, account flags, or fraud alerts could be quietly manipulated, without either side being immediately aware.

Synthetic Identity Generation Is Being Used To Open Fraudulent Accounts

The report draws attention to a growing phenomenon: synthetic identity fraud powered by AI tools that assemble highly plausible—but entirely fictitious—digital identities.

  • These identities are built using publicly available datasets (e.g. Aadhaar data leaks, voter records, dark web dumps) and filled out with fabricated personal histories, fake biometric data, and AI-generated photographs.
  • Using these, attackers are able to pass eKYC checks, generate credit activity, and even obtain legitimate documents from secondary authorities before disappearing entirely.
  • These accounts are then used for laundering money, accessing promotional credit products, or acting as mule accounts in broader fraud schemes.

Customers are often unaware that their compromised details are being used as “fragments” in synthetic identity creation, especially in rural or semi-urban segments where digital trail verification is less stringent.

AI Is Accelerating Financial Infrastructure Mapping For Targeted Breaches

Finally, the report documents how attackers are deploying AI to build real-time maps of institutional digital infrastructure—essentially creating a virtual blueprint of how a bank or insurer’s tech stack is laid out.

  • By scanning headers, DNS data, TLS certificates, public code repositories, and employee tech blogs, threat actors can build detailed models of what software is deployed where, and what its likely vulnerabilities are.
  • These AI-driven scans are run continuously, with results compared over time to detect changes in infrastructure posture, opening the door for just-in-time attacks after patch rollbacks, migrations, or product launches.

This kind of digital surveillance, automated and persistent, means that even minor updates can attract immediate attacker attention, especially in institutions that fail to update WAF rules or reconfigure access controls after change deployments.

Takeaway For Institutions And Customers Alike

AI is no longer a theoretical disruptor in cybersecurity. It is already being weaponised across the attack lifecycle: discovery, deception, exploitation, persistence, and evasion.

For institutions, this means re-evaluating what “real-time defence” actually looks like. For customers, it means being aware that not all fraud starts with negligence—some now begin with a perfect replica of your digital footprint, constructed by systems designed to deceive.

Supply Chain Attacks And Third-Party Risks

For years, cybersecurity strategies in BFSI have focused on perimeter control—keeping external threats at bay. But as financial institutions adopt cloud-native tools, outsourced operations, embedded finance APIs, and open banking frameworks, the perimeter has shifted. It now extends across a vast, interconnected network of vendors, processors, code libraries, and software dependencies.

According to the report, this extended chain of trust has become one of the most actively exploited attack vectors—not because of its visibility, but precisely because of its invisibility.

Trusted Software Is Now A Vector For Silent Breach

The report flags multiple high-profile examples of compromised third-party tools resulting in widespread exposure:

  • The MOVEit Transfer breach, orchestrated by the CL0P ransomware group, affected several Indian BFSI entities indirectly via vendors that relied on the vulnerable file transfer utility.
  • Similarly, GoAnywhere MFT, another widely deployed managed file transfer solution, was exploited in early 2024 to steal sensitive records from downstream BFSI service providers.
  • In both cases, the exploit chain did not originate inside the financial institutions themselves. Instead, it passed through trusted service providers handling data movement or regulatory reporting.

Open Source Is Ubiquitous, But Rarely Audited

The report issues a pointed warning about open-source software in financial applications:

  • Code libraries like XZ Utils, compromised in early 2024 via a backdoor planted in a widely used Linux compression package, serve as a reminder that even core infrastructure is not immune to manipulation.
  • Developers working within BFSI projects often pull libraries from public repositories (e.g., GitHub, PyPI) without verifying integrity or digital signatures.
  • The XZ attack was particularly dangerous because the backdoor was introduced by a trusted contributor over the course of multiple commits across two years, highlighting the patience and planning behind supply chain operations.

This creates a dual risk: institutions unknowingly deploy tainted code into production systems, and attackers exploit that code only after it’s deeply embedded in the transaction pipeline.

API Aggregators And Embedded Finance Platforms Are Emerging Risks

India’s fintech ecosystem is increasingly reliant on API aggregators, account aggregators, and KYC processors—many of which have direct access to user data, payment tokens, or transaction approval mechanisms.

The report identifies risks stemming from:

  • Poorly secured API gateways, where misconfigured authentication policies allow unauthorised access to sensitive data or functionality.
  • Inconsistent patching policies across vendors are leaving outdated components in production environments.
  • Insufficient audit trails make it difficult to attribute unusual behaviour to a specific vendor action.

In one case study, a third-party identity verification platform, integrated via API with a digital NBFC, was exploited using a token replay technique that allowed attackers to submit stale authentication tokens and complete KYC checks under false identities.

Vendor Risk Management Is Often Superficial

While most BFSI organisations have vendor onboarding and audit frameworks, the report points to gaps in enforcement, frequency, and scope:

  • Security questionnaires are often generic and self-attested, with little verification.
  • Annual audits are insufficient in fast-evolving attack environments, especially when codebases and access controls change weekly.
  • Many firms lack visibility into fourth-party dependencies—vendors of vendors—who may hold system-level access or process sensitive customer information.

The challenge, as the report outlines, is not merely identifying risk, but quantifying it and aligning it to real business impact.

Consequences For Customers: Silent Exposure

From a customer’s standpoint, these breaches are largely invisible until it’s too late. Sensitive data may be accessed, accounts manipulated, or transactions interfered with, without any breach occurring within the customer’s bank itself.

This decoupling of compromise from immediate visibility makes response slower and trust erosion harder to contain. Moreover, customers have no visibility into which third-party tools their financial service provider uses, or how rigorously they’re monitored.

Recommendations Emphasised In The Report

The Digital Threat Report offers a few key directives for BFSI firms:

  • Implement Software Bill of Materials (SBOM) for all production dependencies
  • Establish continuous vendor monitoring, not just point-in-time audits
  • Require code integrity checks and digital signing for third-party libraries
  • Ensure zero-trust policies extend to vendors and API partners
  • Classify third-party services based on data access and enforce differentiated risk controls

Sectoral Defence – Observations Across Layers

Through a series of simulated attacks, incident response reviews, and forensic audits, the report reveals how security controls are implemented in reality, not how they are written in policy.

Application Security

Despite sector-wide adoption of microservices and API-first architecture, application-layer security remains patchy. The report highlights that authorisation logic is often enforced at the user interface level but inconsistently applied at the API layer, creating exploitable gaps in back-end enforcement. Several banking and lending applications exposed sensitive data such as PAN numbers, contact information, or KYC metadata through unsecured endpoints.

In many instances, encryption was either absent or poorly implemented. Sensitive user inputs—particularly those related to verification steps—were not consistently masked in transit. The most common oversight was the exposure of internal API keys or session tokens in front-end code, which allowed attackers to replay requests or modify session variables during testing.

Identity And Access Control

Control over digital identities, especially internal roles and service accounts, continues to be a weak link. The report finds repeated use of over-permissioned roles, including admin-level access granted to test accounts and expired vendors. In several simulated intrusions, red teams were able to gain persistent access via dormant accounts that had not been deactivated after a contractor’s exit.

Session management policies, while defined in internal documentation, were rarely enforced rigorously. Attackers exploited long-lived tokens, reused credentials between UAT and production environments, and, in some cases, leveraged a lack of session invalidation after logout to persist across application layers. Multi-factor authentication, though present on public-facing platforms, was notably absent from internal admin portals and dashboards, exposing a major surface of attack.

Cloud And DevSecOps Exposure

The report is especially critical of cloud deployment hygiene. While most BFSI firms had moved to hybrid or multi-cloud infrastructure, many had failed to configure storage and compute permissions correctly. Common findings included publicly accessible S3 buckets, unencrypted backups, and secrets hardcoded into deployment scripts.

DevOps practices often lag behind the security expectations placed on live infrastructure. CI/CD pipelines, which should act as security gatekeepers, were often configured without runtime testing for vulnerabilities. More concerningly, most institutions had no automated enforcement of security policy at the code commit level, leaving misconfigured infrastructure-as-code (IaC) files to propagate into production.

Network Segmentation And Monitoring

In terms of network architecture, the report notes a reliance on traditional perimeter security without adequate internal segmentation. In the event of a breach, attackers were often able to move laterally across environments with minimal resistance. Logs, where available, were typically fragmented between identity systems, cloud platforms, and network firewalls, making effective correlation and detection difficult.

More worryingly, in many real-world breach investigations, alerts were raised by SIEM or IDS systems but not acted upon, largely due to alert fatigue, unclear ownership, or lack of training among operational teams.

Governance And Operational Response

Perhaps the most concerning set of findings relates to governance. Incident response playbooks, where they existed, were often out of date, static, and not tailored to digital operations. Roles and escalation paths were unclear, and in several engagements, it was found that security operations centres (SOCs) escalated alerts to business teams with no defined protocol on how to respond.

Furthermore, third-party systems were frequently onboarded without structured risk reviews or technical integration audits. KYC vendors, payment aggregators, or CRM providers were often trusted by default, even when embedded deep within transaction workflows. The absence of real-time risk scoring or behavioural monitoring meant that suspicious activity through third-party integrations went unnoticed.

Regulatory Directions And Gaps

In recent years, India’s regulatory landscape has undergone a profound shift. Where compliance was once treated as a periodic obligation—an annual exercise in box-ticking—it has now evolved into a core operational function within financial services. The Digital Threat Report 2024 recognises this transformation, but also highlights the growing complexity that institutions must navigate as regulators, jurisdictions, and international frameworks overlap in unpredictable ways.

A Dense Thicket Of Regulatory Mandates

The regulatory ecosystem in India is described in the report as “rapidly evolving”—a polite way of saying labyrinthine. Financial entities today must adhere to a range of directives, including:

  • CERT-In’s six-hour breach reporting mandate, which compels institutions to disclose incidents swiftly, sometimes before investigations have even stabilised.
  • RBI’s Master Directions on Digital Payment Security Controls (DPSC) and Outsourcing of IT Services, placing stringent controls on authentication, data encryption, and vendor oversight.
  • The Cyber Security Framework (CSF) for banks establishes baseline security standards but requires individual interpretation.
  • SEBI’s Cybersecurity and Cyber Resilience Framework (CSCRF), targeted at stock exchanges and depositories.
  • IRDAI’s Information and Cybersecurity Guidelines, built specifically for insurers.
  • The Digital Personal Data Protection (DPDP) Act, 2023, adds statutory backing to consent, storage limitation, and purpose limitation principles.
  • PCI DSS 4.0, GDPR, and CCPA for globally operating BFSI firms.

Each framework represents a good-faith effort to modernise cybersecurity in its domain. But taken together, they form a fractured compliance mosaic, particularly burdensome for fintechs and conglomerates operating across sectors and geographies.

Compliance Fatigue: The Cost Of Fragmentation

Institutions face regulatory duplication, contradictory obligations, and significant operational drag in managing audits, controls, and documentation. The lack of a unified cybersecurity framework leads to redundant risk assessments, overlapping breach reports, and inconsistent technical standards across lines of business.

In cross-border payment systems, where transaction speed and precision are non-negotiable, these inefficiencies have real implications. The inconsistencies slow down decision-making, complicate threat response, and increase the cost of staying compliant without necessarily reducing risk.

Compliance-As-Innovation

What’s more encouraging, however, is the emergence of a design-forward approach to compliance. The report spotlights financial organisations that are embedding compliance protocols at the product development stage, rather than retrofitting them after launch.

This includes the use of:

  • Data anonymisation and synthetic datasets to train fraud models without compromising real customer data.
  • Privacy-by-design principles, where customer consent, data minimisation, and access restrictions are built into application architecture.
  • Security-by-default configurations—especially for API endpoints, transaction logging, and cloud storage platforms.

Such moves are not only cost-effective but also position these institutions for faster scaling, fewer audit frictions, and improved stakeholder trust.

The Push For Harmonisation

Despite the regulatory sprawl, the report observes growing consensus across regulators to pursue harmonised standards. RBI, SEBI, and IRDAI are increasingly aligned in their understanding of sectoral risks, and organisations such as CERT-In and CSIRT-Fin are now acting as connective tissue, providing not just guidance but strategic coordination across response frameworks, threat intelligence dissemination, and testing protocols.

The momentum is clearly towards cohesive regulation, not just to reduce compliance fatigue, but to foster a uniform standard of resilience across India’s BFSI ecosystem.

Regulatory Gaps That Demand Urgent Attention

Yet, the report does not gloss over where gaps remain. These include:

  • Lack of universal standards across digital payment systems—wallets, UPI, QR codes, and embedded finance products still operate under inconsistent security norms.
  • Absence of formal response mandates like red-teaming or breach simulations, which are vital in testing real-world resilience.
  • No regulatory guidance on AI-generated threats, such as impersonation fraud via deepfakes or LLM-manipulated phishing tools.
  • Underpowered cyber leadership, with CISOs often lacking the organisational clout to enforce security policy independently from CIOs or CTOs.
  • No roadmap yet for post-quantum cryptography, despite warnings that public key infrastructure may not withstand future computational models.

These aren’t merely procedural shortcomings. They represent strategic vulnerabilities in an environment where adversaries are increasingly faster and better funded than their targets.

Actionable Recommendations

The report outlines six concrete suggestions to bridge these gaps:

  1. Treat cybersecurity as a techno-commercial function—not an IT silo—with direct reporting to CEOs or Chief Risk Officers.
  2. Standardise digital payment security across form factors, ensuring that UPI, wallets, and cards are treated with parity.
  3. Accelerate preparation for quantum threats, including migration strategies and testing protocols.
  4. Incentivise certification programmes to create a skilled pool of payment security specialists.
  5. Mandate regular incident simulations to uncover hidden failure points before attackers do.
  6. Draft a Responsible AI framework for BFSI, focusing not only on fairness and accuracy but misuse and weaponisation risks​.

Cybersecurity In 2025: What Lies Ahead?

While the core threats are called out explicitly in the report, the full breadth of its findings—spanning observed breach patterns, adversary tactics, and forensic insights—adds texture and urgency to this outlook.

1. Deepfake Identity Fraud Will Scale Executive Impersonation

Voice cloning, synthetic avatars, and video forgeries are no longer fringe experiments. The report cites widespread adoption of deepfake technology for corporate impersonation, where attackers use hyperrealistic voice or video to impersonate a CFO or CEO in real-time, often during virtual calls or messaging threads. OTP phishing, fund diversion, and executive-level BEC scams are the most common payloads​.

  1. Supply Chain Attacks Will Target The Software Backbone

Third-party integrations are a silent risk. The report illustrates how malicious libraries—often disguised as legitimate open-source components—can slip into core banking systems, digital apps, or APIs. These are particularly hard to detect because they arrive via trusted vendors or routine updates. Notably, cases like the MOVEit and GoAnywhere breaches are referenced to highlight the risks of managed file transfer services​.

3. IoT Devices Will Become Prime Infiltration Points

Financial systems are increasingly dependent on kiosks, smart safes, biometric devices, and surveillance hardware. Many of these are underpatched, poorly segmented, or operate on outdated firmware. Once breached, they become pivot points into sensitive systems or customer data environments​.

4. Prompt Injection And Local LLM Exploits Will Rise Sharply

With financial institutions exploring AI-native interfaces—from chatbots to document reviewers—the risk of prompt injection attacks is growing. Locally hosted LLMs (as opposed to cloud-based models) are particularly vulnerable to input manipulation that causes data leaks, policy bypass, or dangerous automated outputs​.

5. Adversarial LLMs Will Democratise Sophisticated Cyber Offence

WormGPT, FraudGPT, WolfGPT—these maliciously trained LLMs are enabling a new class of attackers to generate polymorphic malware, phishing templates, exploit kits, and social engineering scripts at scale. Crucially, these tools can mutate to evade detection and are already being sold on dark web forums​.

6. Cryptocurrencies Will Remain Both Target And Tool

The report details how attackers are shifting focus from exchanges to crypto wallets, smart contracts, and custodial platforms. These assets offer anonymity, immutability, and fast monetisation, making them ideal for laundering and extortion, particularly in ransomware or data-theft scenarios​.

7. Quantum Computing Could Break Today’s Encryption

Although quantum threats are still theoretical in 2024, the report flags them as urgent for financial systems reliant on RSA or ECC encryption. The lack of a national migration plan for post-quantum cryptography puts high-value data, like account credentials or transaction logs, at long-term risk​.

8. Zero-Day Exploits And Patch Lag Will Widen Risk Windows

A key statistic: the average time to exploit a disclosed vulnerability is now eight days. Many BFSI entities still operate without continuous scanning, automated patching, or VAPT cycles frequent enough to match the pace of exposure. Zero-day exploits remain a preferred point of entry​.

9. API Abuse Will Bypass Perimeter Controls

From mobile wallets to third-party payment apps, weak API authentication—hardcoded keys, predictable naming schemes, credential reuse—remains one of the most abused vulnerabilities. These weaknesses are especially dangerous because they are public-facing and linked directly to money movement​.

10. Cloud Misconfigurations Will Continue To Leak Sensitive Data

Cloud buckets left open, IAM roles overly permissive, or critical logs not ingested by SIEMs—these are not hypothetical flaws. The report outlines repeated examples of data breaches due to poor cloud hygiene. The rapid pace of cloud adoption is outstripping the pace of secure configuration in most firms​.

11. Business Email Compromise (BEC) Will Become AI-Powered

AI models can now write perfect emails in multiple languages and spoof tone and formatting. This makes phishing more convincing and harder to detect. The report notes that in over 54% of BEC cases, attackers used pretexting with stolen session data, OTP interception, or AI-generated content​.

12. Multifactor Authentication Will Not Be Enough

MFA, once considered the gold standard, is now regularly bypassed. Methods include session hijacking, push fatigue attacks, deepfake OTP theft, and vulnerabilities like BOLA (Broken Object Level Authentication). Many financial institutions are only now revisiting their MFA implementations in light of these methods​.

13. Ransomware Will Shift To Data Extortion Models

Rather than encrypting data and demanding decryption keys, newer ransomware groups are focusing on exfiltration and extortion, threatening to leak sensitive financial data unless payment is made. This tactic has proven more lucrative and harder to neutralise with backups alone​.

14. Social Engineering Will Converge With Insider Threats

The report also references external actors compromising employees via social engineering, bribery, or deception. In some incidents (including outside India), administrators were persuaded via cryptocurrency incentives to alter settings or disable controls. This marks a concerning convergence of human error and intentional sabotage​.

From Vulnerable To Vigilant: Building Cyber Resilience That Lasts

If the Digital Threat Report 2024 delivers one message with clarity, it’s this: today’s threats will not be stopped by yesterday’s defences. And yet, most financial institutions still rely on security measures built for an earlier time, when threats were linear, insider-driven, and human-scaled.

The new cyber landscape is asymmetrical, faster than before, and often machine-led. Resilience, then, is no longer about plugging holes. It’s about building systems—across people, processes, and infrastructure—that can withstand pressure without collapse.

Investing In People Who Understand The Stakes

Cybersecurity training still exists in most institutions—but it’s often too rare, too broad, and too dull. The report makes a sharp point: staff don’t need longer e-learning videos. They need short, frequent, role-specific training that reflects the threats they are most likely to face.

In today’s environment, that includes recognising deepfakes, spotting QR-code traps, and understanding how AI can spoof tone, identity, and legitimacy. This is especially important for executives and finance teams, who remain prime targets for BEC (Business Email Compromise) and authorisation fraud.

Just as critically, the report calls out the governance gap. It’s not enough to have a CISO buried under the CIO. Cybersecurity must report into risk leadership or directly to the CEO, not because of hierarchy, but because that’s where real decisions get made.

What to do:

  • Drop the once-a-year training model. Move to quarterly, threat-specific refreshers.
  • Equip executives with deepfake and AI-scam awareness, especially around authorisation flows.
  • Ensure cyber risk leadership sits at board level, not just IT or infrastructure.

Fixing The Framework

Good security frameworks often look solid on slides. But the moment a breach occurs, clarity disappears. Who responds first? Who decides if law enforcement is involved? What happens if customer data is affected? And how soon does reporting need to happen?

According to the report, most institutions still don’t run simulation drills to answer these questions under stress. And in several major incidents reviewed, the response plan wasn’t followed, because no one had rehearsed it.

It’s not just response plans that need work. Vulnerability management remains too slow. Patching cycles are still monthly, when most critical exploits go live in under eight days. In the age of adversarial AI, even a fortnight’s delay can be fatal.

What to do:

  • Run regular breach simulation exercises, not just tabletop exercises.
  • Shorten patching cycles. For high-severity CVEs, aim for under a week, not a month.
  • Align cyber process ownership across functions—not just IT, but fraud, compliance, and legal.

Smarter Technology: Tools That Predict, Not Just Detect

The report doesn’t push for more technology. It argues for smarter, integrated technology tools that work together, flag anomalies in context, and allow for automation when response time is everything.

In particular, it points to AI-based monitoring systems capable of identifying behavioural deviations in real time, autonomous patching, and identity-based access controls that remove blanket permissions and reduce lateral movement.

It also warns against blind spots in mobile-first and cloud-first environments. Many firms still fail to monitor API traffic, still leave cloud storage buckets exposed, and still treat service-to-service traffic as trusted. That trust, the report says, is being weaponised.

What to do:

  • Adopt Zero Trust Architecture, not just in theory but in traffic flows.
  • Monitor API and service-layer logs, not just endpoint devices.
  • Transition to adaptive access control—permissions that expire or adjust with behaviour, not just login state.
  • Bake security into DevOps pipelines. Automated checks at code commit and deployment can catch what manual review misses.

Conclusion

The Digital Threat Report 2024 leaves little room for complacency. From AI-driven fraud to deepfake impersonation, from supply chain intrusions to regulatory fragmentation, the risks are escalating in both speed and sophistication. But the message isn’t fatalistic—it’s instructive. Institutions that treat cybersecurity as an operational benchmark, not a compliance obligation, will be best positioned to withstand what’s coming. Resilience isn’t just a matter of controls; it’s a mindset, rooted in clarity, accountability, and constant rehearsal.

KYC Challenges 2025

KYC Challenges In 2025 And Beyond

Once a static box-ticking exercise, the Know Your Customer (KYC) framework is now at the centre of global financial stability, fraud prevention, and digital onboarding. As digital transactions continue to surge—crossing over $11 trillion globally in 2024, according to a recent report—so too does the scale and sophistication of financial crime. Yet, even as the regulatory bar is raised, compliance teams are often left grappling with fragmented data systems, inconsistent global standards, and outdated processes.

Banks, fintechs, and investment firms find themselves amongst a complex mix of regulatory updates, customer expectations, and technological innovation. The introduction of AI-powered due diligence, decentralised identity frameworks, and perpetual KYC models are replacing traditional verification strategies. However, these advancements come with their own set of operational, ethical, and technical challenges.

With data privacy regulations tightening and financial watchdogs ramping up penalties—over €4 billion in AML/KYC-related fines have already been issued in the EU alone since 2020—institutions cannot afford to treat KYC as a back-office function.

How Global KYC Regulations Are Shifting In 2025

Financial institutions today are contending with a slew of constantly evolving KYC and anti-money laundering (AML) regulations that vary not just between countries, but even across states or regions within them. While the intent behind these laws remains consistent—mitigating financial crime and ensuring accountability—the execution is widely fragmented.

The European Union’s Sixth Anti-Money Laundering Directive (6AMLD), for instance, has raised the bar with stricter liability clauses for legal entities and a sharper focus on beneficial ownership. In contrast, the United States’ FinCEN regulations are placing renewed emphasis on data-sharing obligations under the Corporate Transparency Act. Meanwhile, Singapore and the UAE have already mandated continuous due diligence and near-real-time monitoring under updated compliance frameworks, pushing firms to adopt what is now being called “perpetual KYC.”

For multinational banks or investment firms, this patchwork approach means compliance strategies can no longer be static or one-size-fits-all. The administrative burden of keeping up with overlapping regulatory obligations—such as screening against different politically exposed persons (PEP) lists or beneficial ownership thresholds—is growing steadily. This complexity is not theoretical; a 2024 survey found that 61% of global compliance leaders identified jurisdictional inconsistency as their number one KYC challenge.

Furthermore, the penalties for non-compliance have become significantly more severe. Beyond fines, there is the cost of reputational damage. Customers are becoming increasingly conscious of how their data is handled, and regulators are quick to act when financial institutions fall short.

AI In KYC: Promise Vs Reality

Artificial Intelligence (AI) has quickly become one of the most talked-about solutions today. In theory, its appeal is straightforward: faster identity verification, better fraud detection, reduced human error, and lower operational costs. In practice, however, financial institutions are finding that integrating AI into KYC processes is far more nuanced and, in many cases, still underwhelming in its real-world effectiveness.

Challenges Arising

At the heart of the challenge lies the trade-off between automation and accountability. AI-driven KYC systems can scan documents, flag anomalies, and run checks against global watchlists in seconds. Yet these systems are only as reliable as the data they are trained on—and financial data is notoriously unstructured, diverse, and prone to bias. A recent study showed that over 40% of firms using AI tools in compliance still rely on manual intervention in more than half of their onboarding cases due to system flag errors or insufficient data quality.

Another complication is explainability. Regulators are now scrutinising AI-driven decisions more closely, demanding transparency in how customer risk profiles are generated and how adverse decisions are reached. The “black box” nature of many AI systems makes this difficult to justify, especially under laws such as the EU’s AI Act or the UK’s Data Protection and Digital Information Bill, which require clear logic trails for automated decision-making.

Additionally, the deployment of AI in KYC often falls short in covering nuanced fraud scenarios. For example, synthetic identity fraud—where real and fake information is blended to create entirely new identities—has risen by nearly 18% year-on-year in 2024, and most AI systems have proven inadequate in spotting such cases unless combined with behavioural analytics and transaction monitoring tools.

The promise of perpetual KYC (pKYC)—a model where customer data is continuously monitored rather than checked at intervals—depends heavily on AI. But pKYC is still in its infancy, largely confined to pilot projects or select regulatory sandboxes. Organisations report difficulty in justifying ROI on full-scale implementation, especially in mid-tier banks or emerging fintechs with lean compliance teams.

While AI is undoubtedly part of the future of KYC, it is not a silver bullet. The narrative in 2025 is shifting from “full automation” to “augmented decision-making,” where AI supports, rather than replaces, experienced compliance professionals. The path forward lies in marrying technology with strong governance frameworks and ensuring that human oversight remains central to any decision impacting financial access.

Data Silos And Fragmented Identities In KYC

One of the most major obstacles in the KYC lifecycle remains the fractured nature of identity data. Despite rapid advances in digital transformation, many institutions still rely on outdated internal systems that fail to communicate with each other. What results is a patchwork of disconnected databases—across departments, jurisdictions, or service lines—each holding only a partial view of the customer.

This fragmentation introduces friction at every stage of the customer journey. From onboarding delays to verification redundancies, it is not uncommon for a customer to be asked to submit the same documentation multiple times—even within the same financial institution. According to a recent industry report, 68% of customers who abandoned onboarding processes cited “repetitive documentation” and “inconsistent communication” as key reasons.

Why Is This A Concern Operationally?

Beyond the customer experience, the operational implications are equally stark. Institutions spend millions each year on duplicate data handling, remediation efforts, and internal escalations. The average cost of onboarding a retail banking customer has now reached $40–$60 per account, while onboarding a corporate client can exceed $6,000, primarily due to manual verification efforts and cross-functional inefficiencies.

This disjointed approach also makes it harder to detect fraud. Fraudulent actors often exploit these gaps by providing varied information across systems—escaping detection because no single, centralised view of the customer exists. Without a unified identity infrastructure, suspicious patterns go unnoticed, especially when operating across borders.

The idea of a ‘golden record’—a single source of truth for each customer—is still elusive. Although solutions such as decentralised identity (DID), blockchain-based KYC passports, and interoperable eID frameworks are being explored, they remain in pilot stages or suffer from limited adoption. The absence of universally accepted digital identity standards continues to hamper progress.

Today, Regulators have become increasingly intolerant of fragmented customer records, particularly in the wake of AML failures and data breach incidents. Organisations are now under pressure to unify internal KYC systems, break down data silos, and create consistent, audit-friendly identity trails across the entire customer lifecycle.

Customer Experience Vs Compliance: Finding The Balance In A Zero-Tolerance World

Customers today expect fast, frictionless onboarding, often drawing comparisons between opening a bank account and signing up for a digital wallet or a streaming service. At the same time, regulators have taken an uncompromising stance on due diligence, documentation, and real-time risk monitoring.

This divergence creates a dilemma: push too hard on compliance, and institutions risk frustrating and losing customers; ease the process too much, and the consequences can be catastrophic. Another recent report suggested that 72% of financial institutions reported onboarding drop-offs in the past 12 months due to long or intrusive KYC procedures, especially among younger, digitally native clients.

Customers now demand transparency over how their data is used, real-time status updates on KYC checks, and the ability to complete processes without human intervention. Meanwhile, financial institutions are bound by regulatory mandates that often require in-depth reviews, face-to-face verifications (still prevalent in parts of Asia and Africa), and extensive audit trails.

This growing chasm is particularly visible in cross-border scenarios. An individual onboarding with a European fintech may complete verification in minutes, while the same user attempting to open an account with a Middle Eastern bank might face weeks of scrutiny, depending on local laws. This inconsistency not only hurts user trust but also creates competitive disadvantages for legacy financial institutions.

Addressing The Issue

To bridge this divide, many institutions are embracing modular KYC frameworks—layered processes that adapt based on customer risk profiles. For low-risk customers, simplified onboarding with back-end monitoring suffices. For high-risk or high-value clients, enhanced due diligence is triggered automatically. This approach, while still emerging, is allowing some banks to cut onboarding time significantly.

Ultimately, the challenge is not about choosing between compliance and customer satisfaction. It’s about building KYC workflows that are flexible, responsive, and grounded in risk-based logic. As regulators increasingly recognise the value of digital-first processes, there is room for innovation—but only for those who prioritise both control and convenience.

Conclusion

KYC in 2025 has moved beyond compliance for the sake of ticking boxes—emerging instead as a pillar of responsible finance, operational resilience, and customer trust. But the road ahead is not smooth. Institutions are contending with growing regulatory pressure, increasingly complex identity scenarios, and a growing expectation from users for fast, secure, and transparent onboarding experiences.

Many tools still fall short when applied to real-world use cases without adequate data quality and human oversight. Similarly, decentralised identity and perpetual KYC present exciting prospects but require significant groundwork—both technologically and regulatorily—before they can become mainstream solutions.

Ultimately, the future of KYC lies in an institution’s ability to adapt. That means breaking down silos, unifying customer records, rethinking workflows with flexibility in mind, and investing in tools that serve both regulatory needs and user expectations. Those who succeed will not just comply with the rules—they will build trust at every interaction and position themselves to thrive in a more dynamic financial ecosystem.

Consent-Manager-blog-image1

The Crucial Role Of Consent Managers Under The DPDP Act

Introduction

The introduction of the Data Protection and Digital Privacy Act (DPDP Act) in India marks a significant stride towards safeguarding personal information. Central to this new framework is the role of Consent Managers, a novel concept designed to empower individuals in managing their personal data. This article delves into the intricacies of Consent Managers, outlining their legal obligations, the penalties for non-compliance, their distinct role under the DPDP Act, and a comparative analysis with Account Aggregators. By exploring these facets, the article aims to provide a comprehensive understanding of Consent Managers’ pivotal role in the digital economy’s regulatory environment.

Obligations of Consent Managers under the DPDP Act

The Data Protection and Digital Privacy Act (DPDP Act) introduces specific obligations for Consent Managers, who are entrusted with the responsibility of ensuring that individuals’ data is handled transparently and with due consent. As intermediaries between data principals (individuals) and data fiduciaries (entities that process data), Consent Managers play a crucial role in the data ecosystem.

Ensuring Informed Consent

Consent Managers are required to ensure that the consent they manage is informed, specific, and clear. This means that data principals are made fully aware of the nature of the data being collected, the purpose of its collection, and how it will be used. Consent Managers must provide a platform that allows individuals to easily grant, manage, and revoke consent at any time, ensuring that these processes are user-friendly and accessible.

Maintaining Data Privacy

Another critical obligation is the maintenance of privacy and security of the data processed. Consent Managers must employ state-of-the-art security measures to protect data from unauthorized access, breaches, and leaks. This includes implementing robust encryption practices, secure data storage solutions, and regular audits to ensure compliance with the highest standards of data protection.

Transparency and Accountability

Transparency is fundamental to the role of Consent Managers. They are obliged to keep detailed records of all consent transactions and make them available to data principals upon request. Furthermore, they must provide regular updates about any changes in data processing practices and ensure that data principals are always aware of who has access to their data and for what purpose.

These obligations are designed to create a more trusted and transparent environment for personal data management, aligning with global data protection standards and fostering a culture of privacy by design and default.

Fines for Non-Compliance Under the DPDP Act

The Data Protection and Digital Privacy Act (DPDP Act) establishes severe penalties for breaches of its mandates, especially in the management of personal data by Consent Managers. These penalties are essential to ensure compliance and to emphasize the significance of personal data protection.

Scale of Penalties

The DPDP Act introduces hefty fines that can significantly impact an organization’s financial standing. Penalties for non-compliance can reach up to ₹250 crore, depending on the nature and extent of the violation. This high ceiling for fines serves to underline the critical importance the law places on data privacy and the responsibilities of those handling personal data.

Criteria for Determining Fines

Fines are assessed based on the seriousness, duration, and nature of the infringement. Other considerations include whether the infringement was intentional or negligent, the measures taken to mitigate the damage, the degree of cooperation with regulatory authorities, and any history of previous violations by the entity.

Impact of Fines

The potential for such significant financial penalties acts as a strong deterrent against non-compliance. Beyond the direct financial impact, companies facing such fines also risk serious reputational damage, which can affect customer trust and business sustainability. This risk reinforces the need for robust data protection practices and compliance with the DPDP Act’s provisions.

The substantial fines highlighted in the DPDP Act signify the law’s intent to enforce strict compliance and protect individual privacy rights effectively.

Overview of the DPDP Act

The Data Protection and Digital Privacy Act (DPDP Act) serves as a cornerstone in the framework of digital privacy and data protection in India. Its development is a response to the increasing need for a comprehensive legal framework that safeguards personal information while balancing the requirements of the digital economy.

Purpose of the DPDP Act

The primary aim of the DPDP Act is to protect individual privacy concerning personal data. It ensures that data processing is fair, transparent, and respects the rights of individuals. The Act establishes clear guidelines and practices for data collection, processing, and storage, ensuring that personal data is handled securely and with respect for the individual’s privacy.

Key Provisions

  • Consent Framework: The Act introduces a robust consent framework that requires explicit consent for data collection and processing, ensuring that individuals are aware of how their data is used.
  • Rights of Individuals: It empowers individuals with several rights, including the right to access their data, correct inaccuracies, and erase data under specific circumstances.
  • Regulatory Authority: The establishment of a regulatory authority to enforce the provisions of the Act, provide guidance to entities handling data, and address complaints from individuals about data misuse.

Compliance Requirements

Entities that handle personal data must comply with the DPDP Act by implementing adequate security practices and procedures. They are also required to report data breaches, which involve personal data, to the authority promptly.

Role of Consent Manager Under the DPDP Act

Definition and Functionality

A Consent Manager, as defined by the DPDP Act, is an entity that acts as an intermediary between data principals (individuals) and data fiduciaries (entities that process data). Their primary role is to enable individuals to exercise their data protection rights, such as granting, withdrawing, and managing consent for data usage.

Responsibilities of a Consent Manager

  • Facilitate Consent Transactions: Consent Managers are responsible for obtaining and recording explicit consent from data principals for the processing of their personal data.
  • Privacy by Design: They must ensure that their systems and processes are designed to uphold data privacy, incorporating necessary technical and organizational measures to secure personal data.
  • Transparency and Accountability: Consent Managers are required to maintain transparent records of all consent transactions and provide data principals with access to these records upon request.

Benefits to Data Principals

  • Empowerment: Consent Managers empower users by providing them with control over their personal data.
  • Simplified Data Management: They simplify the process of managing consents across multiple platforms, making it easier for individuals to track where and how their data is being used.
  • Enhanced Privacy Control: By facilitating informed consent, they enhance the individual’s ability to control their data privacy and the extent of their data’s usage.

The role of Consent Managers is vital in enforcing the principles of the DPDP Act by bridging the gap between data principals and fiduciaries, thus enhancing the overall trust in digital ecosystems.

Comparison: Account Aggregator vs Consent Manager

Account Aggregators

Account Aggregators (AAs) are a type of financial data fiduciary under India’s financial data sharing system, primarily regulated by the Reserve Bank of India (RBI). They facilitate the sharing of financial data between financial information providers (FIPs) and financial information users (FIUs) with the explicit consent of the customer. This system aims to improve the availability of financial services like loans and investments by ensuring secure and efficient data sharing.

Consent Managers

In contrast, Consent Managers under the DPDP Act have a broader mandate that extends beyond financial data. They help manage consent for any personal data handling by businesses across various sectors. This includes health, education, e-commerce, and more, making their role crucial in protecting data privacy beyond just financial transactions.

Key Differences

  • Regulatory Body: Account Aggregators are regulated by the RBI, whereas Consent Managers are governed under the DPDP Act, showing a varied scope of authority and specialization.
  • Scope of Data: Account Aggregators’ operations are limited to financial data, while Consent Managers deal with a wide range of personal data across different sectors.
  • Purpose: The primary purpose of Account Aggregators is to streamline financial services, enhancing customer experience and service accessibility. Consent Managers focus on the broader aspect of data privacy management, empowering individuals to control how their data is used across any platform.

These distinctions highlight the specialized functions of both roles in managing data privacy and consent in their respective domains, with Consent Managers offering a more comprehensive approach across multiple sectors.

Frequently Asked Questions (FAQs) about Consent Managers under the DPDP Act

A Consent Manager under the Digital Personal Data Protection (DPDP) Act is an entity that assists individuals in managing their consent for the use of their personal data by various data fiduciaries. These managers provide a mechanism for individuals to grant, manage, and revoke consent in a transparent and accessible manner, ensuring greater control over personal data.

While both roles aim to protect personal data, a Consent Manager specifically facilitates the consent management process between individuals and data fiduciaries, while a Data Protection Officer (DPO) oversees an organization’s overall data protection strategy, compliance with the DPDP Act, and acts as a point of contact with regulatory authorities.

Non-compliance with the provisions related to consent management under the DPDP Act can result in significant penalties. Organizations may face fines of up to Rs. 250 crore or higher, depending on the severity of the violation and the discretion of the regulatory authority. This underscores the importance of having robust consent management processes in place.

Yes, individuals can directly interact with Consent Managers to manage their consent preferences. Consent Managers are required to provide easy-to-use tools that allow individuals to grant, modify, or withdraw consent at any time, giving them full control over how their personal data is handled.

Fake HSRP Blog

Fake HSRP Scam In Maharashtra: All You Need To Know

A new scam involving fake High-Security Registration Plates (HSRPs) has come to light in Maharashtra, catching vehicle owners and businesses off guard. Fraudsters set up bogus websites posing as official registration portals, duping thousands of people into paying for counterfeit number plates.

As per several reports, the Pune Regional Transport Office (RTO) and Mumbai Police Cyber Cell had received multiple complaints from victims who made online payments for HSRPs. Later, they realised that they had fallen for a well-organised fraud. In some cases, unsuspecting vehicle owners were lured through fake social media ads and phishing links, leading them to fraudulent portals where they unknowingly shared personal and financial details.

While the scam had raised concerns for individual vehicle owners, its likely implications on businesses operating large fleets, ride-hailing services, and delivery platforms can be even more alarming. Fake number plates pose compliance risks. This could make it difficult for businesses to track and verify their delivery fleet. How can businesses be sure that their fleet vehicles and drivers operate with genuine, legally registered plates?

This is where HSRP verification becomes essential. Ensuring your fleet has authentic registration plates can protect your business from legal liabilities and security risks.

How Did The Fake HSRP Scam Work?

Fraudsters targeted vehicle owners via fake websites, social media ads, and phishing links. This tricked them into making payments for number plates that never arrived. In a few cases, they even issued fake plates that did not comply with government regulations.

As reported in the news, cybercriminals set up fake websites mimicking official portals that claimed to offer authentic HSRP registration. Many victims landed on these sites through misleading Google ads or WhatsApp forwards, believing they were dealing with authorised vendors. Once on these fake platforms, they were prompted to enter personal details, vehicle registration numbers, and payment information. Later, they realised that they had been scammed.

In some cases, even businesses managing vehicle fleets had unknowingly procured fake number plates, putting them at risk of fines and legal action. Reports suggested that unsuspecting logistics providers and ride-hailing platforms may already have had drivers operating with fraudulent plates, making it crucial for companies to verify every vehicle before onboarding.

A senior RTO official in Pune, as quoted in several reports, stated:

“We have received numerous complaints from people who made payments on fake websites and were either issued fake plates or never received them at all. Vehicle owners must only use authorised government portals or vendors listed by their respective transport departments.”

Meanwhile, the Mumbai Cyber Cell has filed multiple FIRs against the fraudsters behind these scams.

While authorities are cracking down on these fraudulent websites, businesses cannot afford to wait for enforcement action. The only way to safeguard against onboarding vehicles with fake HSRPs is through a strong verification process that checks the legitimacy of number plates before they are allowed onto logistics and delivery networks.

Why Businesses Need To Take HSRP Fraud Seriously

For businesses that rely on a network of vehicles—whether in logistics, ride-hailing, or last-mile delivery—this fake HSRP scam is a serious operational risk. 

Many firms onboard drivers and fleet vehicles without verifying the authenticity of their number plates, assuming that vehicle registration is the owner’s responsibility. However, businesses that fail to conduct proper checks may unknowingly allow vehicles with counterfeit plates onto their platforms. This creates multiple risks:

  • Regulatory Violations – Operating a vehicle with an invalid or counterfeit number plate is a punishable offence under the Motor Vehicles Act, 1988. Businesses that fail to verify HSRPs may inadvertently employ non-compliant vehicles, facing regulatory scrutiny and potential fines.
  • Increased Liability in Case of Accidents – If a vehicle with a fake number plate is involved in an accident or criminal activity, tracking its ownership becomes difficult. Businesses may find themselves liable if the vehicle was operating within their network.
  • Compromised Fleet Security – Fraudulent number plates make it easier for criminals to use stolen or unauthorised vehicles for illegal activities under the guise of legitimate operations. This is concerning for companies handling sensitive cargo, food delivery, or passenger transport.
  • Erosion of Customer TrustRide-hailing services and e-commerce platforms rely on trust and transparency. If customers discover that some vehicles within the company’s ecosystem are using fake plates, it could damage the brand’s reputation and lead to customer attrition.

A senior official from the Mumbai Cyber Cell, highlighted the scale of the issue:
Fraudsters are using digital platforms to dupe vehicle owners into purchasing fake number plates. Many of these cases involve logistics and ride-hailing drivers who were unaware that they were issued counterfeit HSRPs.

Key Features Of A High Security Registration Plate (HSRP)

According to the Ministry of Road, Transport and Highways (MoRTH), these are the key features of an HSRP:

  • Chromium hologram.
  • A retro-reflective film, bearing a verification inscription ’India’ at 45 degree inclination.
  • Unique laser numbering contains alpha-numeric identification of both Testing Agencies and the manufacturers.
  • The Registration numbers are to be embossed on the plates.
  • In the case of the rear registration plate, the same is to be fitted with a non-reusable snap lock to make it tamper-proof.
  • A chromium-based third registration plate in the form of a sticker is to be attached to the windshield, wherein the number of engine and chassis are indicated along with the name of registering authority. If tampered with, it self destructs.
  • On the front and rear registration plates, the letter IND in blue color is hot-stamped.
  • Letters ’IND’ in blue colour on extreme left centre of the plates.

How AuthBridge’s HSRP Verification Can Protect Your Business

With this scam, a thorough verification process is the only way to ensure that every vehicle in your ecosystem is legally registered and compliant with transport regulations. AuthBridge provides advanced HSRP verification solutions that help businesses authenticate number plates before onboarding vehicles and drivers. They help companies eliminate fraud using real-time AI-driven data checks and integration with government databases.

What Does HSRP Verification With AuthBridge Offer?

  1. Stolen Vehicle Verification – Ensures that the vehicle linked to the HSRP has not been reported as stolen, preventing fraudulent onboarding.
  2. RC (Registration Certificate) Verification – Cross-checks the vehicle’s number plate with the official registration certificate to confirm authenticity.
  3. Real-Time Authentication – Direct API integration with authoritative databases ensures instant verification of HSRPs.
  4. Protection Against Compliance Risks – Verifies that vehicles meet legal standards, protecting businesses from regulatory penalties.
  5. Seamless Integration for Fleet & Driver Onboarding – Automated verification can be embedded into onboarding workflows for logistics, ride-hailing, and delivery platforms.
Indian DL Frauds

By leveraging AuthBridge’s verification solutions, businesses can:

  • Prevent onboarding of vehicles with fake number plates.
  • Ensure fleet compliance and mitigate operational risks.
  • Reduce liability in case of accidents or legal disputes.
  • Build customer trust by ensuring only verified vehicles operate under their brand.

How To Ensure Your Vehicle Has A Genuine HSRP

To avoid falling victim to fraudulent websites, vehicle owners and businesses must book HSRPs only from government-approved portals. Here are the official sources where you can safely book your High-Security Registration Plate:

  • BookMyHSRP https://bookmyhsrp.com/ (Approved vendor for multiple states)
  • State Transport Department Websites – Each state’s official RTO website provides links to authorised HSRP vendors. Ensure you verify the legitimacy of the website before making any payment.

Conclusion

The fake HSRP scam in Maharashtra has exposed a key weakness in vehicle registration security, making it easier for fraudsters to circulate counterfeit number plates. While individual vehicle owners have suffered financial losses, the real risk lies with businesses operating logistics fleets, ride-hailing platforms, and last-mile delivery networks.

A single unverified vehicle with a fake number plate can put businesses at risk of compliance violations, liability in case of accidents, and reputational damage. Without proper checks, companies may unknowingly allow stolen vehicles or fraudulently registered drivers to operate within their networks, leading to legal and financial consequences.

Top GST Analysers

5 Best Goods & Service Tax (GST) Analysers In India

As businesses across India navigate the complexities of Goods and Services Tax (GST), having the right tools to ensure accurate compliance and optimise tax liabilities has become crucial. With the introduction of GST, managing tax filings, reconciliation, and returns has shifted from a tedious manual process to a more streamlined, automated workflow. Several platforms now offer specialised solutions to help businesses manage their GST data, reduce errors, and stay compliant with changing regulations. In this blog, we will explore the top five GST analysing platforms in India, focusing on the unique services each offers.

1. AuthBridge’s GST Analyser

AuthBridge’s GST Analyser provides a powerful tool for businesses looking to streamline their GST compliance process, reduce the risk of errors, and optimise their tax-related operations. This platform is designed to simplify the often complex process of GST data analysis, helping businesses ensure compliance with the Goods and Services Tax regulations while revealing potential areas for improvement in their tax strategies.

GST Verification
AuthBridge's GST Verification API

Key Features Of AuthBridge GST Analyser:

  • Input Tax Credit (ITC) Validation:
    One of the key aspects of GST compliance is ensuring the accurate calculation and claim of Input Tax Credit (ITC). The GST Analyser helps businesses verify their ITC claims, ensuring that only eligible credits are claimed. Performing this validation against the purchase data ensures businesses avoid over-claiming ITC and potentially facing penalties.
  • Customised Reports and Dashboards:
    The platform offers businesses access to detailed reports that break down GST liabilities, ITC claims, and other critical tax data. These reports can be customised to meet the specific needs of a business, offering decision-makers a clear, actionable understanding of their tax obligations. With real-time data visualisation, the platform ensures that businesses have immediate access to relevant GST insights at their fingertips.
  • Data Integration with Existing Systems:
    The GST Analyser integrates seamlessly with a business’s existing ERP or accounting system, enabling automatic importation of sales and purchase data. This integration eliminates the need for manual data entry, reducing errors and saving time.
  • Audit Support:
    For businesses undergoing GST audits, the GST Analyser serves as an essential tool. It provides a comprehensive history of the business’s GST filings, enabling quick access to transaction-level details for audit purposes. This feature ensures that businesses are always prepared for potential audits and can respond promptly to queries from tax authorities.

Why Choose AuthBridge GST Analyser?

AuthBridge’s GST Analyser is built to simplify the process of GST compliance for businesses of all sizes. Its ability to automate reconciliation, validate ITC claims, and generate detailed reports ensures businesses remain compliant while also optimising their GST filings. With seamless system integrations and audit support, businesses can confidently navigate the complexities of GST without the risk of errors or delays.

2. Corpository GST Analyser

Corpository’s GST Analyser is designed to streamline the GST reconciliation and filing process for businesses. It automates the comparison of purchase and sales data with GST returns, ensuring that businesses stay compliant and minimise the risk of errors.

Key Features:

  • Automated Reconciliation: Compares sales and purchase data against GST returns to identify discrepancies.
  • Accurate Data Validation: Ensures all entries are GST-compliant.
  • Custom Reports: Allows businesses to generate detailed, customised reports for better insight into their GST obligations.
  • Filing Support: Simplifies the filing process, ensuring timely and accurate submissions.

3. BDO GST Analytics

BDO GST Analytics offers businesses a sophisticated approach to managing their GST data with a focus on providing in-depth analysis and optimisation opportunities. The platform provides businesses with essential tools for GST reconciliation, tax analysis, and compliance monitoring, helping them optimise their tax liabilities and ensure compliance with the latest regulations.

Key Features:

  • GST Reconciliation: Helps businesses reconcile their data against GST returns to detect discrepancies.
  • Tax Optimisation Insights: Provides actionable insights for improving tax efficiency and optimising Input Tax Credit (ITC) claims.
  • Comprehensive Reporting: Offers detailed reports to help businesses understand their tax positions and make informed decisions.

4. ScoreMe GST Analysis

ScoreMe GST Analysis is designed to help businesses manage their GST compliance by providing an easy-to-use platform for GST return filing, reconciliation, and ITC optimisation. The platform ensures that businesses stay compliant with GST regulations while helping them streamline their tax processes.

Key Features:

  • GST Return Filing: Assists with timely and accurate filing of GST returns.
  • Reconciliation: Automates reconciliation between purchase and sales data with GST returns.
  • ITC Optimisation: Helps businesses verify and optimise their Input Tax Credit claims for greater tax efficiency.

5. Perfios GST Analysis

Perfios GST Analysis focuses on providing GST analysis tools specifically tailored for small and medium-sized enterprises (SMEs), with a particular emphasis on lending assessments. This platform helps financial institutions assess a business’s GST compliance and financial health, making it an essential tool for those in the lending space.

Key Features:

  • GST Compliance Assessment: Evaluates a business’s GST filings and compliance status.
  • SME Lending Support: Provides valuable insights for financial institutions in assessing SMEs’ creditworthiness.
  • GST Data Validation: Ensures that GST returns and financial data are accurate and aligned.

Choosing the right platform depends on your business needs, scale, and the depth of analysis you require. Regardless of the solution, implementing an effective GST analysis tool can significantly streamline your tax management process and reduce the risk of errors or penalties.

KYB in gaming industry importance

Why KYC Matters In The Gaming Industry

The real money gaming industry is at an important junction. With markets expanding and regulatory frameworks tightening, the operational complexities of managing compliance have multiplied. While Know Your Customer (KYC) guidelines are well-established to verify individual players, businesses in this sector are now facing equal pressure for Know Your Business (KYB) processes to ensure trust and compliance within their partner networks.

For gaming platforms, especially those relying on affiliates and vendors to drive user acquisition and monetisation, KYB offers an amazing solution to verify the legitimacy and integrity of their business partners. This process isn’t just about meeting regulatory demands; it’s about safeguarding operations against risks like fraud, money laundering, and reputational damage. The gaming ecosystem, where stakes are high and transactions are instantaneous, calls for streamlined KYB protocols that blend efficiency with thoroughness.

The Need For KYB In The Gaming Industry

The online gaming industry operates within an ecosystem where multiple entities—affiliates, payment processors, marketing partners, and vendors—converge to deliver seamless user experiences. However, this ecosystem’s reliance on external partnerships exposes gaming platforms to significant risks. Fraudulent affiliates, unverified vendors, and entities engaging in money laundering can tarnish a brand’s reputation, invite regulatory penalties, and remove player trust.

Why Is KYB Essential in Gaming?

Unlike KYC, which focuses on individual players, KYB targets businesses interacting with the platform. This is particularly relevant in real money gaming, where affiliate marketing drives a substantial portion of user acquisition. Affiliates often function independently, making it challenging for platforms to assess their ethical and operational integrity without comprehensive verification protocols. KYB helps to:

  1. Detect Fraudulent Affiliates
    Fraudulent businesses can employ tactics like multi-accounting or unauthorised promotions, which not only violate compliance standards but also harm legitimate operators. KYB ensures that affiliates are genuine entities with verifiable business credentials.
  2. Prevent Money Laundering
    Regulators are increasingly scrutinising online platforms for anti-money laundering (AML) compliance. KYB helps mitigate risks by evaluating the financial standing and transactional behaviour of business partners.
  3. Maintain Regulatory Compliance
    Countries like India, operating under laws such as the DPDP Act, require gaming platforms to conduct exhaustive due diligence on their business affiliates. Failure to meet these requirements can lead to hefty penalties and business disruptions.
  4. Foster Trust and Transparency
    A verified partner network ensures smooth collaboration, enhances reputational credibility and builds long-term trust with stakeholders.

The Scope of KYB in Real Money Gaming

KYB comprises more than just verifying a partner’s business registration. It delves into assessing their legal standing, ownership structures, financial records, and even their adherence to ethical standards. This depth of analysis enables gaming platforms to build a robust, transparent ecosystem aligned with compliance mandates.

Challenges In Implementing KYB For Gaming Platforms

While the benefits of KYB in the gaming industry are evident, implementing these processes comes with its own set of challenges. Gaming platforms, especially those in the real money gaming sector, operate in a highly fluid environment with rapid partner onboarding, high transaction volumes, and evolving regulatory frameworks. These factors can make robust KYB implementation a complex and resource-intensive endeavour.

  • Fragmented Regulatory Conditions

The gaming industry often operates across multiple jurisdictions, each with its own set of compliance requirements. For instance, in India, businesses must adhere to anti-money laundering regulations alongside the DPDP Act, while in other regions, GDPR or equivalent data protection laws apply. This diversity necessitates a KYB framework capable of accommodating region-specific compliance requirements without creating bottlenecks.

  • Limited Transparency Among Affiliates

Many affiliates operate as small businesses or even individuals, making it difficult to access verifiable information about their operations. Traditional verification methods may not be sufficient for smaller entities lacking a robust digital or financial footprint.

  • Time-Consuming Processes

Manual KYB checks, involving document verification, ownership vetting, and financial assessments, can delay partner onboarding. This is a critical concern for gaming platforms reliant on rapid growth through affiliate and vendor networks.

  • Emerging Threats Like Synthetic/Forged Identities

Advanced fraud methods, such as synthetic identities or shell companies, complicate the process of distinguishing legitimate entities from fraudulent ones. Without cutting-edge verification tools, these threats can slip through traditional checks.

  • Cost Implications

Developing and maintaining in-house KYB solutions can be prohibitively expensive, particularly for mid-sized platforms. Outsourcing such operations to third-party providers adds another layer of cost considerations, albeit with operational efficiencies.

  • Balancing Compliance With User Experience

A cumbersome KYB process can discourage affiliates and partners from engaging with the platform. Striking the right balance between thorough due diligence and a smooth onboarding experience is a persistent challenge for gaming operators.

How Technology Streamlines KYB For Gaming Businesses

The complexities of implementing KYB in the gaming industry underscore the need for technology-driven solutions. Advanced tools and platforms are now pivotal in enabling gaming businesses to conduct thorough due diligence while maintaining efficiency and scalability. These technologies not only automate cumbersome manual processes but also provide actionable insights that improve decision-making.

  • Automated Business Verification

Technology platforms like API-driven KYB solutions allow gaming operators to instantly verify a partner’s legitimacy by accessing global business registries. These systems can validate company registration numbers, tax identification details, and financial standings in real time, eliminating the delays associated with manual verification.

  • Enhanced Risk Scoring and Monitoring

Artificial Intelligence (AI) and Machine Learning (ML) are transforming KYB by providing dynamic risk-scoring capabilities. These algorithms analyse data points such as ownership patterns, transaction behaviours, and historical compliance records to assess the credibility of affiliates and vendors. Continuous monitoring ensures that gaming platforms remain compliant even after onboarding.

  • Biometric Verification for Key Individuals

KYB solutions are increasingly integrating biometric technologies to verify the identities of key individuals within partner organisations. These tools cross-reference biometric data with government records, ensuring the authenticity of stakeholders and preventing the use of synthetic identities.

  • Real-Time Financial Health Checks

Advanced KYB systems leverage integrations with financial databases to evaluate the financial stability of partners. Tools such as bank account verification, credit assessments, and transaction pattern analysis ensure affiliates and vendors are solvent and compliant with anti-money laundering (AML) standards.

  • Streamlined Workflow Through Integration

Modern KYB platforms offer seamless integration with existing gaming management systems via APIs. This enables operators to consolidate verification processes into their existing workflows, reducing operational friction and maintaining consistency across departments.

How AuthBridge Drives KYB Efficiency?

AuthBridge leverages cutting-edge technologies to empower gaming platforms with comprehensive KYB solutions. By automating the verification of affiliates, vendors, and partners, AuthBridge ensures that gaming businesses can navigate the complexities of compliance with ease. Its suite of solutions integrates seamlessly into business workflows, offering fast, reliable, and cost-effective verification processes tailored for the dynamic gaming ecosystem.

Conclusion

The gaming industry’s evolution into a highly competitive and regulated space has made Know Your Business (KYB) a cornerstone of sustainable growth. For platforms operating in the real money gaming sector, KYB is not merely a compliance requirement but a strategic imperative to foster trust, ensure operational integrity, and mitigate risks. By embracing technology-driven KYB solutions, gaming businesses can streamline affiliate and vendor verification processes, navigate regulatory landscapes with confidence, and establish a strong foundation for long-term success.

As gaming platforms scale and diversify, the need for robust partner networks is more critical than ever. Advanced KYB solutions, such as those offered by AuthBridge, empower businesses to go beyond basic verification and achieve comprehensive compliance effortlessly. With features like automated business verification, real-time financial health checks, and AI-powered risk assessments, AuthBridge provides a one-stop solution for gaming companies looking to stay ahead in a competitive market.

FAQs

KYB (Know Your Business) refers to the process of verifying the identity, legitimacy, and financial integrity of a business entity. It is a regulatory requirement for companies, particularly in financial services, to prevent fraud, money laundering, and other illicit activities.

A KYB (Know Your Business) strategy ensures compliance with regulatory requirements by verifying the identity and legitimacy of businesses through checks like ownership details, financial records, and legal documentation. It aims to mitigate risks of fraud, money laundering, and other illicit activities.

The function of Know Your Business (KYB) is to verify the identity, legitimacy, and compliance of businesses by assessing their ownership, operations, and regulatory adherence. This ensures trust, reduces fraud, and meets legal obligations for anti-money laundering (AML) and counter-terrorism financing (CTF).

KYB (Know Your Business) is required by financial institutions, fintechs, and businesses to verify and monitor vendors, partners, or corporate clients, ensuring compliance with AML/CFT laws and mitigating fraud and regulatory risks.

The purpose of Know Your Business (KYB) is to verify the legitimacy, ownership, and operations of businesses to prevent fraud, ensure compliance with regulatory standards, and mitigate risks related to financial crimes like money laundering and terrorism financing.

KYB (Know Your Business) ensures compliance with regulatory requirements, mitigates risks of fraud and financial crimes, and enhances trust by verifying the legitimacy and ownership structure of businesses. It streamlines onboarding while safeguarding against reputational and financial risks.

What is Significant Beneficial owner (SBO)

Significant Beneficial Owner (SBO) In India: Definition & Guide

Significant Beneficial Ownership (SBO) has gained considerable attention in India, especially following the updates in November 2023 to the Companies Act, 2013 and the Limited Liability Partnership (LLP) Act, 2008. Recognised globally as a measure to increase transparency and accountability, SBO requirements in India aim to unveil the individuals who have actual control or substantial influence over a corporate entity, even when their ownership is indirect. These regulations form part of India’s broader agenda to combat financial malpractices, including money laundering, tax evasion, and fraud.

What Is A Significant Beneficial Owner (SBO)?

In the Indian context, the concept of SBO mandates that any individual who holds significant indirect rights, whether through voting shares, financial benefits, or decision-making power, must be identified and disclosed. The term “Significant Beneficial Owner” (SBO), specifically under the Limited Liability Partnership (Significant Beneficial Owners) Rules, 2023, is defined as:

An individual who, acting alone, jointly, or through one or more persons or trusts, holds certain rights or entitlements within a reporting limited liability partnership (LLP). Specifically, an SBO must meet at least one of the following criteria:

  1. Contribution: Holds indirectly or together with direct holdings, at least 10% of the contribution in the LLP.
  2. Voting Rights: Holds at least 10% of the voting rights related to management or policy decisions in the LLP.
  3. Profit Participation: Has the right to receive or participate in at least 10% of the total distributable profits or other distributions in a financial year, through indirect holdings alone or along with direct holdings.
  4. Influence or Control: Has the right to exercise, or exercises, significant influence or control in any manner other than through direct holdings alone.

This definition is further qualified by rules that exclude individuals who only hold rights directly, without meeting the indirect or combined thresholds stated above.

The Ministry of Corporate Affairs (MCA) has enforced these obligations to create a transparent corporate ecosystem where investors, regulators, and stakeholders can trust information about a company’s ultimate controllers. For entities structured as LLPs, similar SBO requirements now apply, introducing new compliance layers for firms and individual beneficiaries alike.

The SBO rules affect not only the companies but also various stakeholders and the broader investment climate. The ongoing drive towards transparent ownership structures reflects India’s commitment to aligning with international standards set by organisations like the Financial Action Task Force (FATF)

Criteria for Identifying Significant Beneficial Owners in India

The regulations surrounding Significant Beneficial Ownership (SBO) in India were significantly revised with the 2023 amendment, introducing a more stringent framework for identifying and declaring beneficial owners in Limited Liability Partnerships (LLPs) and companies. The amendment, enacted by the Ministry of Corporate Affairs (MCA) in November 2023, aims to address gaps in transparency, especially concerning entities with complex ownership structures. The 2023 SBO rules place increased responsibility on LLPs and companies to identify individuals who exert significant control, whether directly or indirectly.

Key Definitions Around SBO Under The 2023 Amendment

  1. Significant Beneficial Owner (SBO): Under the 2023 rules, an SBO is an individual who holds at least 10% of either the contribution, voting rights, or distributable profits in a partnership or company. This ownership can be indirect or combined with any direct holdings. Notably, this threshold for SBO identification aligns with global standards, ensuring that entities with any significant influence are documented.
  2. Indirect and Direct Holdings: The amendment specifies that an individual is considered an SBO if they hold rights or entitlements both indirectly and directly in an entity. For instance, if an individual controls an entity that, in turn, holds a stake in a company or LLP, their indirect stake must be calculated in the total ownership assessment.
  3. Control and Significant Influence: The amendment expands on “control” to include the right to appoint majority partners, or to control policy decisions, whether directly or through a group of people acting in concert. This criterion ensures that those who wield control without a direct ownership stake are not overlooked.

Other Scenarios For SBO Determination

The amendment has introduced detailed explanations to capture different ownership structures, making the rules comprehensive yet nuanced. Key scenarios are covered as follows:

  • Body Corporate Ownership: If an individual holds a majority stake in a corporate partner of an LLP or company, they are deemed to have an SBO stake.
  • Trust Ownership: When the partner is a trust, the SBO status is conferred based on whether the individual is a trustee (for discretionary trusts), a beneficiary (for specific trusts), or a settlor (for revocable trusts).
  • Pooled Investment Vehicles (PIVs): For entities controlled by PIVs, individuals such as general partners, investment managers, or CEOs with influence over the PIV are considered SBOs, especially if these PIVs are based in jurisdictions with weak regulatory standards.

Other Key SBO Compliance Requirements

The 2023 SBO rules mandate that LLPs and companies actively identify SBOs within their structure. Reporting LLPs and companies are now required to file returns with the Registrar of Companies using Form BEN-2 within 30 days of identifying an SBO. They must also maintain a register of SBOs, available for inspection by regulatory authorities and stakeholders, to foster transparency and corporate responsibility.

Obligation To Declare Indirect Control

A significant feature of the 2023 amendment is the requirement for SBOs to declare any indirect control they possess. This includes control via family trusts, subsidiary companies, or holding companies. For example, if an individual holds majority control in an LLP’s corporate partner or the ultimate holding entity, that individual must declare themselves as an SBO.

The amended rules also include provisions for situations where multiple individuals act jointly with a common intent, allowing regulators to identify SBOs even in cases where ownership is shared across several individuals or trusts.

Penalties And Non-Compliance With SBO Guidelines

Non-compliance with the 2023 SBO rules can lead to strict penalties. LLPs and companies that fail to declare SBOs or provide inadequate information are at risk of tribunal-directed sanctions, which may include restrictions on profit distribution, suspension of voting rights, or transfer restrictions. The MCA has underscored these enforcement measures to ensure adherence to SBO regulations and to discourage any attempts to obscure actual ownership.

SBO Compliance Obligations For Companies And LLPs

The updated Significant Beneficial Ownership (SBO) regulations have transformed compliance obligations for companies and Limited Liability Partnerships (LLPs) in India. The revised framework now imposes stricter duties on entities to accurately identify, record, and report individuals with significant beneficial control, addressing prior gaps in transparency. Companies and LLPs must now uphold clear records of ownership and control, particularly where indirect ownership structures could obscure true influence.

Identification And Notification Requirements

Under the current regulations, companies and LLPs must take proactive steps to identify and notify SBOs:

  1. Notice Requirement: Companies and LLPs are required to issue formal notices to any non-individual partners or shareholders whose stakes exceed 10%, whether in terms of contribution, voting rights, or share of profits. The notice (Form LLP BEN-4 for LLPs) aims to gather information on potential SBOs, ensuring all possible avenues of control or influence are assessed.
  2. Duty to Declare: Identified SBOs are required to submit a declaration in Form LLP BEN-1 (for LLPs) within 90 days of the regulations’ effective date or 30 days of any change in ownership status. This formal declaration serves to create a verified record of each SBO’s status.
  3. Submission of Form BEN-2: Companies and LLPs must report each identified SBO to the Registrar of Companies within 30 days, formalising the disclosure and providing a verifiable ownership structure for regulatory purposes.
  4. Register of SBOs: Entities are also required to maintain a register of SBOs (Form LLP BEN-3 for LLPs), available for inspection during business hours. This register supports transparency by making ownership records accessible to regulatory authorities and stakeholders.

Responsibilities Of SBOs

The updated regulations place additional responsibilities on the SBOs themselves. Individuals who meet the criteria for significant beneficial ownership must declare their status within the prescribed timeline. Failing to comply may lead to limitations on their rights within the company or LLP, such as suspension of voting privileges or profit distribution entitlements. These measures ensure that SBOs are accountable for transparently disclosing their interests and influence.

Compliance Timelines And Record-Keeping

The regulations mandate strict timelines for compliance to ensure timely and consistent reporting. Initial SBO declarations must be filed within 90 days of the rule’s effective date, with any subsequent changes reported within 30 days. This ensures records accurately reflect current ownership structures, preventing attempts to obscure significant control.

Exemptions To SBO Compliance

Certain entities are exempt from these disclosure obligations, reducing unnecessary reporting. Exemptions include those entities where the Central Government, State Government, or local authority holds a stake, as well as specific investment vehicles regulated by the Securities and Exchange Board of India (SEBI), such as mutual funds, alternative investment funds (AIFs), and real estate investment trusts (REITs).

Tribunal Powers And Penalties For Non-Compliance

The regulations empower tribunals to impose penalties for non-compliance or inadequate disclosures. Companies or LLPs failing to fulfil SBO obligations may face sanctions, including:

  • Profit Distribution Restrictions: SBOs may have their profit distribution rights temporarily suspended.
  • Voting Rights Suspension: The tribunal may suspend an SBO’s voting rights, restricting their influence over company or LLP decisions.
  • Restrictions on Interest Transfer: The tribunal may limit the transfer of interests associated with the SBO’s contribution, effectively preventing transfers until compliance is achieved.

Impact On Indian Corporate Governance

These SBO regulations underscore the importance of transparency and corporate governance in the Indian business landscape. By requiring that beneficial ownership details be disclosed and verified, the rules align Indian practices with international standards, fostering greater trust among investors and mitigating risks associated with hidden ownership. This contributes to a more robust corporate environment in India, reinforcing accountability and financial transparency at every level.

Impact Of SBO Regulations On India’s Corporate

The SBO regulations have introduced significant changes in the Indian corporate landscape, fostering a more transparent and accountable business environment. By focusing on the identification and disclosure of ultimate beneficial owners, these regulations aim to prevent financial misconduct and reduce the risks associated with concealed ownership structures. The broader impact of these rules has resonated across various areas of corporate governance, investor relations, and regulatory compliance.

Enhanced Corporate Governance

A primary goal of the SBO regulations is to strengthen corporate governance by making it harder for individuals to hide behind complex ownership structures. Companies and LLPs are now compelled to establish transparent reporting mechanisms that accurately reveal who truly controls or benefits from their operations. This transparency ensures that ownership and control are aligned with the company’s declared interests, reducing conflicts of interest and fostering a culture of integrity. The benefits of enhanced corporate governance are twofold: companies gain credibility, and investors feel more secure knowing they can verify ownership details.

Increased Investor Confidence

Investor trust is crucial to attracting and retaining capital, and the SBO regulations play a key role in supporting this trust. By mandating the disclosure of all individuals with substantial control or influence, the regulations allow retail and institutional investors to make more informed decisions. Access to clear ownership records means investors can assess any potential conflicts of interest or risks associated with hidden control. In particular, retail investors have shown growing interest in Indian markets, with the number of registered retail investors on the Bombay Stock Exchange increasing by 27% year-on-year as of December 2023. The SBO regulations contribute to an environment where both foreign and domestic investors have confidence in the market’s transparency and fairness.

Alignment With International Standards

Globally, the Financial Action Task Force (FATF) and similar bodies have long advocated for transparency in beneficial ownership to combat money laundering and financial fraud. The SBO rules position India as a proactive participant in the global movement towards financial transparency, aligning Indian practices with those of developed economies. Many countries, including the United Kingdom, the United States, and European Union members, have enacted similar rules to mandate ownership disclosure. By aligning with these standards, Indian companies are more likely to attract foreign investment and participate smoothly in international trade, given the assurance that they adhere to globally recognised practices.

Compliance Burden And Operational Challenges

While the SBO regulations promote transparency, they also introduce a compliance burden for companies and LLPs. The need to constantly monitor ownership structures, issue notices, and maintain up-to-date records can be resource-intensive, particularly for smaller entities with limited compliance teams. Moreover, entities with complex ownership layers may find it challenging to trace indirect ownership accurately. Despite these challenges, the regulations also serve as a deterrent to opaque ownership structures, prompting companies to simplify their ownership models where feasible.

Legal Clarity And Dispute Resolution

The SBO regulations have also brought clarity to the legal framework surrounding corporate ownership and control. With clear guidelines on defining and identifying an SBO, companies now have a straightforward process to follow. The regulations also empower companies to enforce compliance by approaching tribunals to restrict the rights of non-compliant SBOs, adding a layer of enforcement that discourages attempts to evade disclosure. This provision reduces the likelihood of disputes over ownership and control, as the rules now offer a transparent pathway for identifying SBOs and enforcing compliance.

Overall Economic Impact

In the long term, the SBO regulations are expected to contribute to the Indian economy by creating a stable and transparent business environment that attracts both domestic and international capital. Companies that comply with these regulations are seen as more trustworthy, making their shares and securities more appealing to investors. This increase in transparency can lower the cost of capital, support economic growth, and enhance India’s position as a global economic player. By safeguarding the interests of investors and enforcing corporate accountability, the SBO regulations have laid the groundwork for a more resilient and investor-friendly market.

FAQs around Significant Beneficial Owner (SBO)

A Significant Beneficial Owner (SBO) is an individual who directly or indirectly holds at least 10% of the ownership, voting rights, or profit-sharing rights in a company or LLP, or has significant influence or control over it.

Significant beneficial ownership (SBO) in an LLP refers to an individual who, alone or with others, directly or indirectly:

  1. Holds at least 10% of the LLP’s contribution,
  2. Controls at least 10% of voting rights on management decisions,
  3. Receives or participates in at least 10% of the distributable profits, or
  4. Exercises significant influence or control in ways beyond direct ownership.

To obtain the Significant Beneficial Owner (SBO) ID, an individual must:

  1. Submit a declaration using Form LLP BEN-1 to the reporting Limited Liability Partnership (LLP) if they meet the SBO criteria (e.g., holding at least 10% of contribution, voting rights, or profit participation).
  2. The LLP then files this information with the Registrar in Form LLP BEN-2.
  3. Upon verification, the Registrar records the individual as an SBO and assigns an SBO ID as part of the compliance documentation under the Companies Act, 2013.

This process ensures the identification and documentation of SBOs within the reporting LLP.

To calculate the Significant Beneficial Ownership (SBO) percentage in an LLP, follow these steps:

  1. Identify Direct and Indirect Holdings: Determine the individual’s percentage of direct contribution, voting rights, or profit participation, as well as any indirect holdings through trusts, partnerships, or other entities.

  2. Aggregate Holdings: Add the direct and indirect holdings (if any) to get the total percentage.

  3. Assess SBO Criteria: Check if the aggregated percentage meets or exceeds 10% for contribution, voting rights, or profit participation. If it does, the individual qualifies as an SBO.

Only holdings that cumulatively reach at least 10% are relevant for SBO classification.

In India, Significant Beneficial Ownership (SBO) Articles refer to rules established under the Companies Act, 2013, and the Limited Liability Partnership Act, 2008, which require individuals or entities to disclose their significant beneficial ownership in companies and LLPs. Under these regulations, an individual is classified as an SBO if they, directly or indirectly, hold at least 10% of shares, voting rights, or the right to receive at least 10% of distributable profits in an entity. This disclosure mandate aims to increase transparency in business ownership, prevent illicit activities like money laundering, and ensure compliance with the government’s financial regulations.

The main difference between a Beneficial Owner (BO) and a Significant Beneficial Owner (SBO) lies in the extent of their control or interest in a company or LLP:

  1. Beneficial Owner (BO): Generally, any person who enjoys the benefits of ownership (like profits or voting rights) in a company or LLP, even if they are not listed as the legal owner.

  2. Significant Beneficial Owner (SBO): Specifically defined in regulations, an SBO is a beneficial owner who holds a substantial level of control or interest, typically defined as at least 10% of shares, voting rights, or profit participation in the entity, or who has the right to exert significant influence or control.

In essence, while all SBOs are beneficial owners, not all beneficial owners qualify as SBOs due to the specific thresholds that define “significant” ownership or control.

What is Third Party Verification?

What Is Third-Party Verification (TPV)? All You Need To Know

Ensuring the accuracy and authenticity of information provided by vendors, suppliers, and other third parties is essential for mitigating risks and ensuring compliance. Third-party verification (TPV) serves as a crucial process, allowing companies to validate the credentials, claims, and transactions of external entities. By utilising independent verification from a neutral party, such as AuthBridge, businesses can trust the data they rely on for important decisions, whether it’s for vendor onboarding, background checks, or regulatory compliance.

This blog talks about the significance of third-party verification, its key processes, and how it contributes to building trust, reducing fraud, and adhering to legal standards. Whether you’re looking to improve vendor management or strengthen your due diligence process, understanding the core aspects of third-party verification is essential for modern business operations.

What Is Third-Party Verification?

Third-party verification (TPV) is the process in which an external organisation validates the information, claims, or actions of a company or individual on behalf of another entity. This could include verifying a customer’s details, or a vendor’s credentials, or ensuring compliance with industry regulations. The use of third-party verifiers is especially critical when businesses need impartial validation, as it eliminates conflicts of interest and ensures objective results.

Typically, third-party verification ensures that companies can make informed decisions based on verified information, minimising the risk of errors, fraud, and non-compliance. The third-party verification process covers a wide range of industries and scenarios, from financial audits to verifying security practices in supply chains. It helps build confidence among stakeholders, including investors, regulators, and customers, by adding an extra layer of credibility to the business’s operations.

Types And Use Cases of Third-Party Verification

Third-party verification (TPV) can be tailored to meet the specific needs of businesses across various industries. Depending on the nature of the transaction or the relationship being verified, TPV can serve different purposes, from ensuring vendor integrity to confirming customer intentions. Below are the common types of third-party verification and their relevant use cases:

1. Vendor and Supplier Verification

Companies rely heavily on external vendors and suppliers for various products and services. Ensuring the legitimacy and credibility of these partners is crucial for minimising risks in the supply chain. Vendor verification involves checking the credentials, financial stability, and past performance of a supplier before engaging in any business relationship.

  • Use Case: A manufacturer sourcing raw materials might engage a third-party verifier to assess a new supplier’s financial health, ethical practices, and adherence to environmental regulations. This ensures the supplier aligns with the company’s standards and mitigates the risk of supply chain disruptions or reputational damage.

2. Third-Party Background Checks

Third-party verification is often used for background checks in hiring, particularly for critical roles where trust and compliance are paramount. The background check process involves verifying the candidate’s education, employment history, criminal records, and other personal details to prevent fraudulent hires.

  • Use Case: Companies in the financial sector may hire a third-party agency to conduct a thorough background check on potential employees. This ensures that the candidates have a clean history and can be trusted with sensitive financial information.

3. Regulatory and Compliance Verification

With changing regulations, businesses must ensure that their partners and vendors comply with industry-specific rules and laws. Third-party verification helps validate whether a vendor or business partner adheres to necessary regulatory compliance standards, such as data privacy regulations or industry-specific certifications.

  • Use Case: A healthcare company partnering with a third-party software provider may require compliance verification to ensure that the provider adheres to HIPAA (Health Insurance Portability and Accountability Act) standards for data security and patient privacy.

4. Financial Verification

For businesses engaging with vendors, customers, or investors, ensuring financial credibility is paramount. Third-party financial verification involves reviewing an entity’s financial records, credit ratings, and other financial data to confirm its financial standing and reliability.

  • Use Case: A bank considering a loan for a small business may request a third-party financial verification of the borrower’s assets and financial history to assess the risk before approving the loan.

5. Security and Data Privacy Verification

In sectors like IT, where data privacy and security are top priorities, third-party verification is often used to ensure that vendors or service providers follow best practices for data protection. Security verification ensures that partners comply with the necessary security protocols, such as encryption standards and cybersecurity regulations.

Use Case: An e-commerce platform might engage a third-party verifier to audit and verify the data security protocols of a payment gateway provider, ensuring that the gateway complies with PCI-DSS (Payment Card Industry Data Security Standard) requirements.

Benefits Of Third-Party Verification

Third-party verification (TPV) offers a multitude of advantages for businesses, ranging from enhanced trust to better compliance management. By involving an impartial, external party to verify information, companies can ensure transparency, reduce risks, and improve overall efficiency. Below are some key benefits of implementing third-party verification:

1. Enhanced Trust and Credibility

Engaging a third-party verifier adds an extra layer of confidence for all stakeholders involved, including customers, investors, regulators, and business partners. By using independent verification services, businesses can demonstrate their commitment to accuracy and reliability.

2. Reduced Risk of Fraud

One of the primary reasons businesses invest in third-party verification is to mitigate the risk of fraud. Whether it’s verifying a vendor’s credentials, checking a new hire’s background, or ensuring that a customer’s financial details are accurate, TPV helps reduce fraudulent activities. This is especially crucial for sectors like finance, healthcare, and e-commerce, where fraud can have significant consequences.

3. Compliance With Regulatory Standards

In today’s highly regulated industries, businesses must adhere to strict compliance guidelines. Third-party verification plays a pivotal role in ensuring that all partners, vendors, and internal processes comply with relevant laws and standards, such as data privacy regulations or industry-specific certifications. Non-compliance can result in fines, legal issues, and reputational damage.

4. Streamlined Due Diligence

The due diligence process can be complex, especially when dealing with new vendors, partners, or clients. By outsourcing the verification process to a third party, businesses can streamline their due diligence process, ensuring that all necessary checks are completed without overburdening internal teams. This not only saves time but also provides more comprehensive verification results.

5. Objective and Impartial Evaluation

One of the most important aspects of third-party verification is that it provides an objective, unbiased evaluation. Internal assessments may carry inherent biases, especially if they are conducted by individuals with vested interests. TPV eliminates this issue, offering an impartial assessment of the information being verified.

6. Improved Efficiency Through Automation

Many third-party verification providers use advanced technology to automate certain aspects of the verification process, such as background checks or vendor risk assessments. This not only accelerates the verification process but also reduces human error, ensuring that businesses receive accurate and timely results.

Challenges Of Third-Party Verification

While third-party verification (TPV) offers numerous benefits, it also comes with certain challenges that businesses must navigate to ensure its successful implementation. Understanding these obstacles can help organizations better prepare and mitigate potential issues. Here are some of the key challenges associated with third-party verification:

1. Data Privacy and Security Concerns

One of the primary challenges in third-party verification is the handling of sensitive data. Verifiers often require access to confidential information, such as financial records, personal identification, or internal business data, to perform their tasks. Ensuring that this data is protected throughout the verification process is critical, especially in sectors with stringent data protection regulations like healthcare, finance, and e-commerce.

2. Regulatory Compliance Complexity

As third-party verifiers operate across various industries and regions, they must navigate a complex regulatory landscape. Different countries and industries have specific laws regarding regulatory compliance, and TPV providers must stay up-to-date with evolving rules. Ensuring that all third-party vendors meet local and international legal requirements can be a challenge for companies working in multiple markets.

3. Cost Implications

The cost of employing third-party verification services can sometimes be a barrier for businesses, especially small and medium-sized enterprises (SMEs). Although the benefits of TPV often outweigh the costs in terms of risk reduction and compliance, the upfront investment in hiring a reputable verification provider can be significant.

4. Integration With Existing Systems

Another challenge companies face is integrating third-party verification solutions with their existing infrastructure. Businesses with legacy systems may find it difficult to seamlessly incorporate external verification tools, which could lead to operational delays or inefficiencies. Ensuring that the verification process integrates smoothly with internal systems is crucial for avoiding workflow disruptions.

5. Dependence on Third-Party Reliability

When outsourcing verification to a third-party vendor, businesses are dependent on the reliability and accuracy of the service provider. If the verifier fails to deliver accurate results, it could lead to legal and financial repercussions. Therefore, selecting a trustworthy and reliable third-party verification service is essential, but reliance on an external entity also poses risks.

6. Potential for Delays

In some cases, third-party verification can introduce delays, especially when dealing with a high volume of checks or complex assessments. If the third-party verifier does not operate efficiently or is overburdened with work, it could slow down critical processes such as vendor onboarding, due diligence, or background checks.

Best Practices For Implementing Third-Party Verification

Implementing an effective third-party verification (TPV) system requires careful planning, adherence to industry standards, and the use of best practices to ensure successful outcomes. By following these guidelines, businesses can optimize their verification processes, minimize risks, and enhance overall efficiency. Below are key best practices for integrating third-party verification into business operations:

1. Select Reputable Verification Providers

Choosing the right third-party verification provider is crucial to ensuring reliable and accurate results. Companies should thoroughly vet potential TPV vendors based on their experience, certifications, and reputation in the industry. Selecting a vendor that has a proven track record, particularly in your specific sector, can help avoid errors and ensure compliance with relevant regulations.

2. Ensure Compliance With Data Privacy Laws

Given the sensitive nature of the information involved in third-party verification processes, businesses must ensure that they and their TPV providers comply with all applicable data privacy laws. This includes local regulations, such as the General Data Protection Regulation (GDPR) in Europe or the DPDP in India, as well as industry-specific data security standards.

3. Integrate Verification Into Existing Workflows

One of the key challenges businesses face when implementing third-party verification is the integration of these processes with existing workflows. To ensure efficiency and minimize disruption, companies should integrate TPV seamlessly into their systems, particularly in areas such as vendor onboarding, risk assessment, and compliance management.

4. Conduct Regular Audits and Assessments

Even after implementing third-party verification, businesses should perform regular audits and assessments to ensure the effectiveness and accuracy of the verification process. This includes checking the performance of TPV providers, verifying compliance with regulatory requirements, and reviewing the quality of the verification reports.

5. Use Technology to Enhance Accuracy and Speed

Automation and advanced technology can significantly improve the efficiency and accuracy of third-party verification processes. By leveraging tools like artificial intelligence (AI) and machine learning, businesses can streamline verification tasks and reduce the likelihood of errors or delays.

6. Develop Clear Vendor and Supplier Agreements

When working with external partners, it’s important to establish clear agreements regarding the verification process. These agreements should outline the responsibilities of each party, including the scope of the verification, timelines, and any compliance obligations. Having well-defined contracts can help avoid misunderstandings and ensure accountability.

Conclusion

Third-party verification (TPV) is essential for businesses to ensure accuracy, reduce risks, and maintain compliance in today’s complex and globalised marketplace. By employing independent verifiers, companies can confidently validate vendor credentials, conduct background checks, and meet regulatory standards, all while enhancing operational efficiency. As technology continues to evolve, the integration of remote verification methods will further streamline the TPV process, making it a critical tool for securing trust and ensuring transparency in business operations.

FAQs around Third-party verification (TPV)

Third-party verification refers to the process of using an independent, external entity to confirm the accuracy, legitimacy, or compliance of information provided by an individual or organization. It ensures objectivity and credibility by having a neutral party validate claims such as identity, qualifications, or legal standing. 

Examples of third-party verification include:

  1. Background Checks – Verifying employment history, education, and criminal records through an external agency.
  2. KYC (Know Your Customer) – Confirming identity documents, such as Aadhaar or passport, via authorized third-party services.
  3. Supplier Audits – Assessing suppliers’ compliance with quality or regulatory standards by independent auditors.
  4. Financial Audits – Independent review of a company’s financial statements to ensure accuracy and compliance.
  5. Certification Services – External verification of industry certifications like ISO or PCI-DSS compliance.

The benefits of third-party verification include:

  1. Enhanced Credibility: It provides independent validation, boosting trust among customers, clients, and partners.
  2. Risk Mitigation: Reduces exposure to fraud, compliance breaches, and operational risks by ensuring accuracy in information.
  3. Regulatory Compliance: Helps meet industry and government regulations by verifying identities, credentials, or business details.
  4. Streamlined Onboarding: Speeds up processes like vendor, partner, or employee onboarding through reliable verification systems.
  5. Improved Decision Making: Provides verified data to make informed, secure business decisions.

Third-party Background Verification (BGV) involves an external agency conducting checks on a candidate’s credentials and history on behalf of a company. The process typically includes:

  1. Identity Verification – Confirming the individual’s identity through official documents.
  2. Educational and Employment History – Verifying academic qualifications and previous work experience.
  3. Criminal Record Check – Checking for any criminal background.
  4. Address Verification – Confirming current and past addresses.
  5. Reference Checks – Contacting previous employers or referees to assess performance and character.
  6. Credit Check – Reviewing financial stability for specific roles.

The third-party verification process involves an independent organization confirming the accuracy and authenticity of information provided by a business or individual. This verification is commonly used in areas such as employee background checks, vendor assessments, and customer due diligence. The process typically includes verifying identity, financial records, legal standing, or compliance with regulations to ensure trustworthiness and mitigate risks for the requesting party.

PAN Card Based KYC: Online And Offline Methods

Introduction

As the financial landscape in India rapidly embraces digitalisation, the importance of Know Your Customer (KYC) compliance has become more important than ever. KYC regulations, mandated by the Reserve Bank of India (RBI) and the Securities and Exchange Board of India (SEBI), ensure financial institutions have a clear understanding of their customers’ identities and risk profiles. This helps combat money laundering, terrorist financing, and other financial crimes.

While various documents contribute to KYC verification, the Permanent Account Number (PAN) card stands out as a benchmark. This blog delves into the critical role of the PAN card in KYC compliance, exploring its functionalities, benefits, and overall process.

What Is KYC?

Know Your Customer or KYC refers to a set of regulations requiring financial institutions to verify the identity and address of their customers. This verification process typically involves two key steps:

  1. Customer Identification: Customers provide documents proving their identity (proof of identity – POI), address (proof of address – POA), and date of birth (DOB).
  2. Risk Assessment: Based on the collected information, the financial institution assesses the customer’s risk profile for potential financial crimes.

Importance Of KYC Compliance

KYC compliance offers several benefits to both financial institutions and customers:

  • Prevents Money Laundering and Terrorist Financing: KYC helps deter criminals from using financial platforms for illegal activities.
  • Mitigates Fraud Risk: Verifying customer identities helps identify and prevent fraudulent activities like identity theft and account takeover.
  • Enhances Customer Experience: Efficient KYC processes can streamline account opening and transaction approvals, leading to a smoother customer experience.
  • Promotes Financial Inclusion: Robust KYC processes can create a more secure environment, encouraging broader participation in the financial system.

Statistics On KYC Compliance In India

KYC (Know Your Customer) compliance in India has grown significantly, driven by regulations from the Reserve Bank of India (RBI) and the Securities and Exchange Board of India (SEBI). The rise in digital financial services has also accelerated KYC implementation across banking, fintech, and investment sectors. Here are some key statistics and insights related to KYC compliance in India:

1. Growth of Digital KYC

  • 2020-2021: The digital KYC verification market saw rapid adoption, particularly during the COVID-19 pandemic. Many banks and financial institutions transitioned to eKYC, driven by the need for contactless services.
  • eKYC Transactions: As per reports, over 2 billion eKYC transactions were recorded between 2020-2021 in India. The adoption rate continues to rise, with increased financial inclusion and digital banking services.
  • Aadhaar-Based eKYC: Aadhaar-based eKYC continues to dominate. As of March 2023, more than 1.4 billion Aadhaar-based eKYC verifications had been conducted.

2. RBI Mandates and Compliance

  • Mandatory KYC for Banking: The RBI has made KYC compliance mandatory for all banking services in India, including opening accounts, applying for loans, and carrying out large transactions.
  • Penalties for Non-Compliance: Banks and financial institutions are subject to strict penalties if they fail to comply with KYC norms. In 2021, the RBI imposed penalties on 14 banks, including major players like SBI and ICICI Bank, for KYC non-compliance.
  • PMLA Guidelines: KYC is also enforced under the Prevention of Money Laundering Act (PMLA) to combat fraud, money laundering, and terrorism financing.

3. Financial Inclusion Through KYC

  • Jan Dhan Accounts: The Pradhan Mantri Jan Dhan Yojana (PMJDY), aimed at financial inclusion, has made KYC essential for opening accounts. Over 480 million Jan Dhan accounts were opened by 2023, with many using Aadhaar-based eKYC for quicker access.
  • KYC for Mutual Funds and Investments: SEBI mandates that all mutual fund investors must complete KYC through a KYC Registration Agency (KRA). By 2023, nearly 100% of new mutual fund investments required KYC compliance.

4. Challenges in KYC Compliance

  • Rural Areas: While digital KYC processes have eased urban compliance, nearly 30-35% of India’s rural population still faces challenges with access to digital infrastructure and documentation, leading to delays in KYC completion.
  • Fraudulent Activities: Despite the robust KYC framework, a 15% rise in financial fraud was reported in sectors like banking and fintech in 2022, indicating the need for continuous improvements in KYC verification methods.

    The PAN Card: Key Details

    The PAN card issued by the Income Tax Department of India serves as a vital document for KYC compliance for several reasons:

    • Universally Recognized Proof of Identity: As a government-issued document, the PAN card is widely accepted as a reliable proof of identity across various sectors in India.
    • Unique Identification Number: Each PAN card holder is assigned a unique 10-digit alphanumeric identifier. This unique identifier allows for easy verification against official records maintained by the Income Tax Department.
    • Nationally Valid Document: Unlike some regional identification documents, the PAN card holds validity across India, making it a suitable option for KYC purposes regardless of the customer’s location.
    • Link to Financial Information: The PAN card is often linked to a customer’s tax information. This linkage can provide financial institutions with additional insights for risk assessment during KYC verification.

    Table 1: Key Features of PAN Card Supporting KYC Compliance

    Feature

    Description

    Benefit for KYC Verification

    Universally Recognized Proof of Identity

    Government-issued document widely accepted for identity verification.

    Ensures reliability and authenticity of customer information.

    Unique Identification Number

    10-digit alphanumeric identifier assigned to each PAN card holder.

    Enables easy verification against official records.

    National Validity

    Valid across India regardless of location.

    Suitable for KYC purposes irrespective of customer’s geographical location.

    Link to Financial Information

    Often linked to a customer’s tax information.

    Provides additional insights for risk assessment.

    Benefits Of Using PAN Card For KYC Verification

    There are several advantages associated with using your PAN card for KYC compliance:

    • Simplified Process: Since the PAN card is widely accepted as a KYC document, the verification process can be faster and more efficient. Many financial institutions have established streamlined processes for KYC verification using PAN cards.
    • Reduced Paperwork: By using your PAN card, you may need to submit fewer additional documents for identity verification. This reduces the burden of document collection for both you and the financial institution.
    • Enhanced Security: The PAN card system incorporates security features to help prevent fraud and misuse. These features include tamper-proof lamination and unique identification numbers, making it difficult to counterfeit or misuse PAN cards.
    • Universal Acceptance: You can utilize your PAN card for KYC compliance across various financial institutions in India, including banks, investment firms, insurance companies, and online payment platforms. This eliminates the need to carry or submit different documents for different institutions.

    Documents Required For KYC Along With PAN Card

    While the PAN card plays a significant role, it’s often used in conjunction with other documents during KYC verification. Here are some commonly requested documents in addition to the PAN card:

    • Proof of Address (POA): Documents like an Aadhaar card, Voter ID card, utility bills (electricity, water, telephone) not older than three months, passport (for foreign citizens), etc., can serve as proof of address.
    • Photograph: A recent passport-sized photograph is usually required for KYC verification.
    • Additional Documents (Depending on the Institution): In some cases, financial institutions may request additional documents such as bank statements, salary slips, investment proofs, or business registration documents (for businesses) for a more comprehensive risk assessment.

    Table 2: Common Documents Required Alongside PAN Card for KYC Verification

    Document Category

    Examples

    Purpose

    Proof of Identity (POI)

    PAN Card, Aadhaar Card, Voter ID Card, Passport (for foreign citizens)

    Verifies the customer’s identity.

    Proof of Address (POA)

    Aadhaar Card, Voter ID Card, Utility Bills (electricity, water, telephone) not older than three months, Passport (for foreign citizens)

    Verifies the customer’s residential address.

    Photograph

    Recent Passport-sized Photograph

    Captures the customer’s likeness for verification purposes.

    Additional Documents (Optional)

    Bank Statements, Salary Slips, Investment Proofs, Business Registration Documents (for businesses)

    Provides further details about the customer’s financial profile and risk assessment.

    PAN Card KYC Offline Process Steps

    The offline process for completing PAN Card KYC is simple and involves submitting physical documents to the relevant authority. Here’s a step-by-step guide:

    1. Download and Fill the KYC Form
      Visit the official website of CDSL Ventures or the financial institution you’re dealing with and download the KYC application form. Fill in all the required details, including personal information like name, address, and PAN number.

    2. Attach Required Documents
      Along with the filled KYC form, you must submit photocopies of the following:

      • ID Proof: PAN card, passport, voter ID, or driver’s license.
      • Address Proof: Recent utility bills (like electricity or phone), bank passbook, ration card, or rental agreement.
      • Passport-size Photograph: A recent photo needs to be attached to the form.
    3. Submit the KYC Form
      Submit the completed form along with the necessary documents to the relevant financial institution or mutual fund intermediary. Ensure that the documents are self-attested before submission.

    4. Verification
      Once submitted, the documents will undergo a verification process by the concerned authority. This might include a representative physically verifying your information.

    5. Completion
      After the verification process is complete, you will receive confirmation that your KYC has been successfully registered. You can now conduct financial transactions using your PAN card.

    PAN Card KYC Online Process​ Steps

    The online process for completing PAN Card KYC is convenient and can be done from the comfort of your home. Here’s a step-by-step guide to help you through the process:

    1. Visit the KYC Registration Agency (KRA) Website
      Go to the official website of any SEBI-registered KRA, such as CAMS, CDSL Ventures, or NSDL. These agencies store and verify KYC information for financial transactions.

    2. Select the eKYC Option
      On the KRA website, select the option for “eKYC” or “KYC Registration.” Some websites may also have an option specifically for “KYC using PAN Card.”

    3. Enter PAN Card Details
      Fill in your PAN card number and other basic details like your full name, date of birth, and email ID/mobile number. This information is used to verify your identity.

    4. Submit OTP for Verification
      After entering your details, you will receive a One-Time Password (OTP) on your registered mobile number (linked to your Aadhaar card). Enter the OTP to verify your identity.

    5. Upload Required Documents
      You will need to upload scanned copies of the following documents:

      • ID Proof: PAN card (mandatory)
      • Address Proof: Aadhaar card, passport, voter ID, or any other valid address proof.
      • Passport-size Photograph: A recent photograph in digital format.
    6. Complete Video KYC (if required)
      Some KRAs may require you to complete a short video verification process to further validate your identity. This can typically be done using your smartphone or computer with a camera.

    7. Submit the Application
      Once all the details and documents are uploaded, review the information and submit the form.

    8. Track KYC Status
      After submission, you can track the status of your KYC verification by visiting the same website and entering your PAN details. The status will show as “Verified” once the process is successfully completed.

    Additional Tips:

    • Ensure your mobile number is linked with your Aadhaar card as it’s required for OTP verification.
    • Double-check all document scans for clarity before uploading.
    • The process typically takes a few days, but can be faster depending on the KRA.

    FAQs around PAN-based KYC

    Yes, an instant PAN card is valid for KYC purposes, provided it is verified through Aadhaar-based eKYC or other authorised verification methods. The instant PAN, issued in digital format, holds the same legal validity as a physical PAN card for identity verification in KYC processes.

    A DSC-based PAN application uses a Digital Signature Certificate (DSC) to apply for a Permanent Account Number (PAN) online. The DSC serves as an electronic signature for identity verification, making the process paperless. Applicants submit required documents digitally, sign them using the DSC, and complete the application without the need for physical paperwork.

    Yes, you can complete KYC without a physical PAN card. You can use an e-PAN (electronic PAN) or provide the PAN number during the eKYC process, which can be verified digitally through Aadhaar-based eKYC or other government-authorised platforms.

    Yes, banks in India accept ePAN as a valid document for KYC (Know Your Customer) verification. It is considered equivalent to the physical PAN card for most banking transactions, including account opening, provided it is a valid and digitally signed document issued by the Income Tax Department.

    Both ePAN and physical PAN are equally valid forms of PAN. The main difference is that ePAN is a digital version, accessible online and useful for quick KYC and digital transactions, while physical PAN is a hard copy card often required for in-person verifications. ePAN offers more convenience and accessibility, but both serve the same purpose.

    Yes, you can convert your ePAN to a physical PAN card. You need to apply for a reprint of your PAN card through the NSDL or UTIITSL portal, pay the required fee, and the physical card will be sent to your registered address.

    Yes, e-PAN is free of cost for first-time applicants. However, there may be a nominal fee for reprinting or updating details.

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