NPCI and UPI Security and Compliance Audit

NPCI expects annual compliance reports by December 31 each year. Entities must close all open findings and submit a final compliance report with no open findings. Planning your audit engagement at least 10-12 weeks before the deadline ensures adequate time for testing, remediation, revalidation, and final report issuance.

No, the audit scope differs significantly by role. PSP audits focus on bank-side UPI infrastructure, NPCI connectivity, switch integration, and TPAP oversight. TPAP audits focus on mobile app security, SDK integration, device binding, customer data handling, and India-only data storage. Security Brigade maps the correct variant based on your ecosystem role.

While NPCI does not explicitly mandate CERT-In empanelment for all UPI audits, RBI-regulated entities (banks, NBFCs, payment aggregators) are required to use CERT-In empanelled auditors for their security and system audits. Using a CERT-In empanelled auditor like Security Brigade ensures the audit report carries regulatory credibility across both NPCI and RBI requirements.

TPAPs must store UPI payment data only in India. RBI further clarifies that payment data includes customer data, payment-sensitive data, payment credentials, and transaction data. Any data processed abroad for transaction purposes must be deleted from foreign systems and retained only in India. Security Brigade validates data localization across production databases, replicas, logs, backups, DR sites, analytics stores, and third-party processors.

NPCI's 2025 framework guidance requires entities to close open findings before submitting the compliance report. Reports with open findings may block new onboarding, delay feature launches, or trigger escalation. Security Brigade includes remediation support and closure validation as part of every engagement to ensure the final report submitted to NPCI contains no open findings.

A typical engagement takes 8 to 12 weeks from scoping through final report issuance, depending on the number of applications, APIs, and integrations in scope and the time required for remediation. Security Brigade recommends starting the engagement by September to comfortably meet the December 31 deadline. Complex PSP or multi-TPAP environments may require earlier planning.

Yes, but these are feature-specific add-ons beyond the universal core audit scope. UPI AutoPay adds mandate lifecycle controls. Credit on UPI adds credit instrument mapping and chargeback flows. International UPI adds cross-border processing and data localization for foreign components. Security Brigade scopes these add-ons based on which UPI features your entity actually supports.

Yes. BBPS/BBPOU audits focus on bill payment ecosystem controls including biller and agent onboarding, BBPCU/BBPOU integration, ON-US/OFF-US transaction flows, settlement, refunds, disputes, and compliance with BBPS procedural and technical standards. While both fall under the NPCI ecosystem, the audit scope, checklist, and control requirements are distinct. Security Brigade delivers both as part of a unified NPCI compliance engagement.

The RBI System Audit Report (SAR) is a separate regulator-mandated audit covering broader system and security controls for RBI-regulated entities. For entities that participate in both the NPCI ecosystem and hold RBI licenses (such as PSP banks or payment aggregators), both audits may be required. Security Brigade coordinates both engagements to avoid scope duplication, leverage shared evidence, and reduce audit fatigue for your teams.

Yes. Security Brigade maps audit scope across all NPCI products your entity participates in, combining the universal core with role-specific and product-specific requirements. A single coordinated engagement covers UPI, BBPS, and RuPay audit requirements, producing a unified compliance report. This reduces effort, cost, and timeline compared to running separate audits for each product.