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What are restrictions on storage of actual card data?

Reserve Bank of India (RBI) restricts storage of actual card data [i.e. Card-on-File (CoF)] by non-bank payment aggregators and merchants.

What is Card-on-File (CoF)?

Card-on-file (CoF) is the storing of customer card and payment information by a merchant, i.e. keeping card information “on file”.

What are the guidelines on storage of actual card data [i.e. Card-on-File (CoF)]?

No entity in the card transaction / payment chain, other than the card issuers and / or card networks, shall store Card-on-File (CoF) data, and any such data stored previously shall be purged.

From when are the restrictions on storage of actual card data [i.e. Card-on-File (CoF)] applicable?

Reserve Bank of India (RBI) had periodically extended the deadline for effecting the restriction on storage of actual card data [i.e. Card-on-File (CoF)] from June 30, 2021 to September 30, 2022, taking into account the representations received from the stakeholders.

All entities, except card issuers and card networks, are required to purge the CoF data before October 01, 2022.

What relaxations are allowed for “guest checkout transactions”?

For ease of transition to an alternate system in respect of transactions where cardholders decide to enter the card details manually at the time of undertaking the transaction (commonly referred to as “guest checkout transactions”), the following are permitted as an interim measure –

  • Other than the card issuer and the card network, the merchant or its Payment Aggregator (PA) involved in settlement of such transactions, can save the CoF data for a maximum period of T+4 days (“T” being the transaction date) or till the settlement date, whichever is earlier. This data shall be used only for settlement of such transactions, and must be purged thereafter.
  • For handling other post-transaction activities, acquiring banks can continue to store CoF data until January 31, 2023.


References

Reserve Bank of India. (2020, March 17). 'Guidelines on Regulation of Payment Aggregators and Payment Gateways (Updated as on November 17, 2020)'. Retrieved from https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=11822&Mode=0

Reserve Bank of India. (2021, December 23). 'Restriction on storage of actual card data [i.e. Card-on-File (CoF)]'. Retrieved from https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=12211&Mode=0

Reserve Bank of India. (2022, June 24). 'Restriction on Storage of Actual Card Data [i.e. Card-on-File (CoF)]'. Retrieved from https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=12345&Mode=0

Reserve Bank of India. (2022, July 28). 'Restriction on Storage of Actual Card Data [i.e. Card-on-File (CoF)]'. Retrieved from https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=12363&Mode=0


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