The NPCI UPI Information Security Framework 2025 sets mandatory standards for all UPI ecosystem participants to combat evolving cyber threats. It requires annual audits by CERT-In empanelled organizations, full vulnerability remediation, and alignment with global benchmarks like ISO 27001 and PCI DSS.
Framework Introduction
UPI, developed by the National Payments Corporation of India (NPCI), enables seamless linking of multiple bank accounts via a single mobile app, processing billions of transactions monthly. The 2025 framework responds to rising cyber risks by mandating uniform security protocols across banks, payment service providers (PSPs), and third-party apps. It emphasizes proactive threat management, system resilience, and strict compliance reporting by December 31 annually.
Key objectives include enforcing the CIA triad—Confidentiality through encryption and tokenization, Integrity via hashing and digital signatures, and Availability with failover systems. All entities must report audit findings transparently to NPCI, fostering a security-first ecosystem.
Applicability and Stakeholders
The framework applies to issuing and acquiring banks, PSPs, third-party application providers (TPAPs), technology service providers, and IVR platforms. Senior leaders like CISOs drive governance, ensuring end-to-end coverage from mobile apps to backend infrastructure. Non-compliance risks penalties, API throttling, or suspension, as seen in related UPI API guidelines (OC-215).
Core Compliance Requirements
Participating entities undergo comprehensive security audits by CERT-In empanelled auditors before onboarding and yearly. Audits cover full scopes: applications, networks, APIs, and operations, with zero pending vulnerabilities allowed in final reports. Reports submit by year-end, promoting full remediation.
Additional mandates include real-time monitoring, AI fraud detection, and business continuity planning (BCP). Entities implement multi-factor authentication (MFA), secure SDK integrations, and vulnerability assessments continuously.
Governance and Security Controls
Governance focuses on policy, compliance roles, risk management, and legal adherence. Controls span data security, identity access management (IAM), network security, application lifecycle security (AppSec), incident response, and fraud risk mitigation. Infrastructure security, logging, monitoring, and architecture reviews form pillars.
The framework adopts Zero Trust Architecture, aligning with NIST CSF, RBI guidelines, and DPDP Act. Operational reviews include BCP, resiliency testing, and VAPT re-assessments.
Audit Process Breakdown
Audits start with pre-audit readiness: gap analysis against NPCI checklists and document reviews. Vulnerability Assessment and Penetration Testing (VAPT) targets UPI apps, APIs, networks, and cloud setups, using OWASP Top 10 and NPCI-specific threats. Post-testing, remediation verification ensures closure before final submission.
CERT-In empanelled auditors like Certcube Labs Pvt Ltd conduct these, minimizing disruptions in live environments.
Role of Empanelled Organizations
CERT-In empanels auditors for UPI InfoSec audits, verifying qualifications and methodologies. These firms assess risks, controls, and compliance across IT infrastructure, apps, and operations.
Certcube Labs Pvt Ltd, a CERT-In empanelled and ISO 27001 certified firm, specializes in NPCI UPI audits. They cover IT hardening, app security for UPI/RuPay/IMPS, VAPT, threat modeling, and end-to-end support from gap analysis to NPCI submission. Their expertise aids banks and fintechs in building resilience, handling payment ecosystems without major downtime.
Detailed Security Measures
Data and Identity Security
Robust encryption protects sensitive data in transit and at rest. IAM enforces least privilege, MFA, and role-based access. Tokenization minimizes PII exposure.
Network and Infrastructure
Firewalls, segmentation, and server hardening prevent lateral movement. Load balancing ensures availability during peaks.
Application and API Security
Secure SDLC integrates API rate-limiting, documentation, and monitoring per OC-215 guidelines. VAPT identifies OWASP risks in UPI flows.
Incident Response and Monitoring
Real-time logging detects anomalies; AI flags fraud like phishing or deepfakes. Drills test BCP/DR annually.
Alignment with Global Standards
| Standard | Framework Alignment | Key UPI Application |
|---|---|---|
| ISO 27001 | ISMS governance | Policy and risk management |
| PCI DSS | Payment data protection | Encryption and tokenization |
| NIST CSF | Threat management | Identify, protect, detect pillars |
| Zero Trust | Continuous verification | API and access controls |
| RBI/DPDP | Privacy compliance | Data minimization and consent |
This table highlights how the framework integrates benchmarks for comprehensive coverage.
Implementation Challenges
Entities face hurdles in full remediation timelines and end-to-end scoping. Smaller TPAPs struggle with advanced tools like AI monitoring. Solution: Partner with empanelled auditors early for gap analysis.​
Case Insights: Certcube Labs in Action
Certcube Labs delivers structured audits: pre-checks, VAPT on UPI stacks, remediation guidance, and reports. For a PSP bank, they identified API exploits, enabled fixes, and ensured zero-open issues for NPCI submission. Their no-disruption approach suits live payment systems. As CERT-In experts, they extend to IRDAI, UIDAI, aligning multi-regime compliance.