**Executive Summary**
This document is a public consultation issued by the International Financial Services Centres Authority (IFSCA) regarding a draft circular on internet banking services provided by IFSC Banking Units (IBUs) to their clients. It seeks comments, views, and suggestions from the public. Stakeholders must submit their feedback by October 13, 2025. IBUs must comply with the circular by March 31, 2026.
**Key Points / Main Content**
* **Objective of Consultation:**
* To gather public comments/views/suggestions on the types of internet banking services (Information, Interactive, and Transactional) that IBUs need to provide.
* **Background:**
* The IFSCA issued a circular titled "Internet Banking Services to Clients of IBUs" on April 22, 2024.
* Specific compliance requirements for the categories of internet banking services are being laid down.
* **Submission of Comments:**
* Comments/suggestions must be sent via email to Ms. Riddhi Bhandari (riddhi.bhandari@ifsca.gov.in) and Mr. T. P. Samuel Wesly (wesly.samuel@ifsca.gov.in).
* Deadline for submission is October 13, 2025.
* Comments must be in MS Word or MS Excel format and follow the provided format.
* **Information Service Requirements:**
* IBUs must prominently display the list of specified currencies in which transactions are offered.
* IBUs must clearly communicate cut-off timings for executing transactions with the current value date.
* **Interactive Information Exchange Service Requirements:**
* IBUs must provide a unified digital banking dashboard with:
* Real-time balance view across linked accounts.
* Live currency conversion rates.
* Ability to view and download statements in machine-readable formats (CSV, JSON, XML).
* Ability to provide disposal instructions for inward remittances.
* Ability to apply for premature withdrawal of deposits.
* SMS alerts for transactions (charges based on actual usage in India).
* **Transactional Service Requirements:**
* IBU internet banking platforms must have:
* Dual-layer authentication (hardware tokens and/or OTPs).
* Ability to transfer funds between accounts within the same IBU.
* Ability to make payments to third parties holding accounts within the same IBU.
* Ability to initiate payments to third parties holding accounts with another IBU or Bank.
* Ability to create Fixed Deposits.
* User access management for corporate customers with current accounts.
* Ability to create pre-approved beneficiary lists and white-labelling options for fintech partners.
* Ability to initiate currency conversion for pairs mentioned in 3.i
* Ability to auto-schedule payouts.
* Validation tools to identify incorrect account numbers, currency mismatches, or regulatory non-compliance.
* **Compliance Deadline:**
* IBUs must comply with the requirements by March 31, 2026.
**Impact Analysis**
**General Public and Stakeholders**
*Impact*
They have the opportunity to influence the final circular by providing comments and suggestions.
*Action Required*
Review the draft circular and submit comments/suggestions to the provided email addresses by October 13, 2025, in the specified format.
**IFSC Banking Units (IBUs)**
*Impact*
They will need to modify their internet banking services to comply with the new requirements outlined in the final circular.
*Action Required*
Review the draft circular, provide feedback, and prepare to implement the required changes to their internet banking platforms by March 31, 2026.
Key Entities Referenced
International Financial Services Centres Authority (IFSCA): The primary regulatory body issuing the circular.
IFSCA Act, 2019: The act that grants powers to the IFSCA to issue the circular and regulate financial services.
Internet Banking Services to Clients of IBUs: The subject of the draft circular under review, pertaining to the provision of online banking services by IFSC Banking Units.
IFSC Banking Units (IBUs): The entities to which the circular's requirements apply.
INTERNATIONAL FINANCIAL SERVICES CENTRES AUTHORITY
e.F.No. IFSCA-FMPP0BR/5/2024-Banking September 22, 2025
Public Consultation on Circular on” Internet Banking Services to Clients of IBUs-
Review”
I. Objective:
The objective of this public consultation is to seek comments/views/suggestions from
the public on the various types of internet banking services namely Information service,
Interactive information exchange service and Transactional service that IFSC Banking
Units (IBUs) need to provide as specified in the draft circular annexed.
II. Background:
1. Pursuant to the powers conferred under Sections 12 and 13 of the IFSCA Act, 2019,
the Authority issued a circular titled “Internet Banking Services to Clients of IBUs” on
April 22, 2024 (“the circular”). The Circular outlined the requirements governing the
provision of internet banking services by IBUs to their clients
2. On a review, it has been decided to lay down specific compliance requirements with
respect to the categories of internet banking services mentioned in the circular
namely Information service, Interactive information exchange service and
Transactional service. These compliance requirements are specified in draft circular
annexed to this document.
3. General public and stakeholders are requested to forward their
comments/suggestions through e-mail to, Ms. Riddhi Bhandari at
riddhi.bhandari@ifsca.gov.in and Mr. T. P. Samuel Wesly at
wesly.samuel@ifsca.gov.in on or before October 13, 2025 in the attached format.
The comments may be provided in MS Word or MS Excel format only.
Format for providing comments / suggestions
Name, Designation of the Person
Contact No.
Name of Organisation
Page No of Para No. Sub-Para Comments/Suggestions/ Rationale
Public No. Suggested Modifications
Consultati
on of the
circular
1Annexure
Draft circular on “Internet banking services to clients of IBUs –Review”
1. Please refer to the Authority’s circular entitled “Internet banking services to clients
of IBUs” dated April 22, 2024 (“the circular”).
2. On a review, it has been decided to lay down specific compliance requirements with
respect to the various types of internet banking services mentioned in the circular
namely Information service, Interactive information exchange service and
Transactional service.
3. Information service
i. In addition to the information to be provided as per the circular, IBUs shall
prominently display the list of specified currencies in which transactions are
being offered by them to their customers including the facility to convert among
such currencies.
ii. IBUs shall clearly communicate the cut off timing, if any, for executing
transactions with the value date being the date of the transaction.
4. Interactive information exchange service
i. IBUs shall make available a unified digital banking dashboard to their customers
providing, at minimum:
a. Ability to view real-time balances across all linked accounts;
b. Ability to view live conversion rates among currencies, which are offered by
the IBU;
c. Ability to view and download account statements in machine-readable
formats (CSV,JSON,XML) with unique transaction reference, timestamps
and beneficiary details;
d. Ability to provide disposal instructions for inward remittances received
e. Ability to apply for premature withdrawal of deposits
f. SMS alerts for transactions where the customer seeks for such a service and
has a registered number with a telecom service provider in India. The
charges, if any, levied by the IBUs for sending SMS alerts shall be based on
actual usage basis. Where facility for SMS based alerts is not found to be
2feasible facility to intimate the customer through email alerts shall be
provided.
5. Transactional service
i. Transactional services provided through the internet banking platform of the IBU
shall, at minimum, have the following features :
a. Dual-layer authentication (hardware tokens and/or OTPs)
b. Ability to transfer funds between accounts held with the same IBU
c. Ability to make payments to third parties holding accounts with the same IBU
d. Ability to initiate payments to third parties holding accounts with another IBU or
Bank
e. Ability to create Fixed Deposits
f. For Corporate customers holding Current accounts, the IBU shall provide the
facility of user access management including Master user access who may
create or change roles (e.g., Maker-Checker), restrict access to specific
accounts etc.
g. Ability to create pre-approved beneficiary lists and white-labelling options for
fintech partners
h. Ability to initiate currency conversion for pairs mentioned in 3.i
i. Ability to auto-schedule payouts including one-time, date based, recurring, rule-
based executions
j. Validation tools to identify incorrect account numbers to the extent feasible,
currency mismatches, or regulatory non-compliance for eg. the account is in a
FATF compliant jurisdiction etc., before execution
6. IBUs shall comply with the requirements of this circular by March 31, 2026.
Yours faithfully
(Supriyo Bhattacharjee)
Chief General Manager
Department of Banking
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