No. 07Week of September 23, 2026This week’s briefing
Tradecraft

Desk 01For CISOs

The CISO desk

The decisions, deadlines and board questions behind moving customers off phishable authentication.

For CISOs and security leaders.

What matters now

  1. NIST SP 800-63-4 keeps SMS and voice codes as “restricted” authenticators: allowed, but only with a risk assessment, user notice, an alternative and a migration plan.

    Field guide: Preparing for NIST SP 800-63-4: a working plan for banks and agencies
  2. The UAE completed a regulator-ordered phase-out of SMS and email OTP on March 31, 2026, about nine months after it began.

    Dispatch: The UAE’s SMS OTP phase-out is done. What US banks can take from it
  3. Synced passkeys are accepted at AAL2, which gives US organizations a standards-backed phishing-resistant option.

    Explainer: Are synced passkeys phishing-resistant?

Your reading path

Start at the top. Each step builds on the last.

  1. Start here · Field guide

    Moving a bank off SMS OTP: the field guide

    The whole program on one page: flows, replacements, owners.

  2. Then · Dispatch

    The UAE’s SMS OTP phase-out is done. What US banks can take from it

    A finished, regulator-mandated migration to learn from.

  3. Then · Buyer’s guide

    SMS OTP alternatives: a buyer’s guide

    How to evaluate the options before procurement.

  4. Then · Field guide

    Preparing for NIST SP 800-63-4: a working plan for banks and agencies

    The evidence pack for examiners and auditors.

Checklists for this desk

Checklist

SMS OTP flow inventory

Every place your organization still sends a code, ranked by where fraud cashes out.

Rules that apply

Markets most relevant to this desk. Every row links to its primary source.

SMS OTP restrictions by market. Verified September 24, 2026.
MarketRegulatorMeasureTimingStatusPrimary source
UAECentral Bank of the UAESMS and email OTP phase-outJul 2025 – Mar 2026CompleteUAE banks cancel OTPs, switching to in-app verification (The Paypers)
SingaporeMAS and the Association of Banks in SingaporeOTP login phase-out for customers with digital tokensFrom Jul 2024In forceBanks in Singapore to strengthen resilience against phishing scams (MAS)
European UnionCouncil and ParliamentPSR / PSD3 fraud and SCA packageDeal Nov 27, 2025PendingPayment services: Council and Parliament agree to step up the fight against fraud (Council of the EU)
United StatesNISTSP 800-63B-4: SMS OTP is a "restricted" authenticatorFinal 2025GuidanceSP 800-63B-4: Authentication and Authenticator Management (NIST)

Full regulations tracker

Quick answers

How should a bank move customers off SMS one-time passcodes?

Inventory every flow that sends a code, write the risk assessment NIST SP 800-63B-4 asks for, fix account recovery and new-payee setup first, then move customers to phishing-resistant or device-bound methods such as passkeys and in-app approval. Keep SMS only as a restricted fallback, with a dated plan to remove it.

What do organizations need to do to prepare for NIST SP 800-63-4?

Map every authenticator you use to NIST’s assurance levels, identify the restricted ones (SMS and voice codes), and for each restricted authenticator document a risk assessment, user notice, a non-restricted alternative and a migration plan. Add a phishing-resistant option such as passkeys, which Revision 4 accepts at AAL2.

What counts as phishing-resistant MFA?

Phishing-resistant MFA is authentication that a fake site or man-in-the-middle can’t capture and replay, because the credential is cryptographically bound to the real site. FIDO2 passkeys and hardware security keys are the common examples, and CISA also counts PKI-based smart cards. SMS codes, authenticator-app codes and simple push approvals are not phishing-resistant.

What is the best alternative to SMS OTP?

There is no single best alternative for every flow. Passkeys are the most widely standardized phishing-resistant option and are accepted by NIST at AAL2. In-app approval on a registered device is what UAE and Singapore banks moved customers to. Carrier network checks are useful risk signals, and SIM-based cryptographic methods are emerging. Most organizations combine two or more.

Buyer’s guides and vendor briefs

Approaches, evaluation criteria and pre-pilot questions. No rankings; owner interest disclosed.

Buyer’s guide

SMS OTP alternatives: a buyer’s guide

There is no single best alternative for every flow. Passkeys are the most widely standardized phishing-resistant option and are accepted by NIST at AAL2. In-app approval on a registered device is what UAE and Singapore banks moved customers to. Carrier network checks are useful risk signals, and SIM-based cryptographic methods are emerging. Most organizations combine two or more.

Buyer’s guide

Phishing-resistant MFA: a buyer’s guide

Phishing-resistant MFA is authentication that a fake site or man-in-the-middle can’t capture and replay, because the credential is cryptographically bound to the real site. FIDO2 passkeys and hardware security keys are the common examples, and CISA also counts PKI-based smart cards. SMS codes, authenticator-app codes and simple push approvals are not phishing-resistant.

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