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

Desk 05For Compliance

The compliance desk

Every rule that restricts SMS codes, the dates that matter, and the evidence regulators and auditors expect.

For compliance and regulatory teams.

What matters now

  1. The Philippines’ BSP Circular 1213 bars SMS and email OTP for high-risk transactions from June 25, 2026.

    Dispatch: Inside BSP Circular 1213, the Philippines’ OTP rule
  2. India’s RBI Authentication Directions 2025 took effect on April 1, 2026.

    Regulations: SMS OTP regulations tracker
  3. The EU reached a provisional deal on the PSR and PSD3 fraud package on November 27, 2025; it is not yet in force.

    Regulations: SMS OTP regulations tracker

Your reading path

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

  1. Start here · Regulations

    SMS OTP regulations tracker

    Start here: every market, with dates and primary sources.

  2. Then · Field guide

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

    The four conditions for keeping SMS codes, with evidence.

  3. Then · Explainer

    The FCC’s SIM-swap rules: what carriers now have to do

    What US carriers must do, and what the order doesn’t cover.

  4. Then · Dispatch

    Inside BSP Circular 1213, the Philippines’ OTP rule

    The most recent market to restrict SMS and email OTP.

  5. Then · Dispatch

    What the UK’s APP fraud reimbursement rules changed for fraud teams

    How reimbursement rules changed fraud incentives.

Checklists for this desk

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)
PhilippinesBangko Sentral ng PilipinasCircular 1213: no SMS or email OTP for high-risk transactionsFrom Jun 25, 2026In forceNo more SMS, email OTPs for high-risk financial transactions (GMA News)
IndiaReserve Bank of IndiaAuthentication Directions 2025From Apr 1, 2026In forceRBI mandates 2FA and new security rules for digital payments (Regulation Asia)
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)
MalaysiaBank Negara MalaysiaBanks directed off SMS OTP2022 – 2024In forceMalaysian banks stop using SMS for two-factor authentication (Commsrisk)
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.

Is SMS OTP still allowed under NIST SP 800-63-4?

NIST SP 800-63-4 does not ban SMS one-time passcodes. It classifies SMS and voice codes as “restricted” authenticators: still allowed, but only if the organization assesses the risk, tells users about it, offers at least one non-restricted alternative, and keeps a plan to migrate away.

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.

Words this desk uses

Everything for this desk