September 3, 2025

NPCI’s UPI Security Guidelines Get Tougher, Here’s How to Keep Up

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Buchi Reddy B

CEO & Founder at LEVO

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NPCI has issued several advisories on UPI API usage over the years, but the latest circular marks a decisive shift. It is no longer about guidelines scattered across notices; this is the strictest, most consolidated framework yet. Applicability is universal i.e. banks, PSPs, and TPAPs must all conform, and the line between compliance and violation is now sharply drawn. 

Unauthorized API calls, background or batch loads, or even storing customer data outside prescribed boundaries are treated not as oversights but as breaches of UPI’s operating rules. The consequences are equally uncompromising: mandatory audits, financial penalties, or disconnection from the UPI network.

The urgency is immediate. Compliance is not on the horizon; it is already due, and enterprises must respond without delay. This blog unpacks the why and how: why NPCI issues these guidelines, what makes this version different, how it reshapes the API lifecycle, and what enterprises must do to remain trusted participants in India’s payments ecosystem.

NPCI’s New UPI Guidelines: From One-Time Checks to Continuous Compliance

The release of NPCI’s UPI API Security Guidelines (OC-215/2025-26) represents a transformative leap in how banks and payment providers must safeguard India’s real-time rails. 

These rules are no longer a once-and-done exercise. 

NPCI compliance now demands an operational and proactive approach that spans every stage of UPI API delivery. From how banks, PSPs, and TPAPs design and build their integrations to how they monitor and control them in production, adherence must be baked into daily operations. It isn’t enough to log activity or raise alerts, NPCI expects immediate resolution of violations and proof that only authorized, customer-initiated API calls are executed.

What’s new is the emphasis on enforcement. Continuous audits by CERT-In empaneled auditors will now scrutinize API usage, application code, and operational workflows. Auditors will verify that authentication, encryption, velocity controls, and purpose-bound API calls are not just configured but actively enforced in live environments. Under these rules, continuous compliance isn’t an add-on, it is as critical as transaction uptime itself.

Implementing these measures by hand, writing custom throttles, standing up bespoke dashboards, and staffing 24×7 audit teams would stall innovation, choke growth and eat into security budgets.

That is why Levo.ai automates every recommended control, letting your teams do more with less i.e. avoid extra hires, while keeping security airtight. 

In as little as two months you can be fully compliant with NPCI’s baseline requirements, gaining immediate protection against common threats and laying the groundwork for advanced defenses once the basics are in place.

Go through the below table to understand how: 

Violation How Levo Automatically Prevents It Resource Savings
Using an API for an Unintended Purpose
Any call outside its intended flow (e.g., “List Account” outside onboarding; background balance polls).
• API Discovery & Inventory auto-discovers all endpoints and flags unmapped or unused APIs.
• Continuous Monitoring applies custom policies to detect context-less calls and block them at runtime
• Saves developer time by surfacing misuse instantly.
• Reduces sec-ops investigation effort.
Excessive Balance Enquiries
More than 50 per customer/app/day or without explicit user action.
• Continuous API Monitoring enforces per-user quotas and triggers real-time alerts when thresholds are approached.
• Active Testing simulates imbalance scenarios in pre-prod to validate throttling logic.
• Eliminates manual log reviews for polling spikes.
• Prevents production firedrills by catching back-off issues early.
Unauthorized Account-Lookup Calls
Over 25 lookups/day or background refreshes outside onboarding flow.
• Continuous Monitoring & Policy-as-Code enforce any frequency or interval limits you define and surface violations in real time.
• Active Testing integrates into CI/CD to simulate rapid polling and verify throttles before deployment.
• Eliminates manual log reviews for polling spikes.
• Prevents developer rework by catching throttle misconfigurations early.
Status-Check Polling Abuse
More than 3 “CheckTxn” calls per transaction within 2 hours or calls faster than 90 sec apart
• Continuous Monitoring & Policy-as-Code enforce any frequency or interval limits you define and surface violations in real time.
• Active Testing integrates into CI/CD to simulate rapid polling and verify throttles before deployment.
• Cuts troubleshooting time for dev teams.
• Lowers sec-ops alert noise.
Exceeding Rate Limits or Frequency Caps
Violating any NPCI-defined cap (e.g., status checks, balance enquiries).
• Continuous Monitoring & Policy-as-Code detect any calls that exceed configured NPCI caps and generate real-time alerts.
• Active Testing automatically validates rate-limit enforcement for every API in your CI/CD pipeline to ensure limits are correctly applied before production.
• Eliminates hours spent manually verifying thresholds.
• Prevents late-stage fixes by catching rate-limit gaps early.
Batch Processing of APIs
Converting bulk files into rapid-fire API calls (e.g., batch account-lookups).
• Continuous Monitoring observes traffic patterns and detects abnormal bursts consistent with batch processing.
• Custom Policy Rules trigger alerts when rapid, repetitive sequences are detected.
• Eliminates manual anomaly hunting.
• Frees developers from ad hoc debugging.
Sharing or Storing Restricted Data
Forwarding or storing UPI PII (balances, account numbers, VPAs) outside the customer’s bank domain.
• Data Classification & Protection flags sensitive fields in all API traffic.
• Continuous Monitoring alerts whenever classified data appears heading to unauthorized destinations.
• Reduces compliance effort on data-leak investigations.
• Prevents data-handling fixes in production.
Missing NPCI Audit & Certification Deadlines
Failing to complete required security audits or to submit compliance certificates by the specified due date.
• Exportable Compliance Reports generate PDF/CSV summaries of testing coverage, vulnerabilities found, and sensitive-data endpoint visibility.
• Automated Best-Practice Checks continuously validate all NPCI mandates.
• Saves compliance-team time on report preparation.
• Ensures all NPCI requirements are continuously validated.
Third-Party Partner Non-Compliance
Allowing sponsored apps or aggregators to violate NPCI rules (e.g., TPAP caching balances).
Sensitive Data Mapping traces exactly which endpoints and calls carry customer data into third-party domains. • Saves compliance teams hours per partner review.
• Accelerates third-party governance and risk assessment.
Use of Deprecated APIs or Failure to Meet NPCI SLAs
Continuing to call sunset UPI endpoints or missing newly mandated response-time requirements.
• API Discovery correlates live traffic with code repositories to identify zombie, shadow, or deprecated API endpoints. • Eliminates manual endpoint mapping and cleanup.
• Speeds removal of obsolete integrations.

From Basics to Advanced: NPCI’s Two-Tiered Approach to UPI API Security

NPCI doesn’t stop at the basics. While encryption, authentication, schema validation, rate limits, and monitoring form the mandatory foundation, the guidelines point toward advanced defenses such as behavioral anomaly detection, adaptive throttling, and automated incident response. These capabilities only work when anchored in strong fundamentals. 

For instance, incident response is impossible without an accurate inventory of APIs, anomaly detection relies on clean monitoring data, and adaptive throttling depends on well-defined baseline rate limits. This is where our existing modules i.e. Inventory, Monitoring, Access Control, and Runtime Protection, become not just compliance enablers, but the launchpad for advanced resilience.

The circular makes clear that advanced defenses offer greater resilience but cannot be adopted until the basics are firmly in place. 

By automating and accelerating every basic control with minimal overhead, Levo.ai lets you satisfy NPCI’s immediate requirements in weeks rather than months and frees your teams to tackle advanced protections without slowing down innovation or adding headcount. 

From NPCI to GDPR: One Platform for Continuous API Security & Compliance

Achieve Compliance Success with Levo: the only platform that safeguards data as rigorously and continuously as all regulators demand. 

Despite the acronyms, all major compliance frameworks converge on the same control foundations, i.e. protect sensitive data, enforce access, monitor behavior, fix known risks, and respond to incidents. Levo’s API Security platform automates all of it, turning application security into a compliance multiplier.

In practice, every framework, whether from RBI, NPCI, SEBI, or DSCI—demands the same fundamentals. Levo unifies them by automating discovery, monitoring, access control, and response, making one platform sufficient to satisfy all compliance schemes simultaneously.

It embeds API security directly into SDLC across all development, testing, and runtime stages. 

  1. Discover Every API: Documented or Not, Internal or External

Levo continuously discovers APIs across all environments such as QA, UAT, SIT, staging, and pre-prod, using traffic, code repositories and logs. It maps shadow, zombie, and third-party APIs in addition to internal, external and partner APIs without requiring code changes or agent installs. 

This satisfies compliance requirements for system inventory and data mapping under ISO 27001, GDPR, and SOC 2. No more dev surveys or last-minute API reconciliation before an audit.

  1. Keep Documentation Accurate & Updated, Without Relying on Developers

Levo auto-generates OpenAPI specs with 12+ fields including human-readable description auth methods, rate limits, changelogs, and data formats. It updates specs continuously from runtime traffic as they happen, without needing manual uploads or annotations. 

This eliminates the documentation gap that slows down risk assessments and privacy reviews and meets compliance expectations around change management. Compliance teams get consistent, centralized API specs they can trust, with no meetings, no backlogs, no rewrites.

  1. Continuously Discover and Protect Sensitive Data: Everywhere It Flows

Levo maps sensitive data both at the endpoint level and the application level to surface exactly which APIs require the strongest access controls. Automatically flagging endpoints that handle sensitive data with absent or weak Authentication, authorization, and encryption. This ensures that APIs tied to regulated data are always governed with least-privilege access, no manual tagging needed

  1. Replace Point in Time VAPT With Continuous, Accurate, and Complete Testing Coverage

Levo integrates directly into CI/CD Pipelines and runtime environments to run automated security tests containing 1000+ context-aware payloads per endpoint, testing for OWASP Top 10 issues, auth bypasses, injection flaws, and more. It also monitors pre-production and runtime behavior to detect abuse, drift, and misconfigurations against over dozens of default and custom configurations. 

  1. Adapt with Automated Enforcement not operational friction

Levo enables compliance teams to define new sensitive data types directly from the UI, instantly applied across applications and APIs. All new types are immediately reflected in classification logic, reports, and alerts. 

As data protection rules evolve, new classifications can be rolled out instantly and applied across the API ecosystem. Levo empowers compliance teams to enforce policy at the speed of regulation, not the speed of development cycles.

  1. Export Audit-Grade Evidence Instantly: Zero Manual Assembly Required

Levo compiles security findings, testing coverage, and data classifications into exportable reports. Instead of chasing logs or screenshots, compliance teams download evidence with a click. Every report reflects live security posture, not outdated snapshots. 

API Gateways Are Not API Security

API gateways excel at traffic management, request routing, and enforcing runtime access policies, but they are not a substitute for end-to-end API security posture management. A gateway can only enforce what it knows exists and what is correctly configured.

The reality is that most API security risks occur before the gateway sees a single packet or entirely outside its enforcement plane:

  • Undiscovered APIs – Shadow, zombie, and partner APIs never registered in the gateway remain ungoverned.

  • Unvalidated authentication – Flawed or inconsistent auth logic in upstream services bypasses gateway-level checks.

  • Missing or outdated specifications – Without accurate OpenAPI specs, routing is incomplete and policy mapping is error-prone.

  • Improper data handling – PII, PCI, or proprietary data may traverse APIs with no encryption or masking, invisible to gateway policy enforcement.

Implement NCPI Recommendations effortlessly with Levo

Levo.ai complements, not competes with, gateways. It continuously discovers every API, internal, external, partner, and low-traffic, across hybrid and multi-cloud environments, then auto-generates accurate OpenAPI and Postman specifications directly from live traffic. This ensures every service is ready for gateway onboarding with verified contract fidelity and compliance annotations.

With this foundation in place, enterprises can accelerate NPCI compliance, eliminate blind spots, and strengthen security without slowing delivery. Levo further enables faster audits, smoother onboarding, and advanced protections to be adopted seamlessly as UPI scales, thus, driving resilience, trust, and innovation at the same time.

Achieve Continuous and Universal Compliance Success

With the Only Security Platform that directly secures both sensitive data and the closest layer to it, i.e. your APIs.

Book your DEMO through this link to implement NCPI guidelines seamlessly

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