PCI-DSS and OTP: What Indian Payment Apps Need to Know
How PCI-DSS applies to OTP and SMS workflows in Indian payment apps: scope, segregation, audit-trail expectations, and where OTP fits relative to RBI AFA.
StartMessaging Team
Engineering
PCI-DSS focuses on cardholder data. OTP is rarely in scope unless you actively put card data into SMS. This guide explains where OTP sits and how to keep your SMS provider out of scope.
Overview
- PCI-DSS scope is cardholder data.
- OTPs themselves are not cardholder data.
- Keep SMS bodies free of PAN.
PCI-DSS Scope and OTP
OTP is part of authentication; cardholder data is the PAN. Send the OTP via SMS, send the payment-result SMS via the same provider — nothing PAN-bearing leaves the PCI environment.
Cardholder Data Segregation
- Cardholder data lives only in PCI-DSS-scoped systems.
- SMS provider never sees PAN.
- Authorisation responses stay inside the scope.
Audit Trail
Retain (transactionId, OTPrequestId, status, timestamp). 12+ months for PCI-DSS, longer for RBI-side requirements.
PCI-DSS + RBI AFA
PCI-DSS is global; RBI AFA is India-specific. Both align on OTP as the second factor. Read our RBI AFA guide.
FAQ
StartMessaging stays out of your PCI-DSS scope by design — we never see PAN, only the OTP request ID and result.
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