Mobile Banking Compliance

Is 2FA mandatory for mobile banking in Georgia?

Yes, Strong Customer Authentication (SCA) is mandatory for executing financial transactions via mobile apps according to NBG regulations.

Are click-wrap agreements legal for loans?

Yes, agreements accepted by clicking a button in the app are legally binding provided the customer is properly authenticated.

Can the app store biometric data?

Storing biometrics on servers requires strict compliance. Usually, apps rely on local device authentication (FaceID/TouchID) without transferring biometric data.

How must fees be displayed?

All fees and the effective interest rate must be displayed clearly and prominently before the user confirms the transaction.

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Mobile Banking Compliance is a niche service focused on the legal and technical soundness of banking applications. Today, a mobile app serves as a bank's primary branch, so the National Bank pays special attention to its security and consumer rights protection in the digital space. This service addresses not only technical cybersecurity but also interface (UI/UX) compliance with the "Rule on Protection of Consumer Rights." For instance, the app must correctly display the effective interest rate, not hide fees, and ensure secure data transmission. Non-compliance leads to substantial fines and suspension of app functionality. This service helps banks and fintechs create mobile products that are lawful and trustworthy for users.

What Does Mobile Banking Compliance Service Cover?

The service covers all legal aspects of app development and operation:

  • UI/UX Legal Audit: Checking app design and navigation to ensure full and transparent information is provided to the client (e.g., when taking a loan).
  • Strong Customer Authentication (SCA): Implementing 2FA/MFA standards in accordance with NBG regulations.
  • Data Privacy in Apps: Drafting Privacy Policies for data collection, processing, and storage according to GDPR and local law.
  • Electronic Consents: Ensuring the legal validity of "Clickwrap" agreements for "Terms of Use" and other contracts within the app.
  • Cybersecurity Compliance: Developing incident response plans and verifying app security standards.

Common Scenarios and Challenges

Problems in mobile banking often arise from:

  • Hidden Fees: A client didn't see a commission when taking a loan in the app because it was "hidden" in a menu. This violates consumer rights.
  • Fraud: A transfer occurred from a client's account due to weak app authorization. The bank bears liability.
  • App Updates: The bank launched a new feature (e.g., investments) but forgot to add appropriate risk warnings in the interface.
  • Biometric Data: Using Face ID for login requires specific consent for biometric data processing.

Georgian Legal Framework

The field is regulated by the NBG President's Decree "On the Rule for Protection of Consumer Rights by Financial Organizations," which details how information must be presented in digital channels. The Law on Information Security and the Law on Personal Data Protection also apply. Regarding cybersecurity, banks must adhere to minimum standards set by the NBG for mobile applications.

Service Process: What to Expect

A lawyer, together with an IT specialist, walks through the app's "User Journey." Every screen, button, and notification is checked. If a deficiency is found (e.g., font size for warnings is too small), a recommendation for design change is issued. Legal documentation (Terms & Conditions, Privacy Policy) is also prepared for integration into the app.

Why Choose Legal.ge?

Mobile banking is not just code; it is a legal relationship between the bank and the client. On Legal.ge, you will find lawyers who understand the importance of UX/UI design and know how to make it compliant. We will help you create a secure and transparent mobile bank.

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Specialists for this service

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