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India Data Localisation
RBI outlined this in circular reference RBI/2017-18/153 - DPSS.CO.OD No.2785/06.08.005/2017-2018 dated 6 April 2018 (https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=11244).
In order to comply with this regulation, Deutsche Bank is upgrading its systems. In preparation for this upgrade, we will continuously inform you of potential impact on your processes as well as the initial changes that you may notice to your channels/platforms and how to get ready for this.
Please take note of the Impact and FAQs sections of this website and return regularly for the latest updates.
Impact
If you have accounts in India, you are impacted. Regardless of whether you initiate domestic payments/collections or receive account information only. Please note below how different Deutsche Bank products/services are impacted.
DB Direct Internet (DBDI):
In case you use DBDI we do not foresee that you will need to make any changes. The domain set-up, user entitlements, payment data, templates and beneficiaries will be ported to a newly created, separate India instance by us. User profiles, user credentials, administration process to access India account information and payment processing will remain unchanged. If you have an active user preference, alerts, schedulers etc. the same will be replicated into the new India instance by default.
Show content of Further information on DB Direct Internet (DBDI)
✓ If you have a global domain which contains the Indian accounts and you initiate or upload payments manually, you will need to toggle between a new India instance and your existing global domain in order to view your transactions and account reporting or initiate and authorize payments
✓ If you use the file upload or file export functionality, the files will need to be in the “India only” and “non-India” accounts in the new set-up
EBICS Electronic Data Transmission (EDT) Services:
In case you are enabled for EBICS channel for EDT, Request for Payment execution and/or Account Information services, a new, separate India instance will be created in EBICS.
Show content of Further information on EBICS Electronic Data Transmission (EDT) Services:
✓ You are required to set up user access and corporate signatures for your India instance
✓ You are required to send a separate payment file for Indian held accounts and another file for all your other countries
✓ We will reach out to you bilaterally to provide further details on the change
DB Application Programming Interface (API):
If you are calling any DB-hosted API endpoint for initiating payments related instructions from your Indian accounts, there will be a new endpoint (a new hostname) which is hosted to segregate India flows.
Old hostname: https://corporateapi.db.com
New hostname: https://api.corporatebank.db.com
Show content of Further information on DB Application Programming Interface (API):
✓ You will need to make the relevant changes on your side to connect to the new endpoint for all API traffic as outlined above
✓ We will reach out to you bilaterally to provide further details on the change
DB Direct Connect (Host-to-Host):
If you are currently sending/uploading a single payment file with debit accounts of different countries, under the new regulatoion, we will not be able to process combined transaction files containing information and data pertaining to accounts both in India and overseas. Where payment instructions are received in such instances, they will be treated as invalid and will be cancelled.
Show content of Further information on DB Direct Connect (host-to-host):
✓ You are required to send a separate payment file for Indian held accounts and another file for all your other countries
✓ India payment files incoming to global instances will be automatically relayed to India instances and information will be retained for max. 24 hrs. before being deleted from global instances.
✓ In case you receive reports, you need to retrieve these separately for India and the rest of world
✓ We will reach out to you bilaterally to provide further details on the change
SWIFT-FileAct (MaCUG/Score):
In addition to segregating local Indian and other global payment files, a new SWIFT BIC Code DEUTINBB to be used for MACUG & SCORE Services with all other parameters for payment files relating to India accounts remain as is. All responses including Payment Status Reports (PSR) and Bank Statements will be received from the new BIC code. This ensures that the payment files relating to India accounts are routed to the new SWIFT India instance and stored locally in India.
Show content of Further information on SWIFT-FileAct (MaCUG/Score):
✓ You are required to update your systems & stationary accordingly
✓ We will reach out to you bilaterally to provide further details on the change
SWIFT Services/FIN:
If you or your forwarding agent are exchanging payment request information or sending Money Transfer (MX/MT) messages using the SWIFT protocol to Deutsche Bank India as executing Bank, you will need to use a separate FIN channel and the new SWIFT BIC code:
DEUTINBBP9V. All responses received will also come from the new BIC code.
If you are exchanging payment request information to Deutsche Bank India to relay (MX/MT) messages using SWIFT protocol to executing Banks in India, executing banks shall receive messages from new SWIFT BIC code: DEUTINBBP9V.
Show content of Further information on SWIFT Services/FIN:
✓ You are required to update your systems & stationary accordingly
✓ We will reach out to you bilaterally to provide further details on the change
Relationship Management Application (RMA) Exchange:
(Only applicable in case of SWIFT Service/FIN are used)
If you or your forwarding agents / execution banks on your behalf are sending or receiving Money Transfer (MT) requests, then please be informed that the new SWIFT BIC code DEUTINBBP9V will be valid without format changes to MT101 structure.
Show content of Further information on Relationship Management Application (RMA) Exchange:
(Only applicable in case of SWIFT Service/FIN are used)
✓ You will be required to exchange the SWIFT BIC Code DEUTINBBP9V in RMA ahead of the migration date to allow for seamless data exchanges with authentication.
✓ We will reach out to you bilaterally to provide further details on the change
Aggregated Account Information Services:
If you are enabled for aggregated Bank Account information, please be informed that Account Statements for your account(s) with Deutsche Bank, India will be segregated from this service and will be delivered account wise in the existing formats.
FAQ
Please read the attached FAQ carefully as it outlines the impact and action required per channel/product.
Show content of What is changing with payments in India?
In line with RBI vide circular reference RBI/2017-18/153 - DPSS.CO.OD No.2785/06.08.005/2017-2018 dated 6 April 2018 with reference to storing domestic payment data in India and as explained in general terms in recent communication, banks and other payment system operators are now required to store domestic payment data in India. Ref: https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=11244&Mode=0. In Sept 2021 RBI issued further instructions which restricted the payment data elements that can be stored outside India.
Show content of What is the scope of these regulatory changes?
All Indian rupee denominated payment transactions should be stored in India. For crossborder foreign denominated payment transactions, the regulation allows a copy of the payment transactions to be stored abroad as well. Only the following fields are allowed to be stored outside India:
- Banking data (Constitutes all the relational data of the customer e.g., name, account number, account type, KYC data, etc, a bank holds prior to the initiation of the payment transaction by the customer)
- Date and time of the transaction
- Value date of transaction
- Name of the remitter / beneficiary
- Transaction amount
- Transaction reference number
- Payment mode
- Counterparty bank name
Show content of What will Deutsche Bank’s course of action be?
To comply with this recent regulation, Deutsche Bank is upgrading its systems. In preparation for this upgrade, we are informing you of any potential impact on your processes as well as the initial changes that you may notice to your channels/platforms and how to get ready for these changes.
Show content of Is my company impacted?
If you have accounts in India and/or initiating domestic payments or collections, then you are impacted.
Show content of What do I need to do if my company is impacted?
Following the implementation of localized data rules in India, client experience and technical integration may change, including the storage and provision of account information and payments data. Depending on the way in which you interact with Deutsche Bank for initiating payments and receiving account information requests, some actions may be required:
DB Direct Internet (DBDI):
In case you use DBDI we do not foresee that you will need to make any changes. The domain set-up, user entitlements, payment data, templates and beneficiaries will be ported to the new India instance by us. User profiles, user credentials, administration processes to access India account information and payment processing will remain unchanged. If you have an active user preference, alerts, schedulers etc. these will be replicated into newly created India Instance by default.
Specific action for you:
✓ If you have a global domain which contains the Indian accounts and you initiate or upload payments manually, you will need to toggle between a new India instance and your existing global domain in order to view your transactions and account reporting or initiate and authorize payments.
✓ If you use the file upload or file export functionality, the files will need to be in the “India only” and “non-India” accounts in the new set-up.
EBICS Electronic Data Transmission (EDT) Services:
In case you are enabled for EBICS channel for EDT, Request for Payment execution and Account Information services, a new India instance will be created.
Specific action for you:
✓ You are required to set up user access and corporate signatures for your India instance.
✓ You are required to send a separate payment file for Indian held accounts and another file for all your other countries
✓ We will reach out to you bilaterally to provide further details on that change
DB Application Programming Interface (API):
If you are calling any DB hosted API endpoint for initiating payments related instructions from your Indian accounts, there will be a new endpoint (a new hostname) which is hosted to segregate India flows. Old hostname: https://corporateapi.db.com, New hostname: https://api.corporatebank.db.com
Specific action for you:
✓ You will need to make the relevant changes on your side to connect to the new endpoint for all API traffic as outlined above
✓ We will reach out to you bilaterally to provide further details on that change
DB Direct Connect (host-to-host):
If you are currently sending/uploading a single payment file containing debits/credits to accounts held in different countries. Under the new regulation, we will not be able to process transaction files containing information and data pertaining to accounts both in India and overseas. Where instructions are received in such instances, they will be treated as invalid and will be cancelled.
Specific action for you:
✓ You are required to send a separate payment file for Indian held accounts and another file for all your other countries
✓ India payment files incoming to global instances will be automatically relayed to India instances and information will be retained for max. 24 hrs. before being deleted from global instances.
✓ In case you receive reports, you need to retrieve these separately for India and rest of world
✓ We will reach out to you bilaterally to provide further details on that change
SWIFT-FileAct (MaCUG/Score):
In addition to segregating local Indian and other global payment files, a new SWIFT BIC Code DEUTINBB to be used for MACUG & SCORE Services with all other parameters for payment files relating to India accounts remain as is. All responses including Payment Status Reports (PSR) and Bank Statements will be received from the new BIC code. This ensures that the payment files relating to India accounts are routed to the new SWIFT India instance and stored locally in India.
Specific action for you:
✓ You are required to update your systems & stationary accordingly
✓ We will reach out to you bilaterally to provide further details on that change
SWIFT Services/FIN:
If you are sending us MT101FIN for execution from your accounts at Deutsche Bank AG in India, they need to be sent to new receiving BIC (DEUTINBBP9V) in future. Any feedback messages will also come from the new BIC code.
Specific action for you:
✓ You are required to update your systems & stationary accordingly
✓ We will reach out to you bilaterally to provide further details on that change
Aggregated Account Information Services:
If you are enabled for aggregated Bank Account information, please be informed that Account Statements for your account(s) with Deutsche Bank, India will be segregated from this service and will be delivered account wise in the existing formats.
Relationship Management Application (RMA) Exchange:
(Only applicable in case of SWIFT Service/FIN are used)
If you or your forwarding agents / execution banks on your behalf are sending or receiving Money Transfer (MT) requests, then please be informed that the new SWIFT BIC code DEUTINBBP9V will be valid without format changes to MT101 structure.
Specific action for you:
✓ You will be required to exchange the SWIFT BIC Code DEUTINBBP9V in RMA ahead of the migration date to allow for seamless data exchanges with authentication
✓ We will reach out to you bilaterally to provide further details on that change
Show content of What is the impact on reports?
Account Information such as bank statements and intraday reports will be delivered segregated. For example, if you are currently receiving a standard/customized report and/or downloading reports in “Reports module” from user interfaces (such as DB Direct Internet) or other reporting applications, for accounts held in DB India and outside of India, you will only be able to view/receive reports that will contain information for India under the new India instance.
All reports for other jurisdictions will still be made available under the global domain. If you are used to receiving bundled account statement via Host to host / EBICS/Swift-Fileact these will be segregated between Indian and non-Indian-accounts going forward.
Show content of How will the MT940 files be delivered via H2H in the future?
Where reports are received, clients will need to receive these separately for India and rest of world. Where clients are used to receiving bundled account statement via Host to Host, these will be segregated between Indian and non-Indian accounts going forward.
Show content of How do I extract the report file from DBDC?
You can extract as per normal. If you encounter an issue in downloading reports, you can try to extract files from both UK and India directories together.
Show content of What is the sequence number of the CAMT statement? Will it continue from the global domain, or will it start from the beginning?
The construction of bank statement does not change and only the channel will be corrected to store data in India. All values including statement numbering and sequencing will remain unchanged.
Show content of How to deal with archival and database backups taken outside of India during processing?
Archival backups/database backups are considered proprietary and native to Oracle/SQL for database operations and retrieval. As agreed with DB, the same will not be tested for each application but will be called out in the SAR report summary as a factual statement.
Show content of Will an additional domain be created that only contains our Indian account?
Deutsche Bank will have to carve out accounts from your global mandate, with a new routing rule to be defined for pointing to the India instance. Both these activities will be taken up internally (at Deutsche Bank) and there is no action required from clients.
Show content of How will my account(s) look post migration?
As per the above question, your existing domain ‘.ap’ will be split as .ap (APAC) & .ap(India) after the completion of the Regulatory migration by the bank, creating two domains. Post migration, transacting and accessing account information for your India accounts will be made available only in ‘.ap (India). Transacting & Account Information services for other countries will continue to be available under ‘.ap (APAC)’.
Show content of How do I access the new domain? Will existing logins / tokens work on the new domain?
Users will need to toggle between the new India instance and their existing global domain. The same login and token(s) can be used on the new instance.
Show content of How will user creation and deletion work after the mirroring to India instance?
India instance creation is a technical function to access data stored in India for India relationship. From a user and/or entitlement administration perspective, no changes or actions are expected here.
Show content of Will the migration to India instance impact generation of User and Entitlements report from the User Manager menu? Will we be able to view the India products given to the user in the Global instance?
We are working to ensure that the current experience is not changed. A detailed update will be provided where there are any changes in process.
Show content of Can the Indian payment system data be shared with overseas regulators?
The data may be shared with an overseas regulator, if so required, depending upon the nature/origin of the transaction and with due approval of RBI.
Show content of Will there be a testing environment?
Testing environments for some channels/products will be made available.
Show content of Will there be any impact on client operations during the migration process?
Migration will be in different phases based on the services and technical integration in scope. There should be/will be no impact to the client’s operations during migration.
Show content of What are the timelines for migration?
Migration timelines can differ per channel/product and will be communicated in due time. The FAQ will be updated accordingly.
Show content of Will I be informed prior to migration?
Yes. All clients will receive a pre-migration notification via email, confirming when their migration date will be.
Show content of How long does the account migration process take?
Migration duration is dependent on the services and technical integration in scope. We will make sure that any downtime is during non-business hours and transaction services are not impacted during the migration phase.
Show content of How do I retrieve historical transactions dating before the migration after the migration?
In line with Deutsche Bank’s existing data retention processes and periods, records are available and will also be made available for India instance.
Show content of My business has received communications other banks, which have different times lines and dates, why is this?
It is Deutsche Bank’s understanding that every bank has a different timeline agreed with RBI.
Show content of Can you explain what the IDL impact will be to our business?
Client based scenarios are described in the respective Product Fact sheet that are distributed to all clients.
Show content of Can I arrange a call with my business to discuss/understand impact and the way forward?
This is possible, please approach your service or implementation manager directly to arrange a call.
Show content of Who is my DB point of contact for migration and post migration issues?
We are trying to ensure that there is minimal impact and challenges for our clients post migration. Please refer to your Lead Implementation Manager or our Service support for any issues or challenges.
Show content of Do new agreements have to be signed?
Any amendments to the legal framework and agreements will be shared bilaterally for your acknowledgement. No signatures are required.
Show content of Where can I find up-to-date information?
You can find further information on our Corporate Bank India Data Localisation website.
Show content of Do you have questions or need support?
Please approach your Service Officer, Implementation Manager, Relationship Manager or to idl.support@db.com should you have any questions or require further information.
Help
For any questions related to the India Data Localisation project, please contact your Service Officer, Implementation Manager, Relationship Manager or IDL.support@db.com