CBSL technology risk directions: assess your mobile banking app before and after every release.

The Central Bank of Sri Lanka requires licensed banks to run pre-implementation security testing, vulnerability assessments at least quarterly and penetration tests by independent external experts. The guideline for payment related mobile applications adds device registration, multi-factor authentication, session controls, tamper detection and certificate pinning. Ostorlab tests your app and the APIs behind it, behind login, on every release.

  • Assesses the mobile app and the APIs it calls, on the build your customers download
  • Tests login, one-time codes, MFA, account lockout and session handling with your test accounts
  • Checks root and jailbreak detection, anti-tampering, debugger and emulator checks and certificate pinning at runtime
  • Lists the SDKs and native libraries in each release and maps them to known vulnerabilities with fix deadlines
Scan your own appBook a demo

Free scan of your app from the App Store or Google Play. No login required.

Who it applies to
Licensed commercial and specialised banks under the technology risk directions, and payment service providers that run or facilitate payment related mobile applications
Key dates
Directions No. 16 of 2021 issued 9 December 2021 and amended on 8 December 2023; production penetration tests due by 31 December 2028; Personal Data Protection Act Parts I and III from 1 January 2027
Focus
Pre-implementation testing, quarterly vulnerability assessments, annual penetration tests and mobile payment app controls
Main references
Banking Act Directions No. 16 of 2021 and Guidelines on Minimum Compliance Standard for Payment Related Mobile Applications No. 1 of 2020
Key dates

The CBSL texts behind your mobile channel

The technology risk directions sit alongside the payment guideline for mobile applications and the payment circulars that set transaction rules. The dates below are for the texts cited on this page.

  1. 1 June 2020

    Guideline No. 01/2020 applies

    The minimum compliance standard for payment related mobile applications takes effect, replacing the 2018 guideline. It covers the app, web services, server-side infrastructure and network communication.

  2. 9 December 2021

    Technology risk directions

    Banking Act Directions No. 16 of 2021 apply to licensed banks, with information security testing, encryption, access management, SOC and third-party infrastructure requirements.

  3. 8 December 2023

    Amended deadlines

    Directions No. 05 of 2023 amend the framework: revised compliance deadlines, including production penetration tests by 31 December 2028, and quarterly access privilege reviews for critical systems.

  4. 17 January 2024

    JustPay OTP

    Payment and Settlement Systems Circular No. 01 of 2024 requires an OTP from the issuer for JustPay transactions of Rs 10,000 or more, sent to the mobile number registered with the issuer. In operation since 1 April 2024.

  5. 3 December 2024

    Customer identification for payment apps

    Circular No. 02 of 2024 requires payment app providers to identify users with an accepted identity document, verify that identity and match the device mobile number with the account mobile number when linking an account, from 31 March 2025.

  6. 7 May 2025

    Incident reporting circular

    Circular No. 02 of 2025 requires licensed banks to report IT and cybersecurity incidents to the Director of Bank Supervision within 2 hours of detection, with detailed reports within 14 days and quarterly reports after each quarter.

  7. 20 January 2026

    JustPay limits and registration controls

    Circular No. 01 of 2026 caps JustPay transactions at Rs 150,000 and requires mobile payment application providers to apply adequate security controls and procedures when registering customers and linking accounts, in operation from 2 February 2026.

  8. 22 July 2026

    Data Protection Act commencement order

    Extraordinary Gazette No. 2498/16 appoints 1 January 2027 for Section 2, Section 3, Part I and Part III of the Personal Data Protection Act, covering the processing principles and the controller and processor obligations.

What the CBSL asks

The CBSL technology risk rules, applied to your mobile app

For each rule: what the text says, what it means for a mobile banking app, how Ostorlab helps, and what stays with your team. Items from the technology risk directions and the payment guideline are summarised from the English texts.

  1. Banking Act Directions No. 16 of 2021, 5.8.1; compliance deadline 31 December 2025 as amended by Directions No. 05 of 2023

    Test before implementation and before each change

    What the text says

    Critical information systems and information systems exposed to customer data must go through pre-implementation information security tests, both before initial implementation and before modifications, unless a board-approved exclusion policy covers the specific minor change. The framework names the tests: static application security testing (SAST) or source code reviews, dynamic application security testing (DAST), hardening checks on computing and networking infrastructure, and infrastructure vulnerability assessments. The tests must be conducted by a team independent of the team that develops or implements the system.

    Source:Banking Act Directions No. 16 of 2021, 5.8.1; compliance deadline 31 December 2025 as amended by Directions No. 05 of 2023

    What it means for your mobile app

    Every mobile release that touches a critical or customer-data system is a modification. The pipeline and the release process need automated, independent security tests on the build customers download.

    How Ostorlab helps

    Mobile SAST works on the APK, AAB or IPA, with no source code needed, and Mobile DAST tests the running app in CI/CD. The AI-agent pentest tests the app and its APIs behind login, with a working exploit you can replay for each AI-agent finding.

    What stays with you

    The exclusion policy and its board approval, the independence of the test team, source code access and release approval.

  2. Banking Act Directions No. 16 of 2021, 5.8.2 and 5.2.4 (as amended by Directions No. 05 of 2023)

    Run vulnerability assessments at least quarterly

    What the text says

    Critical information systems and information systems exposed to customer data are subject to vulnerability assessments at least quarterly. The assessments focus on both infrastructure vulnerabilities and application vulnerabilities and are performed on production environments. Vulnerabilities identified must be remediated within a time period approved by the bank's Information Security Committee. The same framework requires user access privilege reviews at least quarterly for critical systems and bi-annually for non-critical systems exposed to customer or confidential non-customer data.

    Source:Banking Act Directions No. 16 of 2021, 5.8.2 and 5.2.4 (as amended by Directions No. 05 of 2023)

    What it means for your mobile app

    Four assessment cycles a year on the production app and its APIs leaves little room for one-off manual testing. The cadence has to be automated and repeatable.

    How Ostorlab helps

    Ostorlab runs scheduled scans from your CI/CD pipeline and monitors store releases without manual triggers. Findings are rated critical, high, medium or low and tracked as tickets in the platform or in Jira and ServiceNow.

    What stays with you

    Remediation deadlines approved by the ISC, infrastructure patching and production change management.

  3. Banking Act Directions No. 16 of 2021, 5.8.3; production deadline 31 December 2028 as amended by Directions No. 05 of 2023

    Penetration tests by independent external experts

    What the text says

    Critical information systems, information systems exposed to customer data and repositories of customer data, including those held by agents and third-party service providers, must be tested by independent external penetration testing experts. Critical information systems at least annually, and all other qualifying systems at least once every two years. The tests are threat intelligence-based, conducted on live production systems under normal business conditions, without changing the security measures normally in place, and cover external and internal threats. Both black box tests and gray box tests using bank-provided login credentials for customer, operational and managerial user categories are required. A Penetration Test Scope Specification defines the systems, threat scenarios, targets and time period, the Board of Directors approves the exercise, and an executive summary goes to the Director of Bank Supervision within 60 days of the provider's report.

    Source:Banking Act Directions No. 16 of 2021, 5.8.3; production deadline 31 December 2028 as amended by Directions No. 05 of 2023

    What it means for your mobile app

    The annual penetration test is the deepest assessment in the framework, and the app, its APIs and test accounts are the parts a mobile-focused vendor can cover. Note the timing: penetration tests on production systems are due by 31 December 2028.

    How Ostorlab helps

    The AI-agent pentest tests the app and its APIs behind login with your test accounts, including grey box flows, and gives you a replayable exploit for each AI-agent finding. Findings are grouped into tickets and retested after the fix ships.

    What stays with you

    Board approval of the PTSS and the exercise, the leadership team, the external provider's accreditation, background checks and references, and the 60-day report to the Director of Bank Supervision.

  4. Banking Act Directions No. 16 of 2021, 5.8.4

    Prepare for red team exercises

    What the text says

    Red team exercises extend penetration tests to the human and physical layers of security. D-SIBs must conduct them at least once every two years and other licensed banks at least once every three years, based on a Red Teaming Scope Statement approved by the Board of Directors and paired with a penetration test in the same cycle. Where the Board determines that the bank's security maturity is not yet sufficient, exercises are deferred by up to 12 months.

    Source:Banking Act Directions No. 16 of 2021, 5.8.4

    What it means for your mobile app

    Red teaming tests the whole bank, not the app. It is a different kind of engagement from an external penetration test, and it is expected alongside it.

    How Ostorlab helps

    Ostorlab does not run red team exercises and does not replace them. It keeps the app and API items of your remediation plan tested and retested, so the technology layer is in shape going into a red team cycle.

    What stays with you

    Scoping and running red team exercises, the RTSS, the Board decisions and the human and physical layer assessments.

  5. Guidelines on Minimum Compliance Standard for Payment Related Mobile Applications No. 1 of 2020, sections 5, 6 and 8

    Implement the mobile payment app controls: MFA, device binding, sessions and lockout

    What the text says

    The payment guideline requires user accounts and devices to be registered with the provider using the mobile number and a unique device identifier, with an account usable only on registered devices and no concurrent use of the same account from multiple devices. Authentication must be processed at the backend, except for methods based on biometrics or chip-based authentication. MFA combines the mobile number, device identifier, password or PIN and an identifier specific to the application. The app must have a configurable account lockout after multiple invalid login attempts, a randomized session ID, automatic user logoff after an idle time period, a clearly visible logoff that erases application specific sensitive data from temporary and permanent memory, server-side detection of simultaneous login attempts, and a procedure to disable the app centrally for a device reported lost or stolen.

    Source:Guidelines on Minimum Compliance Standard for Payment Related Mobile Applications No. 1 of 2020, sections 5, 6 and 8

    What it means for your mobile app

    These are testable behaviours, and they have to hold on the backend, not only in the app interface. An attacker who calls the API directly should meet the same controls.

    How Ostorlab helps

    Authenticated testing covers login and logout, token refresh, timeouts, session invalidation, account lockout and MFA enforcement with your test accounts, including the API calls behind them.

    What stays with you

    Identity and access management, device registration records and the lost-device process.

  6. Guidelines on Minimum Compliance Standard for Payment Related Mobile Applications No. 1 of 2020, sections 12, 13, 14 and 15

    Harden the app: tamper, root, debugging and pinning

    What the text says

    The guideline requires server-side integrity checks on hash values or checksums of code blocks, on file sizes and modification timestamps, and on the signature of the package file, with the app disabled if the checks fail. The app must not run on rooted or jailbroken devices. Debugger and emulator detection must be implemented, minification and source code obfuscation must be used, and third parties must not be able to debug the app at runtime. Transport layer encryption is required for all communication, with valid SSL certificates from a trusted certificate authority, certificate pinning implemented with proper exception handling, and controls to mitigate pinning bypass. The app must cease operations until SSL certificate errors are properly addressed.

    Source:Guidelines on Minimum Compliance Standard for Payment Related Mobile Applications No. 1 of 2020, sections 12, 13, 14 and 15

    What it means for your mobile app

    These protections are what an attacker tests first on a payment app. A control that exists in code but can be bypassed at runtime does not count.

    How Ostorlab helps

    Mobile Shielding Scan tests root and jailbreak detection, anti-tampering, debugger and emulator checks and pinning at runtime, and shows which protections held and which were bypassed.

    What stays with you

    Obfuscation and code signing infrastructure, app store releases and the app's behaviour in the field.

  7. Guidelines on Minimum Compliance Standard for Payment Related Mobile Applications No. 1 of 2020, sections 11 and 16; Banking Act Directions No. 16 of 2021, 5.8.2

    Keep components patched and prove it

    What the text says

    Payment related mobile applications must not use vulnerable or deprecated components, protocols, libraries or scripts, implementations of those components must not lead to vulnerabilities, and the app must be properly patched if a vulnerability is identified. Cryptographic algorithms and iteration counts must be currently not identified as vulnerable, industry-tested and accepted by institutions such as the FFIEC, ANSI and NIST. Under the technology risk directions, vulnerabilities identified in assessments must be remediated within a time period approved by the ISC.

    Source:Guidelines on Minimum Compliance Standard for Payment Related Mobile Applications No. 1 of 2020, sections 11 and 16; Banking Act Directions No. 16 of 2021, 5.8.2

    What it means for your mobile app

    The SDKs and native libraries in a banking app are shipped software. Each one needs a known version, a severity when a vulnerability appears, and a fix deadline you can prove.

    How Ostorlab helps

    SCA fingerprints statically compiled libraries and maps them to known vulnerabilities release after release. Closure is tracked as tickets in the platform or in Jira and ServiceNow, and findings are rated critical, high, medium or low.

    What stays with you

    Patching decisions, vendor maintenance contracts, upgrade planning and risk acceptance.

  8. Banking Act Directions No. 16 of 2021, 5.5.1; Guidelines No. 1 of 2020, sections 9.3, 11.2 and 11.3; Personal Data Protection Act No. 9 of 2022, section 10

    Protect customer data on the device and in transit

    What the text says

    Under the technology risk directions, customer data is protected using encryption: database or file level encryption at rest, encryption for data in transit, and full disk encryption for endpoint devices and removable media that store customer data. Where encryption is not feasible or appropriate, deviations need Board approval, compensating controls and monitoring, and a review at least once every two years. The payment guideline adds that sensitive information such as account numbers and customer credentials in temporary storage on the device must be secured, that sensitive data is encrypted in transit and at rest, that encryption keys are not stored on the mobile device without appropriate security controls, and that sensitive data is not stored on the device. The Personal Data Protection Act requires controllers to ensure the integrity and confidentiality of personal data with appropriate technical and organizational measures, including encryption, pseudonymisation, anonymisation or access controls.

    Source:Banking Act Directions No. 16 of 2021, 5.5.1; Guidelines No. 1 of 2020, sections 9.3, 11.2 and 11.3; Personal Data Protection Act No. 9 of 2022, section 10

    What it means for your mobile app

    Tokens, account numbers and credentials should never sit in clear text in the app's storage, caches, logs or crash reports, and they should not travel unprotected to the backend.

    How Ostorlab helps

    Ostorlab looks for session tokens and personal data in local storage, caches, logs and screenshots, and checks for misconfigurations that weaken transport and session protections.

    What stays with you

    Data classification, key management, backups, and the deviation process with the Board.

  9. Payment and Settlement Systems Circulars No. 01 of 2024, No. 02 of 2024 and No. 01 of 2026

    Apply the JustPay OTP threshold and payment app onboarding checks

    What the text says

    For JustPay transactions of Rs 10,000 or more, the mobile payment application that initiates the transaction must request a one-time password from the issuer of the linked account, sent to the mobile number registered with the issuer. This has applied since 1 April 2024. From 31 March 2025, providers must identify users with an acceptable identity document, verify that identity before allowing transactions or linking an account, and, for JustPay, verify that the app user and the account owner are the same by matching the mobile number of the device with the mobile number registered for the account. Circular No. 01 of 2026 caps JustPay transactions at Rs 150,000 from 2 February 2026 and requires all mobile payment application providers to implement adequate security controls and procedures when registering customers and linking accounts.

    Source:Payment and Settlement Systems Circulars No. 01 of 2024, No. 02 of 2024 and No. 01 of 2026

    What it means for your mobile app

    OTP enforcement and the identity checks are backend behaviours. Test them by trying to complete a transaction or link an account without the required factor or with the wrong device.

    How Ostorlab helps

    Ostorlab completes SMS, email or TOTP one-time codes with your test accounts and tests OTP enforcement, MFA and step-up flows, together with the API calls behind account linking and payments.

    What stays with you

    The identity verification process, device registration records and the transaction limits configuration.

  10. Guidelines on Minimum Compliance Standard for Payment Related Mobile Applications No. 1 of 2020, section 25

    Audit before launch and report annually

    What the text says

    Each payment service provider must submit a compliance report, approved by its Board of Directors, to the Director of the Payments and Settlements Department before the commercial launch of each payment related mobile application, and a report for the preceding year before 31 January each year covering new versions, patches and updates. An information system audit and an information security audit of the whole ecosystem are strongly recommended by an independent third-party auditor, with a scope that includes static and dynamic security analysis, source code review for secure controls, backdoors and hardcoded sensitive information, production and testing environment reviews, and vulnerability assessment and penetration testing reviews.

    Source:Guidelines on Minimum Compliance Standard for Payment Related Mobile Applications No. 1 of 2020, section 25

    What it means for your mobile app

    The compliance file needs evidence, not just claims, and every new version restarts the cycle in practice.

    How Ostorlab helps

    Ostorlab produces scan results, request and response evidence, exploits you can replay and retest results for each release, which you can attach to the audit file. Ostorlab does not submit reports to CBSL and is not an audit firm.

    What stays with you

    Board approval of the compliance report, the submissions to CBSL and any opinion you ask a licensed audit firm for.

Summary of public CBSL texts and the Personal Data Protection Act, checked on 27 September 2026. The payment guideline items are summarised from the English text. This page is not legal advice.

Mapping

CBSL rules, control by control

The controls the CBSL texts point to, how Ostorlab tests them in your app and its APIs, and the evidence you can keep.

CBSL rules, control by control
ControlHow Ostorlab helpsEvidence you keep
Pre-implementation security testing of the appDirections 16/2021, 5.8.1Mobile SAST on the APK, AAB or IPA and Mobile DAST in CI/CD, on every change, with no source code needed. Details Scan results per build and per change, attached to the release record
Quarterly vulnerability assessments on productionDirections 16/2021, 5.8.2Scheduled scans from your pipeline on the production build, and monitoring of store releases without manual triggers. Details Assessment results per quarter, with severity and remediation status
Annual penetration test by independent external expertsDirections 16/2021, 5.8.3AI-agent pentest of the app and its APIs behind login, including grey box flows with your test accounts. Details A working exploit you can replay for each AI-agent finding, and a coverage heatmap
Login, MFA and account lockoutGuideline 01/2020, 6Logs in with one-time codes and tests MFA enforcement, step-up flows and lockout after invalid attempts. Details Findings on login and lockout flows, with reproduction steps
Device registration, sessions and lost-device disableGuideline 01/2020, 5 and 8Tests session randomization, idle logoff, session invalidation and the API calls behind device registration. Details Session and token findings, with request and response logs
Tamper, root and emulator detection, certificate pinningGuideline 01/2020, 12 to 15Tests root and jailbreak detection, anti-tampering, debugger and emulator checks and pinning at runtime. Details Bypass evidence showing which protection failed and what it exposed
Vulnerable components and patch deadlinesGuideline 01/2020, 11 and 16Fingerprints statically compiled libraries and maps them to known vulnerabilities, release to release. Details Mapped vulnerabilities with upgrade or replace recommendations, and closure tracked across releases
Hardcoded keys and sensitive configurationGuideline 01/2020, 16.5Finds API keys, tokens and credentials in the app package and validates whether they work. Details Validated secrets, with the permissions and services they expose
Customer data on the device and in transitDirections 16/2021, 5.5.1; Guideline 11Looks for tokens and personal data in storage, caches, logs and screenshots, and checks transport protections. File system evidence showing what was written, where and when
Third-party SDKs and infrastructure in the releaseDirections 16/2021, 9.9; Guideline 23Lists the SDKs and native libraries in each release and shows which backends the app and its SDKs talk to. Details Component identity, version and location in the app bundle, per release

Ostorlab tests controls in the app and its APIs. SOC monitoring, incident response and reporting, red team exercises, TLPT, disaster recovery, governance, vendor procurement and Board approvals stay with your teams.

Action plan

CBSL controls to test in your mobile app

A practical list for security and technology risk teams, based on the CBSL technology risk directions, the mobile payment guideline and the Personal Data Protection Act.

  1. Pre-release testing

    Put SAST or source code review and DAST in the pipeline for every change to the app and its backend, as the pre-implementation tests require.

  2. Quarterly vulnerability assessments

    Schedule app and API assessments on production at least quarterly, with remediation deadlines approved by the Information Security Committee.

  3. Annual penetration test

    Plan the Board-approved scope specification and the external test: black box and grey box, threat scenarios, production systems, and the 60-day executive summary to the Director of Bank Supervision.

  4. App hardening

    Test root and jailbreak detection, anti-tampering, debugger and emulator checks, obfuscation and pinning, and confirm the app disables itself when integrity checks fail.

  5. Authentication, OTP and sessions

    Verify MFA at the backend, account lockout, randomized session IDs, idle logoff that erases sensitive data, lost-device disable, and the JustPay OTP threshold.

  6. Components and secrets

    List the SDKs and libraries in each release, set fix deadlines by severity, and check the package for hardcoded keys and configuration.

  7. Data protection

    Check storage, caches, logs and crash reports for tokens and personal data, and keep encryption and the data protection measures documented.

  8. Report and retest

    Keep the pre-launch compliance report, the 31 January annual report and retest evidence for every fix.

A suggested list, not a CBSL template. This is not legal advice.

Sources

The official texts this page is based on, checked on 27 September 2026.

FAQ

Frequently asked questions

Straight answers on coverage, setup, and how results reach your team.

Can't find your answer? Book a demo or contact us.

Assess your mobile banking app the way the CBSL describes it

Start with a free scan of your app from the store, or book a demo to run logged-in tests of your app and APIs with our team.