Centralized Positive Pay System (CPPS) Explained: Real-World Threats, Practical Risks and How to Control Them

CPPS: The Hidden Threat of Manual Entry and the Path to Biometric Security

Examining the accountability gap in India's Centralized Positive Pay System

Imagine being a bank officer in a bustling branch. A customer walks in, signs a CPPS (Centralized Positive Pay System) confirmation form, and you verify the signature against your system. It looks perfect. You process it in good faith. Weeks later, a fraud is detected—the signature was a masterpiece of forgery, and the "customer" was an impostor.

Under current rules, you might be the one facing an explanation call or a disciplinary inquiry. Even though you followed every rule, the manual nature of CPPS left you holding the bag. Instances have come to notice where manual Positive Pay confirmations, despite procedural compliance, were misused through impersonation and forged signatures, leading to fraudulent cheque clearances. In several such cases, branch officials were held accountable even though the prescribed process had been followed in good faith.

Banking operational risk

📌 What is CPPS and Why was it Introduced?

The Centralized Positive Pay System (CPPS) was introduced by the RBI to combat high-value (above Rs. 50000) cheque fraud. Traditionally, banks relied on signature verification, but "Cheque Washing" and expert forgeries made signatures insufficient. CPPS adds a second layer: the drawer must pre-submit details (amount, date, payee) to the bank.

The Goal: No data match = No payment. It was designed to turn subjective signature verification into objective data matching.

📌 The Reality: Why Manual Entries are a Trap

While digital CPPS (through Mobile Banking, SMS, Internet Banking) is secure, manual confirmation forms at branches have become a weak link. Fraudsters now use forged signatures on the CPPS forms themselves to authorize fake cheques. Once a banker enters this in good faith, the fraud becomes "system-approved," and the frontline staff is unfairly held accountable for the loss.

While the allowance of manual CPPS confirmation is understandable from a financial inclusion and customer convenience perspective, it has inadvertently introduced a residual vulnerability at the authentication stage. This gap not only impacts fraud risk but also results in disproportionate accountability exposure for frontline staff, which may not align with the intended objective of system-driven risk mitigation under CPPS

📌 A Path Forward: The Self-Service CPPS Kiosk

To protect both the institution’s customers and its employees, the bank should prioritize the implementation of Aadhaar-based Biometric Kiosks to replace traditional manual entry workflows. Under this model, all transactions become customer-induced, shifting the responsibility for data input entirely to the user while maintaining a simplified interface to ensure those who are not tech-savvy remain part of the financial inclusion net. Instead of handing physical documents to a teller, customers manually input their own cheque information and transaction details directly into the kiosk. To finalize and authorize the request, the system requires mandatory authentication through either Aadhaar-linked biometric scanning (fingerprint or iris) or a secure OTP sent to their registered mobile device. This transition not only prevents unauthorized access through robust multi-factor identity verification but also ensures that staff members are protected from allegations of data manipulation or clerical errors.

Biometric Kiosk Solution

Ultimately, this shift transforms the CPPS from a mere compliance checkbox into a living shield of operational integrity and genuine consumer trust.

This article is a representation of operational risks and a proposal for policy reform to protect bank customers and employees.

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