RBI Clarifies Capital Infusion for White Label ATM Applicants
Current · Source: Reserve Bank of India · RBI/2012-13/183 · issued 31 Aug 2012 · ~2 min read
Quick answerNon-bank entities can infuse capital after balance sheet audit to meet the Rs 100 crore net worth criterion for White Label ATM authorisation, provided they submit a CA certificate confirming the infusion.
The rule, in the simplest words
Non‑bank companies can add money after their balance sheet has been audited to reach the Rs 100 crore net worth needed for White Label ATM approval.
They must submit a certificate from a Chartered Accountant (CA) that the extra capital has been added and the net worth is now Rs 100 crore.
The CA can be the same accountant who audited the last balance sheet or one who did a limited review of the last quarter/half‑year accounts.
Banks and lenders should look for this CA certificate when checking White Label ATM applications.
This rule lets companies raise funds after the audit, so they don’t have to wait for the next audit cycle.
How it plays out — a real example
Ravi, a gold‑loan officer in Indore, receives a request from a fintech firm that wants to set up a White Label ATM. He asks for the CA certificate proving the firm added capital after its last audit. When Ravi sees the certificate, he happily approves the partnership, allowing the firm to launch the ATM without delay.
What changed
RBI clarified that non-bank entities seeking authorisation to set up White Label ATMs can infuse additional capital after their balance sheet has been audited to meet the net worth requirement of Rs 100 crore. Earlier, queries had arisen whether post-audit capital infusion would be accepted for this purpose.
What it means for you
This gives non-bank WLA applicants flexibility to raise capital after their audited financials are finalised, without waiting for the next audit cycle. Banks and lenders dealing with such entities should note that the net worth certification can now be based on a CA certificate of infusion rather than only audited balance sheet figures.
What you must do
Verify that non-bank WLA applicants submit a CA certificate confirming additional capital infusion to meet the Rs 100 crore net worth criterion.
Accept certificates from the entity's existing auditor who audited the last balance sheet or from a CA who conducted a limited review of the last quarter/half-year accounts.
Update internal due diligence checklists to reflect this clarification when processing WLA-related applications or partnerships.
Who it affects
Non-bank entities applying for White Label ATM authorisation, Scheduled Commercial Banks including RRBs, Urban Co-operative Banks and State/District Central Co-operative Banks, Authorised ATM and card payment network operators
❓ Common questions
Can a non-bank entity infuse capital after its balance sheet is audited to meet the Rs 100 crore net worth requirement?
Yes, RBI has clarified that such post-audit capital infusion is allowed, provided the entity submits a certificate from a Chartered Accountant confirming the additional capital has been infused to meet the net worth criterion.
Who can issue the certificate for capital infusion?
The certificate can be issued either by the entity's existing Chartered Accountant who audited the last balance sheet, or by a CA who conducted a limited review of the accounts for the last quarter or half-year.
📜 Read the original circular — full text as issued by RBI
RBI/2012-13/183
DPSS.CO.PD. No.391/02.10.002/2012-13
August 31, 2012
The Chairman and Managing Director / Chief Executive Officers
All Scheduled Commercial Banks including RRBs /
Urban Co-operative Banks / State Co-operative Banks /
District Central Co-operative Banks
Authorised ATM Network Operators /Card Payment Network Operators
Prospective White Label ATM Operators.
Dear Sir,
White Label ATMs (WLAs) in India - Guidelines
Please refer to the guidelines issued vide DPSS.CO.PD. No.2298/02.10.002/2011-2012 dated June 20, 2012 on the captioned subject.
2. We have been receiving queries from non bank entities, whether infusion of capital to satisfy the criteria of net worth of Rs 100 crore would be considered if the capital is infused after the entities’ balance sheet have been audited while seeking authorisation from RBI under the PSS Act, for setting up White Label ATMs.
3. It is clarified that such non-bank entities that wish to infuse capital can do so provided they submit a certificate to this effect from a Chartered Accountant that additional capital has been infused to satisfy the criterion of net-worth of Rs. 100 crore. The certificate to this effect may be submitted from its existing Chartered Accountant who has audited the entity’s last balance sheet or a Chartered Accountant who has conducted a limited review of the accounts of the last quarter / half-year along with the application seeking authorisation as per the stipulated guidelines.
Yours faithfully,
(Vijay Chugh)
Chief General Manager
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2012-13/183 · issued 31 Aug 2012. The plain-English explanation above is BankPulse’s own independent summary.
Verify that non-bank WLA applicants submit a CA certificate confirming additional capital infusion to meet the Rs 100 crore net worth criterion.
Update internal due diligence checklists to reflect this clarification when processing WLA-related applications or partnerships.
📜 Compliance
Accept certificates from the entity's existing auditor who audited the last balance sheet or from a CA who conducted a limited review of the last quarter/half-year accounts.
Grouped from the action items above — a single circular may involve more than one team.
Worked example & action-note template
Example: if you are an IT/Systems lead at a bank this circular applies to (Non-bank entities applying for White Label ATM authorisation, Scheduled Commercial Banks including RRBs, Urban Co-operative Banks and State/District Central Co-operative Banks, Authorised ATM and card payment network operators), your first concrete step on “RBI Clarifies Capital Infusion for White Label ATM Applicants” is: “Verify that non-bank WLA applicants submit a CA certificate confirming additional capital infusion to meet the Rs 100 crore net worth criterion.” (RBI issued this 31 Aug 2012).
Circular: RBI/2012-13/183 -- RBI Clarifies Capital Infusion for White Label ATM Applicants
Issued: 31 Aug 2012
Action required: Verify that non-bank WLA applicants submit a CA certificate confirming additional capital infusion to meet the Rs 100 crore net worth criterion.
Action required: Accept certificates from the entity's existing auditor who audited the last balance sheet or from a CA who conducted a limited review of the last quarter/half-year accounts.
Action required: Update internal due diligence checklists to reflect this clarification when processing WLA-related applications or partnerships.
Owner: ____________ Target date: ____________
Board/committee approval needed? Y / N
Evidence filed in compliance register on: ____________
Built only from this circular’s own published fields — not legal advice; always confirm against the official RBI source.
💬 Banker Discussion
Discuss this circular with fellow bankers — reply, upvote what helps, report what doesn’t belong. Be professional; no client data. Views are the commenter’s own, not BankPulse’s.
BankPulse Compliance Evidence Pack — generated 03 Aug 2026 · status cross-checked against RBI’s official withdrawal register (refreshed weekly). Official RBI source: https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=7535&Mode=0 — Plain-English summary by BankPulse (bankpulse.ai), reviewed by our expert reviewer, CA Amit Jain. Independent platform, not affiliated with the Reserve Bank of India; is our own plain-English paraphrase, not RBI’s original wording.
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