HomeCirculars › RBI/2012-13/183

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
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

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.
🧰 Tools — save, print, templates & related
Who does what — compliance checklist
💻 IT / Systems
  • 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).

  1. Circular: RBI/2012-13/183 -- RBI Clarifies Capital Infusion for White Label ATM Applicants
  2. Issued: 31 Aug 2012
  3. 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.
  4. 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.
  5. Action required: Update internal due diligence checklists to reflect this clarification when processing WLA-related applications or partnerships.
  6. Owner: ____________ Target date: ____________
  7. Board/committee approval needed? Y / N
  8. 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.

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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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