FDIC Extends Digital Compliance Deadline—But Don’t Delay Your Planning

The FDIC has announced an extension to the compliance deadline for certain digital-related requirements under Part 328, which were originally outlined in FIL-65-2023. While institutions now have until March 1, 2026, to meet signage requirements for digital channels and ATMs, the deadline for physical signage remains May 1, 2025.

Financial institutions should begin preparations now—particularly if third-party vendors manage digital platforms. The upcoming changes involve detailed signage standards that may require extended lead times, coordination, and technical execution beyond internal capabilities. Taking early action can help minimize disruptions and avoid compliance setbacks.

Understanding the FDIC’s Part 328 Final Rule

The FDIC’s revised Part 328 rule modernizes signage and advertising regulations to reflect the realities of today’s digital banking environment. Its core objective is to help consumers clearly identify which products and services are insured by the FDIC—across both physical and online channels.

The rule outlines several significant updates, including:

• Physical Signage Updates: Institutions must display the updated FDIC sign at all locations where insured deposits are accepted. This includes adherence to new standards regarding size, design, and placement at branch entrances, teller windows, and other service areas.
• Digital Signage Requirements: Banks must now display the official digital FDIC sign on their homepage (near the bank name or logo), on all login or sign-in pages, and on any page where customers can initiate deposit transactions such as remote deposits or account transfers.
• Non-Deposit Product Disclosures: When offering non-deposit products—such as insurance or investments—whether in person or online, institutions must make it clear that the FDIC does not insure these offerings, are not deposits, and that they may lose value.
• Prohibition on Misrepresentation: The rule also tightens restrictions around the misuse of the FDIC name or logo, particularly by third parties, to avoid misleading consumers about insurance coverage.

These updates touch nearly every customer-facing aspect of an institution’s operations and require a thoughtful review of signage across physical and digital platforms. While the rule is regulatory in nature, it also offers an opportunity for institutions to improve transparency and reinforce consumer trust.

What’s Required by May 1, 2025

By May 1, 2025, institutions must meet the revised physical signage requirements outlined in the Final Rule. This includes proper placement of the official FDIC sign at branch entry points and throughout interior locations—particularly where deposit-taking activity or account openings occur. The signs must meet specific size and design standards and be clearly displayed to show that the institution is FDIC-insured.

Extended Deadline to March 1, 2026

Additional time has been granted for institutions to comply with the ruling’s digital and ATM-related signage requirements, with the new deadline for these aspects set for March 1, 2026. These rules apply to ATMs and similar self-service devices, as well as bank websites and mobile apps. Digital compliance involves displaying the FDIC digital sign on an institution’s homepage near the logo, on login or sign-in pages for retail and business customers, and on any page where depository transactions—such as transfers or remote deposits—can occur.

Take Action Now to Avoid Compliance Bottlenecks

While the extended deadlines offer flexibility, they should not be mistaken for extra time to wait. Adapting to the revised requirements of FDIC Part 328 is a multi-step process that may involve coordination with third-party vendors, technical scoping, and thorough testing—especially for digital platforms. These efforts can take longer than anticipated, making early planning critical. Contact a CRI advisor today to discuss your next steps. Our team is here to support you with signage reviews, vendor coordination, implementation planning, regulatory exam, and build a compliance strategy tailored to your institution’s needs