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Security, data handling and the rules

What happens to your documents, and what the regulators say

No badges that say "compliant". Below: exactly what each edition stores and for how long, what never appears in a log, and the regulators' own words with links to the instruments.

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Data handling

Where your documents go, by edition

 AWS Marketplace editionHosted APIOn-premises edition
Where documents are processedYour AWS account, your regionHabileLabs' AWS account, MumbaiYour server or data centre
What leaves your environmentA licence check; a daily page count unless switched offThe document, for the time it takes to maskNothing
RetentionDeleted within a day, in your bucketDeleted within 24–48 hoursYour folders, your policy
Audit recordPer-page JSON in every answer, plus your own CloudWatch logsPer-page JSON in every answerSpreadsheet per run, row per file

In transit and at rest

TLS 1.2 or better at the edge, with a web application firewall in front of the API; storage encrypted at rest with no public access; download links signed and short-lived.

What is never logged

Document content, Aadhaar numbers and API keys. Logs hold request ids, timings, page counts and the per-page record of what was found and covered.

What never happens

Documents are not used to train or tune anything. The hosted service keeps no copy past the retention window; the other editions never see your documents at all.

Claims

What we claim, and what we do not

We claim

  • Measured accuracy, with the method and the misses published on the Accuracy page.
  • AWS Qualified Software for the AWS Marketplace edition: AWS's Foundational Technical Review of its security, reliability and operations, valid two years from approval. About the review
  • That the product produces UIDAI's masked form and is built to the rules quoted below.

We do not claim

  • ISO 27001 or SOC 2 certification. HabileLabs does not hold them for this product.
  • That any regulator has "approved" or "certified" the product. Regulators set rules for you; we show the rules and how the product meets them.
  • A number "without a miss". The misses are listed on the Accuracy page.
The rules

What the regulators actually say

Each quote is the regulator's own wording, with the instrument, the clause and a link. The line under each says what it means for a lender.

UIDAI

“Masked Aadhaar implies replacing of first 8 digits of Aadhaar number with 'xxxx-xxxx' while only last 4 digits of the Aadhaar Number are visible.”

UIDAI FAQ: what is masked Aadhaar · e-Aadhaar FAQ

This is the form the engine produces: the first eight digits covered, the last four left readable.

UIDAIupdated 21 August 2025

“no entity, including a requesting entity, which is in possession of the Aadhaar number of an Aadhaar number holder, shall make public any database or record containing the Aadhaar numbers of individuals, unless the Aadhaar numbers have been redacted or blacked out through appropriate means, both in print and electronic form.”

Aadhaar (Sharing of Information) Regulations, 2016 · Regulation 6(3)

Any copy that leaves your control, on paper or as a file, must already be masked.

UIDAI

“No entity … shall retain Aadhaar numbers or any document or database containing Aadhaar numbers for longer than is necessary for the purpose specified to the Aadhaar number holder at the time of obtaining consent.”

Aadhaar (Sharing of Information) Regulations, 2016 · Regulation 6(5)

A loan file that keeps the full number for years is a retention problem, not just a sharing one.

UIDAI4 November 2025

“Actual Aadhaar number should not be stored in any business databases other than ADV”

UIDAI Circular No. 14 of 2025 (Aadhaar Data Vault) · Directions to requesting entities

For requesting entities the full number belongs in the Aadhaar Data Vault alone; documents elsewhere should carry the masked form.

RBI28 November 2025

“The bank shall, where its customer submits a proof of possession of Aadhaar Number containing Aadhaar Number, ensure that such customer redacts or blacks out his Aadhaar number through appropriate means”

Reserve Bank of India (Commercial Banks – Know Your Customer) Directions, 2025 · Paragraph 23, Explanation 1 (the same text stood in Section 16 of the KYC Master Direction, 2016)

The duty to ensure redaction sits with the regulated entity. It is not the customer's job.

RBI9 January 2020

“RE shall ensure to redact or blackout the Aadhaar number in terms of Section 16.”

RBI amendment to the KYC Master Direction (Video-based Customer Identification Process) · RBI/2019-20/138, DOR.AML.BC.No.27

Video KYC captures are covered too: the Aadhaar shown on camera must end up redacted in the record.

MeitY13 February 2019

“Every reporting entity shall, where its client submits his Aadhaar number, ensure such client to redact or blackout his Aadhaar number through appropriate means where the authentication of Aadhaar number is not required under sub-rule (15).”

Prevention of Money-laundering (Maintenance of Records) Amendment Rules, 2019 · Rule 9(16), G.S.R. 108(E)

The root rule behind RBI, SEBI and IRDAI's wording: every reporting entity, every Aadhaar copy taken without authentication.

SEBI12 October 2023

“It shall be ensured that full Aadhaar number is not stored and displayed anywhere in the system and wherever required only last 4 digits of Aadhaar number may be displayed.”

SEBI Master Circular on Know Your Client (KYC) norms · SEBI/HO/MIRSD/SECFATF/P/CIR/2023/169

For intermediaries the rule reaches the systems, not just the paperwork: nothing stored or shown beyond the last four digits.

IRDAI29 January 2019

“At no point in time, more than last four digits of the Aadhaar number of any individual should be stored by the insurers in physical or digital form.”

IRDAI circular on Aadhaar as a KYC document · Circular of 29 January 2019, as reported

Insurers may keep the last four digits and nothing more, on paper or on disk.

IRDAI1 August 2022

“Insurers shall ensure to redact or blackout the Aadhaar number as per extant PML Rules”

IRDAI Master Guidelines on Anti-Money Laundering / Counter Financing of Terrorism, 2022 · IRDAI/IID/GDL/MISC/160/8/2022, effective 1 November 2022

The same "shall ensure" duty as banks and NBFCs, written into the insurance AML guidelines.

Parliament2023; penalty provisions commence 13 May 2027 under the 2025 Rules

“May extend to two hundred and fifty crore rupees”

Digital Personal Data Protection Act, 2023 · The Schedule: breach of the duty to take reasonable security safeguards, section 8(5)

An archive of unmasked Aadhaar copies is personal data without reasonable safeguards. This is the ceiling.

MeitY13 November 2025

“securing of personal data through encryption, obfuscation, masking or the use of virtual tokens mapped to that personal data”

Digital Personal Data Protection Rules, 2025 · Rule 6(1)(a), the minimum reasonable security safeguards

Masking is named in the Rules as a minimum safeguard.

MeitY13 November 2025

“within seventy-two hours of becoming aware of the breach”

Digital Personal Data Protection Rules, 2025 · Rule 7(2)(b), notice of a personal data breach to the Board

Three days to tell the Board, and every affected person must be told without delay.

Parliament

“Whoever, intentionally discloses, transmits, copies or otherwise disseminates any identity information collected in the course of enrolment or authentication to any person not authorised under this Act … shall be punishable with imprisonment for a term which may extend to three years”

Aadhaar (Targeted Delivery of Financial and Other Subsidies, Benefits and Services) Act, 2016 · Section 37

Disclosure of identity information is a criminal offence, not only a regulatory one.

RBI8 May 2025

“all data is stored only in servers located within India”

Reserve Bank of India (Digital Lending) Directions, 2025 · Paragraph 13(iv); data processed outside India "shall be deleted from servers outside India and brought back to India within 24 hours of processing"

Where a masking service runs, and where it keeps your files, is part of the compliance question.

Why it matters

The eight problems the product is bought to solve

The regulator says "ensure". Your customers won't black out anything.

RBI, SEBI and IRDAI each put the duty on the regulated entity: it "shall ensure" the Aadhaar number is redacted. In practice customers hand over full copies, field staff photograph full cards, and the duty lands on whoever stores the file.

What Aadhaar Masking does: Masking happens at the point of capture or ingestion, by the API or inside your DMS, so the stored copy is the redacted one.

Every unmasked copy in your archive is a breach waiting for a date.

The large Indian KYC exposures of 2024–25 were not live systems: they were archives. 36 million KYC files of an RBI-registered NBFC in an open storage bucket; 27 million files of a micro-lender; 4 million KYC forms of an ISP, Aadhaar copies among them.

What Aadhaar Masking does: Point the batch mode at the archive: ZIPs of up to 500 MB through the API, or a folder-in, folder-out run on your own servers, at about 500 pages a minute.

DPDP puts a price on it: up to ₹250 crore, and 72 hours to report.

The Digital Personal Data Protection Act's schedule caps the penalty for failing reasonable security safeguards at two hundred and fifty crore rupees. The 2025 Rules name "encryption, obfuscation, masking" as the minimum safeguards and give you seventy-two hours to notify the Board of a breach. Full effect: 13 May 2027.

What Aadhaar Masking does: A masked archive is a safeguarded archive; the masked copy is what a breach would expose.

Holding the full number is itself a retention breach.

UIDAI's Sharing of Information Regulations forbid keeping Aadhaar numbers "for longer than is necessary", and Circular 14 of 2025 tells requesting entities the actual number lives in the Aadhaar Data Vault and nowhere else. A loan file that still shows the full number years later fails both.

What Aadhaar Masking does: Masked copies can be kept for the life of the loan; the vault keeps the number, the file keeps the last four digits.

Prove it was masked, before the inspector asks.

RBI's Directions require exception records "available for supervisory review", and RBI fined a public-sector bank ₹1.32 crore in 2024 for failing to preserve customer-identification records. An auditor wants to know which files were masked, when, and what was found.

What Aadhaar Masking does: Every answer carries a per-page record: Aadhaar found, number masked, QR covered; the on-premises edition writes a spreadsheet for the whole run.

Field photos defeat ordinary OCR masking.

Loan files are phone photos of cards in plastic sleeves, faxed scans, rotated pages and photocopies of photocopies. Text-only tools fail quietly on them and log the page as "not an Aadhaar". Those pages are exactly where the number stays readable.

What Aadhaar Masking does: The engine looks at the page four ways round, reads each candidate twice and checks the checksum; 99.94% of numbers on real loan files, misses published.

Masking the card isn't enough: the number is in the form, the deed and the QR.

Applicants write the number into forms. Sale deeds and gift deeds print both parties' numbers in running Hindi text. Maharashtra had to hide Aadhaar numbers in registered-document copies in 2024. And the QR code on older Aadhaar letters is plain XML that carries the full number.

What Aadhaar Masking does: Numbers in running text in English and Hindi, numbers split across lines, and every Aadhaar QR code, wherever it is on the page.

Sending documents to a vendor's cloud is its own compliance problem.

UIDAI's Circular 14 limits where Aadhaar data may be hosted. RBI's Digital Lending Directions require that "all data is stored only in servers located within India" and that anything processed abroad is deleted and brought back within 24 hours. Most masking APIs want your documents on their servers.

What Aadhaar Masking does: Run it inside your own AWS account from AWS Marketplace, or on your own servers. Nothing leaves. Nothing to explain.

Get started

Judge it on one of your own files

Send a card photo, a scan or a short PDF and get it back masked by the production engine, with a per-page record of what was covered. Or book thirty minutes with a HabileLabs engineer to see it on your document types and plan a deployment in your AWS account.

Or email support@habilelabs.io · Monday to Friday, 10:00–19:00 IST (excluding public holidays)