Top risks and controls for Digital Banking

From the Doorstep International risk register, curated by Ahmer Nehal. Last updated 17 Oct 2026.

The Digital Banking register lists 17 key risks and 42 best-practice controls across 5 units: Digital Channels, Digital Customer Experience, Digital Marketing and Sales, Digital Payments, Digital Strategy and Innovation. Use it to identify risks, benchmark your existing controls or start a risk and control self-assessment (RCSA).

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AI-era lens: digital channels are where customers meet AI first, through chatbots, onboarding checks and fraud scoring. Failures here are visible, fast and reputational. Pair the controls below with the digital banking controls guide.

Commercial banks have incorporated digital banking features more frequently in the current digital era to offer their clients quick and effective financial services.

To ensure the security and safety of customer data, transactions, and assets, risks associated with digital banking must be carefully controlled.

Therefore, risk evaluation is essential for a commercial bank's digital banking operation.

Banks can build effective risk management strategies to lessen the impact of threats and safeguard the interests of their customers by discovering, analysing, and evaluating potential risks.

Inadequate risk assessment can result in major monetary losses, harm to one's reputation, and legal implications, all of which eventually erode consumer trust and confidence in the bank.

Digital Channels: key risks and controls

This department is in charge of overseeing the bank's digital channels, which include ATMs, mobile and internet banking, and other self-service options.

Risk	What can go wrong	Best-practice controls
Cybersecurity Risks	This is the most significant risk facing the digital banking department. Cyber attacks such as hacking, phishing, and malware can compromise the security of customer information, transaction data, and the bank's reputation.	Multi-factor Authentication: Multi-factor authentication is the most effective control for preventing unauthorized access to customer accounts and transaction data. It requires users to provide two or more authentication factors, such as a password and a one-time code sent to their mobile device. Encryption: Encryption is an effective control for protecting sensitive customer information, transaction data, and other critical information from being intercepted or accessed by unauthorized parties. Employee Training: Regular employee training and awareness programs can help employees recognize and avoid common cyber threats such as phishing emails and social engineering attacks.
Data Breaches	A data breach can occur due to human error, technical issues, or malicious attacks, leading to the loss or theft of sensitive customer information.	Access Control: Limiting access to sensitive data to authorized personnel is the most effective control to mitigate the risk of data breaches. Access control can be achieved through technical measures such as authentication, authorization, and encryption, as well as physical measures such as security cameras, guards, and biometric controls. Data Encryption: Encrypting sensitive data such as customer information, transaction data, and passwords can prevent unauthorized access and ensure the confidentiality of the data.
Identity Theft and Fraud	Digital channels are vulnerable to identity theft and fraud, which can cause financial losses for both customers and the bank.	Multi-factor Authentication (MFA): Implementing strong authentication measures such as MFA can significantly enhance security. MFA requires users to provide multiple forms of identification, such as a password, a unique code sent to their mobile device, or biometric authentication, before granting access. This helps prevent unauthorized access to customer accounts, reducing the risk of identity theft and fraud. Encryption and Secure Communication Protocols: Implement robust encryption mechanisms and secure communication protocols to protect sensitive customer information.

Digital Customer Experience: key risks and controls

The seamless and satisfying consumer experience across all digital platforms is the responsibility of this division.

Risk	What can go wrong	Best-practice controls
Cybersecurity Risks	Cyber threats such as hacking, phishing, and malware can compromise customer information, transaction data, and the bank's reputation.	Strong Authentication Measures: Implementing robust authentication measures is crucial to protect customer information and prevent unauthorized access. This includes the use of multi-factor authentication (MFA) methods such as combining passwords with biometric verification, tokens, or one-time passwords (OTPs). Strong authentication makes it significantly harder for hackers to gain unauthorized access to customer data and the bank's systems. Continuous Employee Training and Awareness Programs: Implementing ongoing training programs and fostering a culture of cybersecurity awareness among employees are vital measures to mitigate cyber threats. By regularly updating employees on the latest hacking techniques, phishing scams, and malware threats, they can stay vigilant and take appropriate actions to protect customer information and the bank's reputation. Training should cover topics such as safe browsing practices, password hygiene, identifying suspicious emails or attachments, and reporting security incidents promptly. By empowering employees with the knowledge and skills to recognize and respond to cyber threats, banks can significantly enhance their overall security posture.
Inadequate Customer Support	Customers expect timely and effective support from the bank in case of any issues they face while using digital channels. Inadequate customer support can lead to customer dissatisfaction and loss of trust.	Customer Service Training: Providing comprehensive training to customer service representatives on digital banking products and services, as well as effective communication skills, can improve the quality of customer support and lead to higher customer satisfaction. Customer Feedback Mechanisms: Establishing customer feedback mechanisms such as surveys, feedback forms, and complaint tracking systems can help the bank identify areas for improvement and address customer concerns promptly. Service Level Agreements (SLAs): SLAs can be established to define the level of service that customers can expect from the bank, including response times for inquiries and issue resolution.
Insufficient Customer Education	Customers may lack the knowledge or understanding of how to use digital channels effectively and securely.	User Education and Training: Providing education and training programs for customers on the safe and secure use of digital channels is the most effective control. This can include online tutorials, webinars, and one-on-one sessions with bank staff. User Authentication and Authorization: Implementing strong user authentication and authorization measures, such as two-factor authentication, can help prevent unauthorized access to digital channels. User-friendly Interfaces: Designing user-friendly interfaces and providing clear instructions and prompts can help customers use digital channels effectively and securely.
Technical Issues	Technical issues such as system outages, slow response times, and errors can disrupt digital banking services, negatively impacting the customer experience.	Redundancy and Resilience Measures: Implementing redundancy and resilience measures is crucial to minimize the impact of system outages and ensure uninterrupted service. This can include having backup servers, employing load balancing techniques, implementing failover mechanisms, and utilizing cloud infrastructure with built-in redundancy. These measures help maintain service availability and reduce the likelihood of disruptions. Robust Monitoring and Alerting Systems: Deploying effective monitoring and alerting systems allows proactive detection and identification of technical issues.

Digital Marketing and Sales: key risks and controls

This department is in charge of advertising the bank's digital services and generating sales through those channels.

Risk	What can go wrong	Best-practice controls
Compliance Risks	The bank must comply with regulatory requirements and industry standards governing digital marketing and sales operations. Non-compliance can lead to legal and reputational risks.	Robust Compliance Framework: Implement a comprehensive compliance framework that includes policies, procedures, and guidelines specifically tailored to digital marketing and sales operations. This framework should cover all relevant regulatory requirements and industry standards, and provide clear instructions and protocols for employees to follow. Regular training and awareness programs should be conducted to ensure employees understand and adhere to the compliance framework. Regular Compliance Assessments: Conduct periodic assessments to evaluate the bank's adherence to regulatory requirements and industry standards in digital marketing and sales operations. These assessments should be conducted by an independent internal or external party with expertise in compliance. The assessments should encompass a comprehensive review of processes, systems, controls, and documentation to identify any areas of non-compliance. Any identified gaps or deficiencies should be promptly addressed and remediated to ensure ongoing compliance and mitigate potential legal and reputational risks.
Fraudulent Activities	Promoting digital offerings through digital channels can make the bank vulnerable to fraudulent activities, such as phishing scams, identity theft, and other online scams.	Customer Education and Awareness: Educating customers about digital security risks, safe online practices, and how to identify and report fraudulent activities can help mitigate the risk of fraudulent activities. Two-Factor Authentication: Implementing two-factor authentication for digital channels can add an extra layer of security and reduce the risk of unauthorized access. Monitoring and Detection: Implementing monitoring and detection systems to identify and prevent fraudulent activities can help minimize the risk of financial loss and reputational damage.
Privacy Risks	Digital marketing and sales activities involve the collection, processing, and storage of customer data.	Data Encryption: Encryption is the most effective control to mitigate the risk of unauthorized access to sensitive customer data. It ensures that data remains protected even if it falls into the wrong hands. Access Control: Limiting access to customer data to authorized personnel through authentication, authorization, and other access control measures can significantly reduce the risk of data breaches. Data Minimization: Collecting and storing only the necessary customer data can reduce the risk of data breaches and limit the potential impact of a breach.

Digital Payments: key risks and controls

The management of the bank's digital payment services, including as mobile payments, person-to-person payments, and digital wallets, falls under the purview of this division.

Risk	What can go wrong	Best-practice controls
Fraudulent Transactions	Digital payment services are vulnerable to fraudulent transactions, which can result in financial losses for both the bank and its customers.	Multi-factor Authentication (MFA): Implementing MFA is one of the most effective ways to enhance security. By requiring users to provide multiple forms of identification (such as a password, biometric authentication, or a one-time verification code), MFA significantly reduces the risk of unauthorized access and fraudulent transactions. Transaction Monitoring and Analytics: Employ robust transaction monitoring systems that use advanced analytics and artificial intelligence to detect suspicious patterns and behaviors.
System Outages	Technical issues and system failures can cause payment processing delays, service disruptions, and impact the customer experience.	Redundancy and Disaster Recovery: Implementing redundancy and disaster recovery measures, such as backup systems and contingency plans, is the most effective control to mitigate the risk of system failures and ensure uninterrupted service. Monitoring and Alerting: Using monitoring and alerting tools can help detect technical issues early and allow for prompt resolution before they escalate into system-wide failures. Regular Maintenance and Testing: Regular maintenance and testing of the payment processing systems can help identify and address technical issues before they cause service disruptions or impact the customer experience.
Third-Party Risks	Digital payment services often rely on third-party vendors for technology and infrastructure support, which can introduce additional risks such as supply chain disruptions.	Vendor Due Diligence: Conducting thorough due diligence on potential vendors before engaging their services can help identify and mitigate supply chain risks. Due diligence can include background checks, financial assessments, and security audits. Contractual Agreements: Establishing clear contractual agreements with vendors that include specific performance standards and protocols for supply chain disruptions can help ensure that the vendor meets the bank's requirements and minimizes the risk of supply chain disruptions. Risk Monitoring: Implementing risk monitoring and management procedures can help the bank identify supply chain disruptions early and take appropriate action.

Digital Strategy and Innovation: key risks and controls

This department is in charge of creating the bank's digital strategy and seeking out chances for new and improved digital solutions.

Risk	What can go wrong	Best-practice controls
Competitive Risks	Digital banking is a highly competitive field, and failure to keep pace with competitors can lead to loss of market share and revenue.	Continuous Market Research and Analysis: Conducting continuous market research and analysis to stay abreast of industry trends and customer preferences is the most effective control to mitigate the risk. This can be achieved through regular surveys, customer feedback mechanisms, and analysis of competitor strategies. Innovation: Continuously innovating to improve the bank's digital offerings can help it stay ahead of the competition. This can be achieved through initiatives such as developing new products, leveraging emerging technologies, and improving customer experience.
Operational Risks	Digital initiatives can be complex and involve multiple stakeholders, making it challenging to ensure seamless integration and efficient execution.	Robust Project Management Practices: Implementing effective project management practices is crucial for managing complex digital initiatives. This includes establishing clear project objectives, defining roles and responsibilities, creating a comprehensive project plan, and monitoring progress against milestones. A project manager should be assigned to oversee the entire initiative, ensuring efficient execution and coordination among stakeholders. Stakeholder Engagement and Collaboration: Ensuring active engagement and collaboration with stakeholders is essential for mitigating the challenges of complex digital initiatives. This involves identifying and involving key stakeholders, such as end-users, IT teams, executives, and external partners, from the early stages of the initiative. By fostering open lines of communication, soliciting feedback, and involving stakeholders in decision-making processes, seamless integration and efficient execution can be achieved. Regular meetings, workshops, and collaborative platforms can facilitate effective stakeholder engagement and promote a shared understanding of project goals and expectations.
Regulatory Risks	Digital banking operations are subject to regulatory scrutiny and must comply with laws and regulations governing customer privacy, data protection, and security.	Compliance Framework: Developing a robust compliance framework that includes policies, procedures, and training programs is the most effective control to mitigate regulatory compliance risk. The framework should be designed to ensure compliance with relevant laws and regulations governing digital banking operations. Risk Assessment: Conducting regular risk assessments to identify potential compliance risks and implementing controls to mitigate them is an essential control to manage regulatory compliance risk. Internal Controls: Implementing strong internal controls, such as access controls, segregation of duties, and monitoring of transactions, can help ensure compliance with regulatory requirements.
Technological Risks	Rapidly evolving technologies and changing customer preferences can make it difficult for the bank to stay relevant and maintain its competitive edge.	Continuous Market Research and Analysis: Keeping a close eye on market trends and customer preferences is crucial for a bank to stay relevant. This control involves conducting regular market research, analyzing customer behavior, and monitoring emerging technologies to identify potential shifts in the industry. By staying updated on market dynamics, the bank can proactively adapt its products, services, and strategies to meet changing customer needs. Agile Business and Technology Alignment: Ensuring seamless alignment between the bank's business and technology functions is crucial to maintain a competitive edge in the face of rapidly evolving technologies and changing customer preferences. This control involves fostering close collaboration and communication between business and technology teams. By establishing cross-functional teams and implementing agile methodologies, the bank can facilitate swift adaptation to emerging technologies and customer demands. An aligned approach enables the bank to efficiently leverage technology to drive innovation, streamline processes, and deliver products and services that meet evolving customer expectations.

This register is a starting point for risk identification and benchmarking against international practice. Adapt the risks and controls to your institution's size, products, jurisdiction and regulatory requirements.

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A spreadsheet-ready CSV with every risk and control on this page, plus blank columns for control owner, inherent likelihood and impact, control design, operating effectiveness, residual rating and actions. We confirm your email with a 6-digit code, then email you the download link.

Frequently asked questions

What are the key risks in Digital Banking?

The main risk areas covered are Digital Channels, Digital Customer Experience, Digital Marketing and Sales, Digital Payments, Digital Strategy and Innovation. Each unit lists its key risks with a short explanation and the best-practice controls that mitigate them.

How do I use this register for a risk and control self-assessment?

Select the risks that apply to your units, map the listed controls to the controls you actually operate, rate inherent risk and control effectiveness, then agree actions for gaps. The free RCSA workbook on this page has the columns ready.

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