By: Heather Campbell, Pinion Financial Institutions Advisor

Financial institutions now have more time to prepare for the Federal Deposit Insurance Corporation’s (FDIC) revised signage requirements, but the extended timeline should not put compliance planning on the back burner. With the new compliance date set for April 1, 2027, banks should use this window to review digital deposit-taking channels, ATM screens, and non-deposit product disclosures to confirm signage is clear, consistent, and aligned with the final rule. Starting now can help avoid last-minute implementation challenges and ensure a smoother transition.

For background on the original requirements, see our prior article, “Stay Ahead in 2025: Compliance Updates Every Financial Institution Should Know About”.

Following are changes per the Federal Register dated January 29, 2026: https://www.fdic.gov/board/federal-register-notice-part-328-fdic-sign-and-ad.pdf

What Changed for Digital Channels

FDIC Official Digital Sign Design Requirements [12 CFR 328.5(b)]

  • The text of the official digital sign must be navy blue or black and use the font Source Sans Pro Web or similar, but does not mandate specific color codes. This should provide flexibility due to technical limitations.
  • The FDIC will continue to provide a standardized, but optional, digital sign via FDICconnect.

Display of FDIC Official Digital Sign and Other Signage Requirements for Insured Depository Institutions’ (IDIs) Digital Deposit-Taking Channels

FDIC Official Digital Sign Requirements for Digital Deposit-Taking Channels [12 CFR 328.5(d)]

  • Banks must display the FDIC’s official digital sign on the:
    • Homepage or initial page of the website or application
    • Login page
    • Page or screen where the consumer first initiates the process of opening a deposit account
  • The rule does not prohibit the inclusion of uninsured products on digital pages bearing the FDIC official digital sign

Static Non-Deposit Signage Requirements for Digital Deposit-Taking Channels [12 CFR 328.5(g)(1)]

The following requirements apply to digital deposit-taking channels that offer customers the ability to make deposits electronically, provide customers with access to deposits, and advertise, provide information about, or access to non-deposit products.

  • IDIs must clearly, continuously, and conspicuously display non-deposit signage on any page that is primarily dedicated to advertising or providing information about, or access to, non-deposit products.
    • The required disclosure must clearly state that non-deposit products:
      • Are not FDIC insured
      • Are not deposits
      • May lose value
    • Pages covered by this standard where the primary focus of the content is marketing or providing information about non-deposit products, include examples like ‘‘Investing’’ or ‘‘Wealth Management’’

 Examples of Clear, Continuous, and Conspicuous Display [12 CFR 328.5(e)]

  • Signage at the bottom of a webpage in small print would not be considered as clearly, continuously, and conspicuously displayed. The text should be in larger or bold font compared to the smallest text on the page. It must be larger than the footnotes.

One-Time Notification for Bank Customers Related to Third-Party Non-Deposit Products [12 CFR 328.5(g)(2)]

  • The notification requirement applies only when a customer leaves the IDI’s digital deposit-taking channel.
  • The timeframe for the notification is for a minimum of three seconds or until the customer dismisses the notification manually.

Additional Disclosures Permitted [12 CFR 328.5(f)]

  • Signage requirements for digital deposit-taking channels do not limit the ability to display signage and disclosures in addition to those required.

What Changed for ATM Signage

Signage Requirements for ATMs and Like Devices

FDIC Official Digital Sign Requirements for ATMs and Like Devices [12 CFR 328.4(c)]

Under the revised rule, the FDIC official digital sign must appear on the ATM’s initial screen. The sign is no longer required on each deposit transaction screen throughout the transaction process.

Limited Exception for Certain ATMs and Like Devices to Display Physical FDIC Official Sign [12 CFR 328.4]

A limited exception was created to allow certain ATMs to continue displaying the physical FDIC sign if the ATM or like device was placed into service prior to April 1, 2027.

Degraded or Defaced Physical FDIC Official Signs [12 CFR 328.4(f)]

This section was removed because institutions are already required to display signage clearly and conspicuously. A degraded or defaced sign that cannot be readily understood by consumers would not satisfy the standard.

Non-Deposit Signage Proposed Rule [12 CFR 328.4(d)]

The final rule requires IDIs to display non-deposit signage on its ATMs and like devices only for its own customers, not to all users of the device.

  • Non-deposit signage must appear only on the initial transaction page or initial transaction screen for a non-deposit product.
    • The ‘‘initial transaction page or screen’’ includes the first screen displayed upon initiating a transaction with a non-deposit product.

 Additional Disclosures Permitted [12 CFR 328.4(e)]

Nothing in 12 CFR 328.4, which covers ATMs and like devices, limits an IDI’s ability to include additional disclosures beyond what is required by 12 CFR part 328.

What Financial Institutions Should Do Now

The final rule significantly simplifies the digital signage requirements adopted in 2023 by reducing the number of webpages and ATM screens that must display FDIC signage.

To get ready for the April 1, 2027 compliance date, banks should consider taking the following steps:

  • Identify all of your digital deposit-taking channels, including online banking, mobile banking, and digital account opening platforms.
  • Review those channels and determine where the FDIC official digital sign will be required. Document any areas that are not currently compliant so changes can be planned.
  • Evaluate whether any non-deposit products are advertised or accessible through those channels and confirm the required non-deposit disclosures are displayed where appropriate.
  • Review links that direct customers away from your website or digital banking platform to determine whether the required one-time notification will be needed and, if so, whether it is already in place.
  • If updates are needed, reach out to your vendors early to understand implementation requirements and timelines.
  • Review ATM and kiosk screens to determine whether any signage updates will be necessary.
  • Update policies, procedures, and training materials, as applicable, to reflect the revised requirements.
  • Consider performing a final review or testing of your digital channels before the compliance date to verify signage and disclosures are functioning as intended.

Need Help Preparing?

Contact a Pinion advisor if you have questions or would like assistance evaluating your institution’s compliance with the revised requirements.