FDIC Digital Signage and Non-Deposit Disclosures: Start the 2027 Countdown

The FDIC has finalized updates to its official digital sign and non-deposit signage requirements, with a compliance date of April 1, 2027. While that date may feel distant, banks know how quickly digital projects can become crowded with vendor timelines, testing issues, approval steps, and competing priorities. The final rule applies to FDIC-insured financial institutions and addresses signage requirements for digital deposit-taking channels, ATMs, and similar devices. 

Year-end is a good time for banks to begin turning the rule into an implementation plan. Websites, mobile apps, online account-opening flows, ATM screens, and pages involving non-deposit products may all require review. Starting now can help reduce last-minute remediation and give management time to coordinate compliance, marketing, operations, IT, and vendor teams. 

Map Every Digital Customer Path 

The final rule requires the FDIC official digital sign to appear clearly, continuously, and conspicuously on an institution’s homepage, login page, and the first page or screen where a consumer initiates opening a deposit account. 

Banks should begin by identifying each place a consumer can interact with deposit products digitally. 

• Inventory public websites, mobile apps, online banking portals, and account-opening platforms. 

• Identify all login screens and deposit account-opening entry points. 

• Confirm which channels are controlled internally and which depend on third-party vendors. 

• Document where the official digital sign will need to appear. 

Review Non-Deposit Product Pages 

The final rule narrows non-deposit signage requirements to pages primarily dedicated to advertising or providing information about, or access to, non-deposit products. Required signage must indicate that non-deposit products are not insured by the FDIC, are not deposits, and may lose value. 

This is an area where careful review matters. Non-deposit products may appear on investment, insurance, wealth management, retirement, or referral pages. Banks should also review pages where insured and uninsured products are presented near each other. 

• List all non-deposit product pages and customer entry points. 

• Identify pages that may be “primarily dedicated” to non-deposit products. 

• Review disclosures for clarity, placement, and consistency. 

• Confirm whether one-time customer notifications are needed for third-party non-deposit product access. 

Include ATMs and Similar Devices 

The FDIC also streamlined signage requirements for ATMs and like devices, focusing the official digital sign on the initial screen and non-deposit signage on the initial non-deposit transaction screen. The rule also permits certain ATMs and similar devices to display the physical FDIC official sign instead of the digital sign. 

• Inventory ATMs by model, function, and service date. 

• Determine which machines accept deposits or allow access to non-deposit products. 

• Coordinate early with ATM vendors on screen design and deployment timing. 

• Build testing into the 2026 implementation calendar. 

Start Before the Deadline Feels Close 

The April 1, 2027 compliance date gives banks time to plan, but not time to delay. A year-end review can help management identify affected channels, assign ownership, and build a practical timeline. Brady Martz professionals can help financial institutions think through regulatory readiness, documentation, and board-level reporting as implementation work begins.