The proposal would refine the signage rules that require the FDIC logo on digital deposit-taking and other channels and label non-deposit products, like cryptocurrency, as uninsured
On August 21, 2025, the Federal Deposit Insurance Corporation (FDIC) published a proposed rule with several key changes to its FDIC Official Sign and Advertising Rule, only two years after it adopted requirements that were originally scheduled to take effect earlier this year (that were delayed due to concerns regarding implementation and consumer confusion). The new proposed rule aims to add flexibility to the requirements under 12 CFR Part 328 by eliminating specific formatting requirements for the FDIC official digital sign, and instead focusing display requirements on the screens and pages where signage would be most relevant for consumers, with the compliance date postponed to January 1, 2027.
Comments on the proposed rule are due by October 20, 2025.
Key Takeaways
- Compliance with the FDIC Official Sign and Advertising Rule is important for banks, their partners, and service providers. As described in our previous post, the FDIC has broad enforcement authority over banks and nonbanks for misuse of the FDIC name or logo and misrepresentations about FDIC deposit insurance.
- The proposal would likely reduce compliance burdens and better reflect modern banking and customer preferences. The proposed amendments reflect a recognition by the FDIC that most banking activities today are conducted online and that design and display requirements that work for desktop computers might not work for smaller devices, such as phones, and wearable technology, like smart watches. The proposal would also focus on display requirements for the FDIC official digital sign and the non-deposit signage on screens and pages that provide disclosures to consumers at the most appropriate place and time.
- As we noted back in March, when the FDIC delayed the compliance date for the 2023 final rule on FDIC signage and advertising FDIC deposit insurance, the 2023 final rule demonstrated that the FDIC has not been a leader on modern, tech-forward approaches to financial services. The proposal here represents a new way of thinking for the FDIC that better appreciates the use of new technologies by the financial services industry and federal agencies.
- The proposed rule lists a number of questions for comment. Tech-forward banks and service providers should consider responding to help the FDIC understand where trends may be going. While the FDIC has attempted to modernize and simplify the signage rules, it is remarkable how anchored it remains to past practices and paradigms. For instance, the proposed rule does not grapple with whether more streamlined, modern, signs/logos and disclosures could be useful or more effective. Considering other countries' approaches could be helpful (for instance, Canada and the United Kingdom). In addition, comments about what and how users read or process information displayed on digital devices, how they react to notifications that are essentially pop-ups, whether static symbols are universally beneficial versus interactive or dynamic alternatives—lots of ample ground to cover—would likely help the FDIC move forward.
Below is a summary of key changes for banks, which may also be important for their partners and service providers, as well as new entrants to the market.
Design Requirements for the FDIC Official Digital Sign
Citing questions about the design of the FDIC official digital sign and requests for flexibility in color codes and font sizes, the FDIC proposes to eliminate the specific hexadecimal color code, pixel size, and font size requirements for the FDIC official digital sign. Instead, banks would be required to display the FDIC official digital sign in a clear and conspicuous manner, using either a combination of navy blue and black text or all-white text and Source Sans Pro Web or a similar font. In addition, the proposal would expressly permit banks to "wrap" the text of the FDIC official digital sign to address space constraints. These changes reflect real questions and concerns industry raised when attempting to prepare for implementation of the current rule.
Signage for Digital Deposit-Taking Channels
The proposal would scale back some of the signage requirements on digital deposit-taking channels, reflecting questions and concerns raised with implementing these requirements.
- The FDIC would remove the requirement to display the FDIC official digital sign on so-called "landing pages" (possibly unclear to some, or overbroad for others) while retaining the requirement to display the FDIC official digital sign on the "login page" (a more precise term) of the institution's deposit-taking channel.
- The proposal would more precisely require banks to display the FDIC official digital sign on the institution's digital deposit-taking channels' page or screen where the customer initiates opening a deposit account, instead of requiring the institution to display the FDIC official digital sign on (all) "pages where the customer may transact with deposits."
- The proposal would narrow the non-deposit signage requirement to require the display of non-deposit signage only on pages and screens that are primarily dedicated to one or more non-deposit products, such as a page or screen that provides substantive information on one or more non-deposit products or where a consumer could purchase a non-deposit product.
- The FDIC would provide a non-exhaustive list of examples on various placements of the FDIC official digital sign and non-deposit signage that would meet the requirement that banks "clearly, continuously, and conspicuously" display such signage.
- The proposal would permit banks to satisfy the current requirement to provide a one-time notification when a customer attempts to access non-deposit products from a non-bank third party platform with a notification that must be either dismissed by an act of the customer or dismissed automatically after a minimum of three seconds, to allow the customer a reasonable opportunity to read the notification's content.
Signage for ATMs and Similar Devices
The proposal would simplify compliance for banks with signage requirements for ATMs and like devices.
- The proposal would narrow the display requirement for the digital sign and non-deposit signage to the initial screen and initial non-deposit transaction screen, respectively. An ATM's "initial screen" (or "welcome screen") is the screen displayed before a customer inserts a debit card or other credentials to access the device.
- The proposal would expand the current limited exception for certain ATMs and like devices to display either the FDIC official digital sign or the physical FDIC official sign to include (1) all ATMs and like devices placed into service prior to January 1, 2027, and (2) all ATMs and like devices, regardless of when placed into service, that do not allow customers to transact with non-deposit products.
- The proposal would clarify that the non-deposit signage requirements only apply to ATMs or like devices that receive deposits and permit customers to transact with one or more non-deposit products, and a financial institution is only required to display the non-deposit signage on pages and screens viewed by its own customers.
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