HomeCirculars › RBI/2020-21/80

CKYCR Extended to Legal Entities from April 2021

No longer current — withdrawn, no replacement on file yet
Source: Reserve Bank of India · RBI/2020-21/80 · issued 18 Dec 2020 · ~2 min read
Quick answerRBI mandates all regulated entities to upload KYC data of legal entity accounts opened from April 1, 2021, onto the Central KYC Registry. Existing individual accounts opened before 2017 must also be uploaded during periodic updation. KYC Identifier usage is streamlined to reduce duplication.

What changed

The CKYCR, previously limited to individual accounts opened after January 1, 2017, is now extended to legal entities. Regulated entities must upload KYC data for all new LE accounts from April 1, 2021, and for existing LE accounts during periodic updation. Additionally, all individual accounts opened before January 1, 2017, must be incrementally uploaded to CKYCR during periodic updation. The circular also clarifies that customers submitting a KYC Identifier with consent need not resubmit KYC records unless specific conditions apply.

What it means for you

Banks and lenders must update their systems to handle the new LE template and ensure timely uploads to CKYCR. This reduces duplication of KYC efforts for legal entities and enhances the central registry's utility. The incremental upload of legacy individual accounts will improve data completeness. Compliance with periodic updation timelines becomes critical to avoid regulatory gaps.

Historical instruction — do not use for current compliance. This is what was required at the time; it no longer reflects current RBI requirements. If no replacement rule is linked above, that only means none is recorded on our register yet — it does not prove no later applicable rule exists. Confirm on the official RBI source below.

What banks were required to do at the time

Who it affects

All regulated entities (banks, NBFCs, etc.), Legal entity customers opening accounts from April 2021, Individual customers with accounts opened before January 1, 2017

❓ Common questions

Regulatory timeline

Built from our lineage records — each fact carries its provenance; missing history simply is not shown (never guessed).

What is the deadline for uploading KYC data of legal entities?

For accounts opened on or after April 1, 2021, upload must happen at account opening. For existing LE accounts, upload during periodic updation or earlier if updated KYC is received.

Can a customer avoid submitting KYC documents again if they have a KYC Identifier?

Yes, if the customer provides explicit consent to download records from CKYCR using the KYC Identifier, they need not resubmit the same KYC records unless there is a change in information, address verification is needed, or the regulated entity requires enhanced due diligence.

What about individual accounts opened before January 1, 2017?

Their KYC data must be uploaded to CKYCR during periodic updation or earlier if updated KYC is obtained, and details must be migrated to current CDD standards.

📜 This document’s life story (1 recorded event, each backed by RBI’s own words)
Repealed by RBI/2025-26/100 — Consolidation of Regulations — Withdrawal of circulars (28 Nov 2025)
RBI’s words: “Official withdrawal register entry #331: DOR.AML.BC.No.31/14.01.001/2020-21 — "Amendment to Master Direction (MD) on KYC - Centralized KYC Registry - Roll out of Legal Entity Template & other Changes"”
📜 Read the original circular — full text as issued by RBI
RBI/2020-21/80 DOR.AML.BC.No.31/14.01.001/2020-21 December 18, 2020 The Chairpersons/ CEOs of all the Regulated Entities Dear Sir/Madam, Amendment to Master Direction (MD) on KYC – Centralized KYC Registry – Roll out of Legal Entity Template & other changes Regulated Entities (REs) have been uploading the KYC data pertaining to all individual accounts opened on or after January 1, 2017 on to CKYCR in terms of the provisions of the Prevention of Money Laundering (Maintenance of Records) Rules, 2005. Changes to the template, as and when required are released by CERSAI after consulting the Reserve Bank. 2. As the CKYCR is now fully operational for individual customers, it has been decided to extend the CKYCR to Legal Entities (LEs). Accordingly, REs shall upload the KYC data pertaining to accounts of LEs opened on or after April 1, 2021, on to CKYCR in terms of Rule 9 (1A) of the PML Rules. The LE Template and the Annex thereof are attached as Annex “A” and Annex “B” respectively to this circular. The LE Template would be released by CERSAI well in advance so that REs start using it from the notified date. REs shall also ensure that in case of accounts of LEs opened prior to April 1, 2021, the KYC records are uploaded on to CKYCR during the process of periodic updation as specified in Section 38 of the Master Direction, or earlier when the updated KYC information is obtained/received from the customer in certain cases. REs shall ensure that during periodic updation, the customers’ KYC details are migrated to current Customer Due Diligence (CDD) standards. 3. In order to ensure that all existing KYC records of individual customers are incrementally uploaded on to CKYCR, REs shall upload the KYC data pertaining to accounts of individuals opened prior to January 01, 2017, at the time of periodic updation as specified in Section 38 of the Master Direction, or earlier when the updated KYC information is obtained/received from the customer in certain cases. REs shall ensure that during periodic updation, the customers’ KYC details are migrated to current CDD standard. 4. Where a customer, for the purpose of establishing an account based relationship, submits a KYC Identifier to a RE, with an explicit consent to download records from CKYCR, then such RE shall retrieve the KYC records online from CKYCR using the KYC Identifier and the customer shall not be required to submit the same KYC records or information or any other additional identification documents or details, unless – there is a change in the information of the customer as existing in the records of CKYCR; the current address of the customer is required to be verified; the RE considers it necessary in order to verify the identity or address of the customer, or to perform enhanced due diligence or to build an appropriate risk profile of the client. 5. Once KYC Identifier is generated by CKYCR, the REs shall ensure that the same is communicated to the individual/legal entity as the case may be. 6. The Master Direction on KYC dated February 25, 2016 , is hereby updated to reflect the changes effected by the above amendment and shall come into force with immediate effect. Yours faithfully, (Thomas Mathew) Chief General Manager Encl: As above
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2020-21/80 · issued 18 Dec 2020. The plain-English explanation above is BankPulse’s own independent summary.
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Official RBI source: https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=12008&Mode=0 — Plain-English summary by BankPulse (bankpulse.ai), reviewed by our expert reviewer, CA Amit Jain. Independent platform, not affiliated with the Reserve Bank of India; is our own plain-English paraphrase, not RBI’s original wording.
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