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.
What you must do
- Prepare to upload KYC data for all new legal entity accounts from April 1, 2021, using the CERSAI-released LE template.
- Upload KYC records for existing LE accounts during periodic updation or earlier if updated KYC is obtained.
- Ensure all individual accounts opened before January 1, 2017, are uploaded to CKYCR during periodic updation.
- Migrate customer KYC details to current CDD standards during periodic updation.
- Communicate the KYC Identifier to customers once generated by CKYCR.
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
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.