What changed
RBI amended its November 2025 KYC Directions for All India Financial Institutions to insert an Explanation in paragraph 62. This Explanation specifies that the entity which last uploaded or updated customer KYC records to CKYCR bears the responsibility for verifying identity/address. AIFIs downloading and relying on such current records are exempt from re-verifying identity/address, but must still fulfill all other CDD requirements.
What it means for you
This amendment reduces duplication of KYC verification for AIFIs that use CKYCR, saving time and costs. However, the downloading AIFI remains fully accountable for the entire CDD process except identity/address verification, so due diligence on record currency and compliance is critical. It aligns with the government's September 2025 office memorandum on ultimate responsibility of regulated entities.
What you must do
- Identify which AIFI last uploaded/updated each customer's KYC records in CKYCR before relying on them.
- Ensure downloaded KYC records are current and compliant with PML Act/Rules before accepting them.
- Maintain robust internal controls to verify record currency and completeness, as CDD responsibility remains with you.
- Update your KYC policy and procedures to reflect this clarification and train staff accordingly.
Who it affects
All India Financial Institutions (AIFIs) covered under RBI's KYC Directions, Compliance and KYC operations teams at AIFIs, Customers whose KYC records are shared via CKYCR
Does this mean we never need to verify customer identity if we download from CKYCR?
No. You are exempt from re-verifying identity/address only if the records were last uploaded/updated by another AIFI and are current and compliant. You still must perform all other CDD steps and remain responsible for the overall CDD procedure.
What if the CKYCR record is outdated or non-compliant?
You cannot rely on such records. You must either obtain fresh KYC from the customer or ensure the uploading AIFI updates the record. Your responsibility for CDD means you must verify record currency and compliance before use.
Who is the 'last uploading or updating' AIFI?
It is the AIFI that most recently uploaded or updated the customer's KYC records in CKYCR. That entity bears the primary responsibility for verifying identity/address. You should check CKYCR metadata to identify this entity.