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ARC KYC Amendment: CKYCR Uploader Holds Verification Responsibility

Current · Source: Reserve Bank of India · RBI/2025-26/158 · issued 29 Dec 2025 · ~1 min read
Quick answerRBI clarifies that the entity which last uploaded/updated a customer's KYC records to CKYCR is responsible for verifying identity/address. ARCs downloading current records from CKYCR need not re-verify those details, but remain liable for all other CDD aspects.
The rule, in the simplest words
How it plays out — a real example

As a KYC & compliance officer in Indore, Rohan relies on CKYCR records to verify the identity and address of a customer. Since the records are current and compliant, he doesn't need to re-verify them. However, he ensures that the customer's risk profile is up-to-date and that ongoing monitoring is in place to prevent any potential money laundering activities.

What changed

RBI inserted an Explanation in paragraph 59 of the ARC KYC Directions, 2025, effective immediately. It specifies that the regulated entity which last uploaded or updated customer KYC records to CKYCR bears the responsibility for verifying identity/address. ARCs that download and rely on such current records from CKYCR are exempt from re-verifying identity/address, but must still fulfill all other Customer Due Diligence obligations.

What it means for you

For ARCs, this reduces duplication of KYC verification when records are sourced from CKYCR, provided the records are current and compliant. However, ARCs cannot offload overall CDD responsibility—they remain accountable for all other aspects like risk profiling and ongoing monitoring. This aligns with the government's September 2025 office memorandum on CKYCR responsibility.

What you must do

Who it affects

Asset Reconstruction Companies (ARCs), Regulated entities uploading KYC records to CKYCR, Compliance and AML teams at ARCs

❓ Common questions

Does this amendment apply to all ARCs immediately?

Yes, the amendment came into force with immediate effect from the date of issuance, December 29, 2025, and applies to all ARCs covered under the ARC KYC Directions, 2025.

📜 Read the original circular — full text as issued by RBI
RBI/2025-26/158 DOR.AML.REC.362/14.01.010/2025-26 December 29, 2025 Reserve Bank of India (Asset Reconstruction Companies – Know Your Customer) Amendment Directions, 2025 Reserve Bank had issued Reserve Bank of India (Asset Reconstruction Companies – Know Your Customer) Directions, 2025 dated November 28, 2025 (hereinafter referred to as the Directions) in compliance of the provisions of the PML Act, 2002 and the Rules made thereunder. There is a need to amend the Directions to clarify the responsibility of entities uploading customer records to and downloading the same from CKYCR, based on the office memorandum (OM) titled “CKYCR and the ultimate responsibility of REs – reg.” issued by the Department of Revenue, Govt of India, dated September 18, 2025. 2. Accordingly, in exercise of the powers conferred by sections 3, 9, 10, 12 and 12A of the Securitisation and Reconstruction of Financial Assets and Enforcement of Security Interest Act, 2002 (54 of 2002) , sections 45JA, 45K, and 45L of the Reserve Bank of India Act, 1934, section 10(2) read with section 18 of Payment and Settlement Systems Act 2007 (Act 51 of 2007), section 11(1) of the Foreign Exchange Management Act (FEMA), 1999, Rule 9(14) of the Prevention of Money-Laundering (Maintenance of Records) Rules, 2005, and all other enabling laws in this regard, the Reserve Bank being satisfied that it is necessary and expedient in the public interest so to do, hereby issues the Amendment Directions hereinafter specified. 3. Short Title and Commencement (1) These Directions shall be called the Reserve Bank of India (Asset Reconstruction Companies – Know Your Customer) Amendment Directions, 2025. (2) These Directions shall come into force with immediate effect. 4. These Amendment Directions modify the Reserve Bank of India (Asset Reconstruction Companies – Know Your Customer) Directions, 2025 as under: (1) In paragraph 59, the following “Explanation” is being inserted after sub-paragraph (10): “ Explanation: The RE that has last uploaded or updated the customer’s KYC records in the CKYCR shall be responsible for verifying the identity and / or address of the customer, as applicable. Accordingly, any ARC downloading and relying on such records from the CKCYR shall not be required to re-verify the authenticity of the customer’s identity and / or address, provided the KYC records downloaded from CKYCR are current and compliant with the PML Act, 2002 / PML Rules, 2005. The ARC downloading and relying on KYC records downloaded from the CKCYR shall remain responsible for all aspects of CDD procedure and provisions of these Directions, except verification of identity and / or address of the customer.” (Veena Srivastava) Chief General Manager
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2025-26/158 · issued 29 Dec 2025. The plain-English explanation above is BankPulse’s own independent summary.
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Who does what — compliance checklist
💻 IT / Systems
  • Ensure your systems check the 'last uploaded/updated by' field in CKYCR to confirm the uploading entity's responsibility.
📜 Compliance
  • Update internal KYC policies to reflect that ARCs relying on CKYCR records need not re-verify identity/address if records are current and PML-compliant.
  • Maintain documentation of downloaded CKYCR records and their currency to demonstrate compliance during audits.
  • Train CDD teams that overall CDD responsibility (except identity/address verification) remains with the ARC.
Grouped from the action items above — a single circular may involve more than one team.
Worked example & action-note template

Example: if you are a Compliance officer at a bank this circular applies to (Asset Reconstruction Companies (ARCs), Regulated entities uploading KYC records to CKYCR, Compliance and AML teams at ARCs), your first concrete step on “ARC KYC Amendment: CKYCR Uploader Holds Verification Responsibility” is: “Update internal KYC policies to reflect that ARCs relying on CKYCR records need not re-verify identity/address if records are current and PML-compliant.” (RBI issued this 29 Dec 2025).

  1. Circular: RBI/2025-26/158 -- ARC KYC Amendment: CKYCR Uploader Holds Verification Responsibility
  2. Issued: 29 Dec 2025
  3. Action required: Update internal KYC policies to reflect that ARCs relying on CKYCR records need not re-verify identity/address if records are current and PML-compliant.
  4. Action required: Ensure your systems check the 'last uploaded/updated by' field in CKYCR to confirm the uploading entity's responsibility.
  5. Action required: Maintain documentation of downloaded CKYCR records and their currency to demonstrate compliance during audits.
  6. Action required: Train CDD teams that overall CDD responsibility (except identity/address verification) remains with the ARC.
  7. Owner: ____________ Target date: ____________
  8. Board/committee approval needed? Y / N
  9. Evidence filed in compliance register on: ____________
Built only from this circular’s own published fields — not legal advice; always confirm against the official RBI source.

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Official RBI source: https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=13234&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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