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Payments Banks KYC Amendment: CKYCR Responsibility Clarified

Current · Source: Reserve Bank of India · RBI/2025-26/161 · issued 29 Dec 2025 · ~2 min read

Quick answerRBI clarifies that the payments bank which last uploaded or updated a customer's KYC records in CKYCR is responsible for verifying identity/address. Other banks downloading those records need not re-verify, but remain liable for all other CDD aspects.

The rule, in the simplest words

The bank that last uploaded or updated a customer's KYC (know your customer) records in CKYCR (central KYC registry) is the one who must check the customer's identity and address.
If another bank downloads those records from CKYCR and they are current and follow the rules, that bank does not have to check identity and address again.
The bank that downloads the records still must do all other customer checks (like understanding the customer's business and source of money).
Banks must make sure the records they download are up-to-date and follow the law before using them.

How it plays out — a real example

A KYC & compliance officer in Indore downloads a customer's KYC records from CKYCR that were last updated by a payments bank. The officer does not need to re-check the customer's identity or address, but she still verifies the customer's income source and purpose of the loan, and keeps a record of her reliance on the CKYCR data.

What changed

RBI inserted an Explanation in paragraph 65 of the Payments Banks KYC Directions, 2025. It specifies that the entity which last uploaded or updated KYC records in CKYCR bears the responsibility for verifying the customer's identity and/or address. Banks downloading and relying on such current and compliant records are exempt from re-verifying identity/address, but must still handle all other CDD procedures.

What it means for you

This amendment reduces duplication of KYC verification for payments banks when they rely on CKYCR records, lowering operational costs and onboarding time. However, the downloading bank retains full responsibility for all other CDD aspects, so due diligence on record currency and compliance is critical. It aligns with the government's September 2025 office memorandum on CKYCR responsibility.

What you must do

Update internal KYC policies to reflect that the last updater in CKYCR is responsible for identity/address verification.
Ensure your bank's CKYCR uploads are accurate and timely to avoid liability for downstream users.
When downloading KYC records from CKYCR, verify that records are current and PML Act/Rules compliant before relying on them.
Document the reliance on CKYCR records and maintain audit trails for all CDD steps except identity/address verification.

Who it affects

Payments banks, Other banks using CKYCR for customer KYC, Compliance and AML teams, CKYCR system administrators

❓ Common questions

Regulatory timeline

Decoded by BankPulse 2026-06-17 18:22 IST
Amends — RBI Payments Banks Directions Amendment

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

Does this amendment apply to all banks or only payments banks?

The amendment is specifically to the Payments Banks KYC Directions, 2025, so it directly applies to payments banks. However, the principle may influence broader KYC practices for other regulated entities.

What happens if the CKYCR records are not current or compliant?

The downloading bank must not rely on such records for exemption from re-verification. It remains responsible for all CDD procedures, including identity/address verification, if records are outdated or non-compliant.

Who is liable if a customer's identity is later found to be fraudulent?

The bank that last uploaded or updated the KYC records in CKYCR is responsible for verifying identity/address. The downloading bank is not required to re-verify, but must ensure records are current and compliant.

📜 This document’s life story (1 recorded event, each backed by RBI’s own words)

Amends RBI Payments Banks Directions Amendment

📜 Read the original circular — full text as issued by RBI

RBI/2025-26/161
 DOR.AML.REC.365/14.01.009/2025-26
 December 29, 2025
 Reserve Bank of India (Payments Banks – Know Your Customer) Amendment Directions, 2025 
 Reserve Bank had issued Reserve Bank of India (Payments Banks – 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 35A of the Banking Regulation Act, 1949, 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 (Payments Banks – 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 (Payments Banks – Know Your Customer) Directions, 2025 as under:
 (1) In paragraph 65, 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 bank 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 bank 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/2025-26/161 · issued 29 Dec 2025. The plain-English explanation above is BankPulse’s own independent summary.

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Worked example & action-note template

Example: if you are a Compliance officer at a bank this circular applies to (Payments banks, Other banks using CKYCR for customer KYC, Compliance and AML teams, CKYCR system administrators), your first concrete step on “Payments Banks KYC Amendment: CKYCR Responsibility Clarified” is: “Update internal KYC policies to reflect that the last updater in CKYCR is responsible for identity/address verification.” (RBI issued this 29 Dec 2025).

Circular: RBI/2025-26/161 -- Payments Banks KYC Amendment: CKYCR Responsibility Clarified
Issued: 29 Dec 2025
Action required: Update internal KYC policies to reflect that the last updater in CKYCR is responsible for identity/address verification.
Action required: Ensure your bank's CKYCR uploads are accurate and timely to avoid liability for downstream users.
Action required: When downloading KYC records from CKYCR, verify that records are current and PML Act/Rules compliant before relying on them.
Action required: Document the reliance on CKYCR records and maintain audit trails for all CDD steps except identity/address verification.
Owner: ____________ Target date: ____________
Board/committee approval needed? Y / N
Evidence filed in compliance register on: ____________

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Official RBI source: https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=13237&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.