Current · Source: Reserve Bank of India · RBI/2025-26/164 · issued 29 Dec 2025 · ~2 min read
Quick answerRBI clarifies that the SFB which last uploaded or updated a customer's KYC records to CKYCR is responsible for verifying identity/address. Other banks downloading and relying on current records need not re-verify identity/address 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 to CKYCR (central KYC registry) is responsible for checking the customer's identity and address.
If another bank downloads those records from CKYCR and they are current and correct, that bank does not have to check identity and address again.
The bank that downloads the records is still responsible for all other parts of customer due diligence (like checking the customer's business or source of money).
How it plays out — a real example
A KYC & compliance officer in Indore at a small finance bank receives a customer who already has KYC records uploaded by another bank to CKYCR. The officer downloads the records, sees they are current, and does not re-verify the customer's identity or address. However, the officer still checks the customer's loan purpose and income source to complete the full customer due diligence process.
What changed
RBI inserted an Explanation in paragraph 66 of the Small Finance Banks KYC Directions, 2025. It specifies that the bank which last uploaded or updated customer KYC records to CKYCR bears responsibility for verifying identity/address. Banks downloading such records are exempt from re-verifying identity/address if records are current and compliant, but retain responsibility for all other CDD procedures.
What it means for you
This amendment reduces duplication of KYC verification for SFBs when they rely on CKYCR records uploaded by another bank. It clarifies liability: the uploading bank owns the verification, while the downloading bank must still ensure overall CDD compliance. This should streamline customer onboarding and reduce operational burden for SFBs using CKYCR.
What you must do
Review your SFB's KYC processes to identify which entity last uploaded customer records to CKYCR.
Ensure your SFB's uploads to CKYCR are accurate and compliant, as you bear verification responsibility.
Update internal policies to reflect that downloading banks need not re-verify identity/address if records are current.
Train staff on the new liability split: uploading bank verifies identity/address; downloading bank handles other CDD aspects.
Who it affects
Small Finance Banks, Compliance teams at SFBs, KYC operations teams, CKYCR system administrators
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 Small Finance Banks?
The amendment specifically modifies the Reserve Bank of India (Small Finance Banks – Know Your Customer) Directions, 2025, so it applies only to Small Finance Banks.
What happens if the CKYCR records are not current or compliant?
If the records downloaded from CKYCR are not current or compliant with the PML Act/Rules, the downloading bank cannot rely on the exemption and must verify identity/address as per standard CDD procedures.
Who is responsible if a downloading bank uses CKYCR records but fails in other CDD aspects?
The downloading bank remains fully responsible for all aspects of CDD procedure and provisions of the Directions, except verification of identity and/or address. So any other CDD failures are its liability.
📜 This document’s life story (1 recorded event, each backed by RBI’s own words)
📜 Read the original circular — full text as issued by RBI
RBI/2025-26/164
DOR.AML.REC.368/14.01.007/2025-26
December 29, 2025
Reserve Bank of India (Small Finance Banks – Know Your Customer) Amendment Directions, 2025
Reserve Bank had issued Reserve Bank of India (Small Finance 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, the Banking Regulation Act (AACS), 1949, read with section 56 of the Act ibid., 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, 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 (Small Finance 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 (Small Finance Banks– Know Your Customer) Directions, 2025 as under:
(1) In paragraph 66, 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/2025-26/164 · issued 29 Dec 2025. The plain-English explanation above is BankPulse’s own independent summary.
Example: if you are a Compliance officer at a bank this circular applies to (Small Finance Banks, Compliance teams at SFBs, KYC operations teams, CKYCR system administrators), your first concrete step on “SFB KYC Amendment: CKYCR Upload Responsibility Clarified” is: “Review your SFB's KYC processes to identify which entity last uploaded customer records to CKYCR.” (RBI issued this 29 Dec 2025).
Action required: Review your SFB's KYC processes to identify which entity last uploaded customer records to CKYCR.
Action required: Ensure your SFB's uploads to CKYCR are accurate and compliant, as you bear verification responsibility.
Action required: Update internal policies to reflect that downloading banks need not re-verify identity/address if records are current.
Action required: Train staff on the new liability split: uploading bank verifies identity/address; downloading bank handles other CDD aspects.
Owner: ____________ Target date: ____________
Board/committee approval needed? Y / N
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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BankPulse Compliance Evidence Pack — generated 03 Aug 2026 · status cross-checked against RBI’s official withdrawal register (refreshed weekly). Official RBI source: https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=13240&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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