What changed
RBI inserted a new Explanation in paragraph 64 of the UCB KYC Directions, 2025, effective immediately. It specifies that the bank which last uploaded or updated KYC records to CKYCR must verify the customer's identity/address. Any other bank downloading those records from CKYCR is not required to re-verify identity/address, provided the records are current and compliant with PML Act/Rules.
What it means for you
This amendment reduces duplication of KYC verification for Urban Co-operative Banks that rely on CKYCR records, cutting operational costs and turnaround time. However, the downloading bank remains fully responsible for all other Customer Due Diligence (CDD) procedures under the Directions. Banks must ensure they only rely on current, compliant records from CKYCR to avoid compliance gaps.
What you must do
- Update internal KYC policies to reflect that the uploading bank bears identity/address verification responsibility.
- Train CDD staff to verify that downloaded CKYCR records are current and PML-compliant before relying on them.
- Ensure your bank's CKYCR uploads are accurate and timely, as you become liable for verification of those records.
- Review existing KYC outsourcing agreements to align with this clarification on responsibility allocation.
Who it affects
Urban Co-operative Banks, KYC/CDD operations teams, Compliance officers at UCBs
Does this mean my bank can skip identity verification if we download KYC from CKYCR?
Yes, for identity and address verification only, provided the downloaded records are current and compliant with PML Act/Rules. Your bank still must perform all other CDD steps and remains responsible for the overall KYC process.
Who is liable if a downloaded KYC record turns out to be incorrect?
The bank that last uploaded or updated that record to CKYCR is responsible for verifying the identity/address. The downloading bank is not liable for that specific verification, but must ensure the record is current and compliant before relying on it.
When does this amendment take effect?
It is effective immediately from December 29, 2025, the date of the circular.