Current · Source: Reserve Bank of India · RBI/2025-26/165 · issued 29 Dec 2025 · ~2 min read
Quick answerRBI clarifies that the Urban Co-operative Bank which last uploaded or updated a customer's KYC records to CKYCR is solely responsible for verifying identity/address. Downloading banks can rely on those records without re-verifying, but remain liable for all other CDD aspects.
The rule, in the simplest words
The bank that last put or updated a customer's KYC (know your customer, like checking ID and address) records into CKYCR (a central database) must check that the customer's identity and address are correct.
If another bank takes those records from CKYCR, it does not have to check the identity and address again, as long as the records are up-to-date and follow the rules.
The bank that takes the records is still responsible for all other checks (like understanding the customer's business and risk), just not the identity and address part.
How it plays out — a real example
Priya, a compliance officer at a small urban co-operative bank in Pune, downloads a customer's KYC records from CKYCR. She knows her bank does not need to re-check the customer's identity or address because the uploading bank already did that. But she still carefully reviews the customer's transaction patterns and risk profile, because her bank remains responsible for those other checks.
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
❓ Common questions
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.
📜 Read the original circular — full text as issued by RBI
RBI/2025-26/165
DOR.AML.REC.369/14.01.006/2025-26
December 29, 2025
Reserve Bank of India (Urban Co-operative Banks – Know Your Customer) Amendment Directions, 2025
Reserve Bank had issued Reserve Bank of India (Urban Co-operative Bank – 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 (Urban Co-operative Bank – 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 (Urban Co-operative Bank – Know Your Customer) Directions, 2025 as under:
(1) In paragraph 64, 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/2025-26/165 · 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 (Urban Co-operative Banks, KYC/CDD operations teams, Compliance officers at UCBs), your first concrete step on “UCB KYC Amendment: CKYCR Uploader Bears Verification Responsibility” is: “Update internal KYC policies to reflect that the uploading bank bears identity/address verification responsibility.” (RBI issued this 29 Dec 2025).
Action required: Update internal KYC policies to reflect that the uploading bank bears identity/address verification responsibility.
Action required: Train CDD staff to verify that downloaded CKYCR records are current and PML-compliant before relying on them.
Action required: Ensure your bank's CKYCR uploads are accurate and timely, as you become liable for verification of those records.
Action required: Review existing KYC outsourcing agreements to align with this clarification on responsibility allocation.
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.
💬 Banker Discussion
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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=13241&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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