Current · Source: Reserve Bank of India · RBI/2025-26/166 · issued 29 Dec 2025 · ~2 min read
Quick answerRBI clarifies that the RE which last uploaded/updated a customer's KYC records in CKYCR is responsible for verifying identity/address. Banks downloading current compliant records from CKYCR need not re-verify identity/address but remain liable for all other CDD aspects.
The rule, in the simplest words
The bank that last added 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 your bank downloads a customer's KYC records from CKYCR and those records are current and follow the rules, you do NOT have to re-check the customer's identity and address.
But your bank is still fully responsible for all other customer checks (like understanding why the customer wants the account, checking for suspicious activity, etc.).
Before using downloaded KYC records, your bank must make sure they are up-to-date and follow the PML Act (anti-money laundering law) and its rules.
How it plays out — a real example
Priya, a KYC & compliance officer in Indore, is onboarding a new customer who already has KYC records in CKYCR uploaded by another bank last month. She downloads those records, confirms they are current and compliant, and does not re-verify the customer's identity or address. However, she still completes all other due diligence steps, like asking about the source of the gold and documenting the loan purpose, because her bank remains responsible for those checks.
What changed
RBI inserted an Explanation in paragraph 65 of the KYC Directions, 2025, based on a September 2025 Department of Revenue office memorandum. It specifies that the regulated entity which last uploaded or updated customer KYC records in CKYCR bears responsibility for verifying identity and address. Banks downloading and relying on such current, compliant records are exempt from re-verifying identity/address but retain full responsibility for all other customer due diligence procedures.
What it means for you
This amendment reduces duplication of KYC verification for banks that use CKYCR records, lowering operational costs and turnaround time for onboarding. However, the downloading bank must ensure the records are current and compliant with PML Act/Rules, and remains accountable for all other CDD steps. Banks should update their internal processes to clearly document reliance on CKYCR records and verify their currency and compliance status.
What you must do
Update internal KYC policies to reflect that the last uploading RE is responsible for identity/address verification.
Ensure your bank's systems check that downloaded CKYCR records are current and compliant before relying on them.
Document reliance on CKYCR records in customer files to demonstrate compliance with the new Explanation.
Train CDD staff on the revised responsibility split: no re-verification needed for identity/address, but all other CDD obligations remain.
Who it affects
All commercial banks, KYC operations teams, Compliance and AML departments, Customer onboarding teams
❓ Common questions
Does this mean we never have to verify identity again if we use CKYCR records?
No. You can skip re-verifying identity and address only if the records you download from CKYCR are current and compliant with PML Act/Rules. You remain fully responsible for all other CDD procedures under the Directions.
Who is liable if a CKYCR record turns out to be incorrect?
The RE that last uploaded or updated the customer's KYC records in CKYCR is responsible for verifying identity and address. The downloading bank is not required to re-verify those aspects but must ensure the records are current and compliant.
📜 Read the original circular — full text as issued by RBI
RBI/2025-26/166
DOR.AML.REC.370/14.01.002/2025-26
December 29, 2025
Reserve Bank of India (Commercial Banks – Know Your Customer) Amendment Directions, 2025
Reserve Bank had issued Reserve Bank of India (Commercial 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 section 35A of the Banking Regulation Act, 1949, section 10(2) read with section 18 of Payment and Settlement Systems Act, 2007, section 11(1) of the Foreign Exchange Management Act, 1999, Rule 9(14) of 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 (Commercial 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 (Commercial 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/2025-26/166 · issued 29 Dec 2025. The plain-English explanation above is BankPulse’s own independent summary.
Ensure your bank's systems check that downloaded CKYCR records are current and compliant before relying on them.
📜 Compliance
Update internal KYC policies to reflect that the last uploading RE is responsible for identity/address verification.
Document reliance on CKYCR records in customer files to demonstrate compliance with the new Explanation.
Train CDD staff on the revised responsibility split: no re-verification needed for identity/address, but all other CDD obligations remain.
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 (All commercial banks, KYC operations teams, Compliance and AML departments, Customer onboarding teams), your first concrete step on “CKYCR KYC Upload Responsibility Clarified” is: “Update internal KYC policies to reflect that the last uploading RE is responsible for identity/address verification.” (RBI issued this 29 Dec 2025).
Action required: Update internal KYC policies to reflect that the last uploading RE is responsible for identity/address verification.
Action required: Ensure your bank's systems check that downloaded CKYCR records are current and compliant before relying on them.
Action required: Document reliance on CKYCR records in customer files to demonstrate compliance with the new Explanation.
Action required: Train CDD staff on the revised responsibility split: no re-verification needed for identity/address, but all other CDD obligations remain.
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
Discuss this circular with fellow bankers — reply, upvote what helps, report what doesn’t belong. Be professional; no client data. Views are the commenter’s own, not BankPulse’s.
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=13242&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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