RBI Shifts CKYCR Verification Responsibility to Last-Updating Entity

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  • Last Updated on 31 December, 2025

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RBI KYC amendment on CKYCR

Circular no. RBI/2025-26/160 DOR.AML.REC.364/14.01.003/2025-26; Dated: 29.12.2025

1. Regulatory Background

The Reserve Bank of India (RBI) has amended the Master Directions on Know Your Customer (KYC) to bring clarity on accountability and responsibility under the Central KYC Records Registry (CKYCR) framework.

The amendment addresses long-standing operational concerns regarding duplication of KYC verification and allocation of responsibility among Regulated Entities (REs).

2. Clarification on Responsibility for KYC Verification

Under the amended directions:

  • The Bank/NBFC/ARC that last uploads or updates a customer’s KYC record in the CKYCR shall be fully responsible for verification of the customer’s identity and/or address
  • This entity bears the primary accountability for the accuracy and validity of the KYC information uploaded or modified.

3. Reliance on CKYCR Records by Other Regulated Entities

Where another Bank, NBFC, or ARC:

  • Downloads and relies on the latest CKYCR record, and
  • The KYC record is current and valid,

then:

  • Such entity is not required to re-verify the customer’s identity and address again.

This eliminates unnecessary duplication of KYC verification and reduces onboarding friction.

4. Continued Responsibility for Overall CDD

While re-verification of identity and address is not required, RBI has clarified that:

  • Overall Customer Due Diligence (CDD) responsibility continues
  • REs must still comply with:
    1. Risk categorisation
    2. Ongoing due diligence
    3. Enhanced Due Diligence (EDD), where applicable
    4. Monitoring of transactions
    5. Periodic KYC updates as prescribed

Thus, reliance on CKYCR does not dilute AML/CFT obligations.

5. Operational and Compliance Impact

5.1 For Banks, NBFCs and ARCs

  • Clear accountability reduces ambiguity in KYC audits
  • Need to exercise heightened diligence while uploading or updating CKYCR records
  • Strengthens reliance on CKYCR as a single source of truth

5.2 For Customer Onboarding

  • Faster onboarding and reduced documentation burden
  • Less repetitive KYC for customers dealing with multiple REs
  • Improved customer experience

6. Regulatory Intent

The clarification aims to:

  • Promote efficient KYC sharing across the financial system
  • Reduce duplication and compliance costs
  • Strengthen data accountability under CKYCR
  • Maintain robust AML/CFT safeguards while enabling ease of doing business

7. Key Takeaway

RBI has clarified that the RE which last uploads or updates KYC data in CKYCR is responsible for identity and address verification, and other REs may rely on such records without re-verification, while continuing to remain accountable for overall CDD compliance.

Click Here To Read The Full Circular

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Author: Taxmann

Taxmann Publications has a dedicated in-house Research & Editorial Team. This team consists of a team of Chartered Accountants, Company Secretaries, and Lawyers. This team works under the guidance and supervision of editor-in-chief Mr Rakesh Bhargava.

The Research and Editorial Team is responsible for developing reliable and accurate content for the readers. The team follows the six-sigma approach to achieve the benchmark of zero error in its publications and research platforms. The team ensures that the following publication guidelines are thoroughly followed while developing the content:

  • The statutory material is obtained only from the authorized and reliable sources
  • All the latest developments in the judicial and legislative fields are covered
  • Prepare the analytical write-ups on current, controversial, and important issues to help the readers to understand the concept and its implications
  • Every content published by Taxmann is complete, accurate and lucid
  • All evidence-based statements are supported with proper reference to Section, Circular No., Notification No. or citations
  • The golden rules of grammar, style and consistency are thoroughly followed
  • Font and size that's easy to read and remain consistent across all imprint and digital publications are applied