RBI Shifts CKYCR Verification Responsibility to Last-Updating Entity

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

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).

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.

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.

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:
- Risk categorisation
- Ongoing due diligence
- Enhanced Due Diligence (EDD), where applicable
- Monitoring of transactions
- Periodic KYC updates as prescribed

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

Operational and Compliance Impact

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

For Customer Onboarding

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

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

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.