Review of Know Your Client process for individual Person Resident Outside India clients

भारतीय प्रतिभूति और विनिमय बोर्ड
Securities and Exchange Board of India

CIRCULAR

HO/38/30/12(3)2026-MIRSD-POD2/I/25175/2026 November 04, 2026

To,

All intermediaries registered with SEBI under Section 12 of the Securities and Exchange Board of India Act, 1992;
Recognised Stock Exchanges;
Recognised Clearing Corporations; and
All Depositories

Dear Sir/ Madam,

Subject: Review of Know Your Client process for individual Person Resident Outside India clients

1. SEBI vide Master Circular SEBI/HO/MIRSD/SECFATF/P/CIR/2023/169 dated October 12, 2023 (‘KYC Master Circular’), inter-alia, specifies the Know Your Client (KYC) requirements for on-boarding client by an intermediary and a framework for validation of KYC records by a KYC Registration Agency (KRA)¹.

2. The extant provisions of the KYC Master Circular, inter-alia, requires an intermediary to ensure that, during digital KYC, the physical location of the client is in India. This requirement in effect restricts a client outside India, at the time of on-boarding, to submit the KYC documents and complete the KYC process digitally.

3. In order to ease the process of on-boarding of an individual Person Resident Outside India (PROI)² client, it has been decided to review the existing provisions governing the KYC process. Individual PROI client shall mean Non-Resident Indian (NRI)³, Overseas Citizen of India (OCI)⁴ or foreign national.

4. Upon review of the said framework, and after taking into account the representations from market participants, the modifications being introduced, inter-alia, includes the following:

• 4.1. The requirement of a client being in India during digital on-boarding is being relaxed for an individual PROI client located in a Financial Action Task Force (FATF) compliant country⁵ and the intermediary may accept digital submission of KYC information and supporting documents from such client.

• 4.2. KRA shall tag individual attributes in the KYC record as “validated”, if verified with official or source database. All KYC records shall be portable i.e. can be shared with another intermediary, irrespective of every individual attribute being validated or not.

• 4.3. The intermediary may rely on the KYC undertaken by a SEBI registered intermediary or by an entity regulated by other financial sector regulators, based on record obtained from KRA or Central KYC Records Registry (CKYCRR).

• 4.4. The authorised official of the intermediary shall be present during Video In Person Verification of a client and the VIPV process shall be subject to concurrent audit.

5. Accordingly, the on-boarding of individual PROI clients through intermediaries and KRAs, are being detailed below:

• 5.1. The intermediary shall, at the time of commencement of an account based relationship, identify its client, verify the identity and obtain information on the purpose and intended nature of the business relationship.

• 5.2. When the client approaches an intermediary to initiate an account based relationship or update KYC, the intermediary shall seek the PAN and CKYC ID⁶ from the client, if available. Thereafter, the intermediary shall retrieve the KYC records (i.e. information and documents) from KRA and CKYCRR.

• 5.3. If the client record already exists, the intermediary shall obtain additional details from the client only when:

  • 5.3.1. there is a change in the existing records of the client;

• 5.3.2. details retrieved are incomplete or are not as per extant norms;

• 5.3.3. the validity of the Officially Valid Document or deemed officially valid document⁷ has lapsed;

• 5.3.4. the intermediary considers it necessary to verify the identity or address; or

• 5.3.5. to perform enhanced due diligence (EDD) or to build an appropriate risk profile of the client.

• 5.4. The intermediary shall provide the updated KYC information of the client to KRA, which shall update the existing KYC record and inform all intermediaries that avail of the services of the KRA in respect of that client, in line with the provisions of the SEBI {KYC (Know Your Client) Registration Agencies) Regulations, 2011 (‘KRA Regulations’).

• 5.5. The KYC process shall involve the following aspects:

  • 5.5.1. PAN:

    • a. The intermediary shall collect the PAN of the client and verify the same with the Income Tax Database, without insisting on producing the original PAN or providing a copy thereof.
    • b. The KRA shall also verify the PAN and the name of the client, as mentioned in the KYC form, with the Income Tax Database. Accordingly, the said attribute shall be tagged as “validated” in the KYC record.

  • 5.5.2. Passport:

    • a. The intermediary shall collect a copy of the Passport from the client.
    • b. The intermediary shall also collect Overseas Citizen of India (OCI) card from the client, as applicable.
    • c. The intermediary shall verify the passport of the client, if feasible.

• 5.5.3. KYC form:

  • a. The intermediary shall collect the KYC information from the client, as per CKYCRR template⁸ prescribed for “individuals”, in physical or through app, website or digital mode.
  • b. The intermediary can collect the filled KYC form in any of the following manners:
    • i. original physical form; or
    • ii. scanned copy of physical form, under electronic signature⁹; or
    • iii. digital KYC form, under electronic signature.

• 5.5.4. Specimen signature:

  • a. The intermediary shall collect specimen signature from the client in any of the following forms:
    • i. wet signature on the physical KYC form; or
    • ii. cropped image of specimen signature, under electronic signature.
  • b. In case of digital submission of specimen signature, the client shall do wet signature before the intermediary during Video In Person Verification (VIPV), and the intermediary in turn shall verify if the said signature matches with the client’s submission.

• 5.5.5. Proof of Identity and Proof of Address:

  • a. The intermediary shall collect any one of the specified officially valid documents or deemed officially valid documents, for proof of identity and proof of address, from the client. For this purpose, the current address for an individual PROI client shall be an overseas address.

Footnotes

1. KYC Registration Agencies as per SEBI (Know Your Client Registration Agencies) Regulations, 2011; ↩

2. PROI is defined under section 2(w) of the Foreign Exchange Management Act, 1999, as a “person who is not resident in India”; ↩

3. In terms of section 2(30) read with section 2(42) of the Income Tax Act, 1961, "non-resident" means a person who is not a "resident", and for the purposes of sections 92, 93 and 168, includes a person who is not ordinarily resident within the meaning of clause (6) of section 6 thererof; "resident" means a person who is resident in India within the meaning of section 6 thereof; ↩

4. OCI cardholder is defined under section 2 (ee) of the Citizenship Act, 1955, as a person registered as an Overseas Citizen of India Cardholder by the Central Government under section 7A thereof; ↩

5. As per details published by FATF; ↩

6. The unique number or code assigned to a client by CKYCRR; ↩

7. OVD and deemed to be OVD, as defined under the Prevention of Money Laundering (Maintenance of Records) Rules, 2005 (PMLR);

   • d. KRA shall verify the passport of the client, if feasible. Accordingly, the said attribute shall be tagged as “validated” in the KYC record.
   ↩

8. KYC template provided by Central Registry of Securitization Asset Reconstruction and Security Interest of India (CERSAI); ↩

9. “electronic signature” shall have the meaning as defined under the Information Technology Act, 2000; ↩