Date: 2025-12-02Category: Public Private Partnership in IndiaState: Union GovernmentCountry: India
Amendment to Master Circular - Guidelines on Know Your Customer / Anti Money Laundering/Combating the Financing of Terrorism (KYC/AML/CFT) issued on 25.09.2025 with an emphasis on KYC requirements for Non-Resident Indian (NRI) and Overseas Citizen of India (OCI) onboarding to NPS.
**Executive Summary**
This document, issued by the Pension Fund Regulatory and Development Authority (PFRDA) on December 2nd, 2025, amends the Master Circular on KYC/AML/CFT guidelines issued on 25.09.2025. The amendment focuses on KYC requirements for Non-Resident Indian (NRI) and Overseas Citizen of India (OCI) onboarding to the National Pension System (NPS). It details revised KYC/CDD processes, acceptable documents, and verification procedures for NRIs and OCIs.
**Key Points / Main Content**
* **Digital Onboarding Relaxations:**
* The requirement for the physical location of the subscriber being in India is relaxed for digital KYC onboarding of NRI/OCI subscribers.
* PoPs must ensure GPS location captured matches the subscriber's Proof of Address and prevent spoofed IP address connections.
* Digital onboarding applications must include liveness detection, randomness checks, and anti-spoofing measures.
* **Acceptable Documents for KYC:**
* For NRIs, passport is accepted as Proof of Identity (Pol). Passport or address proof certified by foreign authorities are accepted as Proof of Address (PoA).
* For OCIs, OCI card and foreign passport are accepted as Pol. Foreign passport or driving license are accepted as PoA (only if containing current overseas address).
* Foreign language documents must have a translated English version.
* REs must ensure documents are valid on the date of onboarding. Expired documents are not acceptable.
* **KYC Updation and Modification:**
* All KYC modes permitted for new subscriber onboarding are applicable for KYC updation, including NRI and OCI subscribers.
* The physical presence requirement in India is relaxed for re-KYC/KYC modification of existing NRI/OCI subscribers.
* If no KYC information changes, a self-declaration is sufficient for periodic updates.
* Updation can be done at any overseas branch of the RE.
* Periodic updation can be done digitally or by submitting attested copies of KYC documents.
* **Enhanced Due Diligence (EDD):**
* Alternate mobile numbers shall not be linked post CDD with such accounts.
* If documents are suspected to be forged, the subscriber will be classified as high-risk, and a Suspicious Transaction Report (STR) will be filed.
* PAN must be obtained and verified.
* The first transaction must be a credit from an existing KYC-compliant bank account.
* Customers opened in non-face to face mode shall be subjected to enhanced monitoring
* **Contributions and FEMA Compliance:**
* Contribution amounts must be paid via inward remittance or from NRE/FCNR/NRO accounts.
* Withdrawal proceeds will be credited to the subscriber's NRO/NRE account.
* Subscribers must inform CRA/PoP of a change in NRI status within 3 months.
* **NPS Tier II Account Restriction**
* Option of NPS Tier II account will not be available for both NRI and OCI subscribers.
**Impact Analysis**
**Point of Presence (PoPs), NPS Trust.**
* **Impact:** Must update their onboarding processes and systems to comply with the new KYC requirements for NRIs and OCIs. Responsible for ensuring that documents meet the revised guidelines and that digital onboarding processes include necessary security measures.
* **Action Required:** Review and modify existing onboarding procedures, update KYC checklists, train staff on new requirements, and implement necessary system changes to support digital onboarding security measures.
**NRI and OCI Subscribers**
* **Impact:** Benefit from relaxed physical presence requirements for digital KYC and KYC updates. Will need to provide necessary documentation as per revised guidelines.
* **Action Required:** Provide valid and current documents as required for KYC, ensure address proofs meet specified requirements, and inform CRA/PoP of any changes in NRI status within the stipulated timeframe.
**Regulated Entities (REs)**
* **Impact:** Must adhere to the updated KYC/AML guidelines specified in the circular.
* **Action Required:** Update policies and procedures to align with the amended guidelines and ensure compliance.
Key Entities Referenced
Pension Fund Regulatory and Development Authority (PFRDA): The regulatory body issuing the circular, responsible for regulating and developing the pension sector in India.
Master Circular - Guidelines on Know Your Customer / Anti Money Laundering/Combating the Financing of Terrorism (KYC/AML/CFT): The primary policy document being amended by this circular, concerning KYC, AML, and CFT guidelines.
National Pension System (NPS): The pension scheme that the policy amendment specifically addresses, particularly regarding onboarding of NRIs and OCIs.
Non-Resident Indian (NRI) and Overseas Citizen of India (OCI): The specific category of subscribers targeted by the amendment, relating to KYC requirements.
Prevention of Money Laundering Act (PMLA): Referenced in the document, outlines regulations for Anti-Money Laundering which entities must comply with.
PFRDA/2025/22/REG-POP/04 02nd December 2025
To,
All Point of Presence (PoPs), NPS Trust.
Dear Sir/Madam,
Subject: Amendment to Master Circular - Guidelines on Know Your Customer / Anti
Money Laundering/Combating the Financing of Terrorism (KYC/AML/CFT) issued
on 25.09.2025 with an emphasis on KYC requirements for Non-Resident Indian
(NRI) and Overseas Citizen of India (OCI) onboarding to NPS.
This is with reference to the master circular no. PFRDA/Master Circular/2024/04/PoP-
02 on “Guidelines on Know Your Customer / Anti Money Laundering/Combating the
Financing of Terrorism (KYC/AML/CFT)” updated as on 25th September 2025. In addition
to the various provisions made therein for the purpose of KYC/AML/CFT, this amendment
intends to lay down the KYC/CDD process required for on boarding of Non-Resident
Indian (NRI) and Overseas Citizen of India (OCI) into NPS.
2. The KYC process requires PFRDA registered PoPs/intermediaries to obtain and verify
the Proof of Identity (PoI) and Proof of Address (PoA) from the subscriber at the time of
commencement of an account-based relationship.
3. In this respect, Para 8.2 regarding Modes of KYC, a para may be inserted as under:
8.2.1.5 (a) In case of digital onboarding for the NRI/OCI subscribers, the requirement of
capturing a live photograph of the subscribers, a digital copy of an officially valid document
(OVD) and geo-coordinates of the captured location, all recorded electronically by an
authorized official shall be applicable. For this purpose, the requirement of physical
location of subscriber being in India, during digital onboarding, shall be relaxed for KYC
for the subscriber.
8.2.1.5 (b) The Points of Presence (PoPs) shall ensure that the GPS location (latitude
and longitude) captured by the intermediary matches with the latitude and longitude of
country given in Proof of Address of the subscriber and it shall also prevent connections
from spoofed IP address.
The digital onboarding application shall incorporate liveness detection, randomness
checks, and anti-spoofing/anti–deep fake measures, ensuring that the interaction is live,
tamper-proof and not pre-recorded.
Page 1 of 6
5th Floor, Tower E, World Trade Center, Nauroji Nagar, New Delhi – 110 029
Phone: 011 - 26517501, 26517503. website: www.pfrda.org.in4. In this respect, Para 8.3 regarding ‘Officially Valid Documents (OVDs)’, a para may
be inserted as under:
Para 8.3 (a): Admissible digital copy of Officially Valid Document (OVD) for Non-Resident
Indian (NRI) and Overseas Citizen of India
REs, at the time of onboarding the subscriber into NPS, shall identify their subscriber,
verify their identity and obtain information for the purpose Customer Due Diligence (CDD).
The name as mentioned in the application/KYC form shall match the name as mentioned
in the Proof of Identity (PoI) submitted by subscriber. The following documents shall be
admissible as Proof of Identity (PoI) and Proof of Address (PoA) for opening of NPS
tier I accounts.
A. For Non-Resident Indian (NRI):
a) The following documents shall be accepted as PoI:
i. The passport;
a) The following documents shall be accepted as PoA:
i. The passport;
ii. Address proof duly certified by the foreign government or foreign public
authorities:
Residence Permit; or
Work Permit; or
Foreign National ID; or
Overseas driver’s licence (if government-issued)
iii. Any other document as notified by the Central Government in
consultation with the Regulator
Note:
i. Where the passport of an NRI subscriber contains both the permanent and current
address as foreign addresses, the same shall be accepted as valid Proof of Address
(PoA). In such cases, no separate Indian address proof shall be required for Indian
correspondence address. The passport copy shall be self-attested by the subscriber
and attested by a competent authority (Indian Embassy / Consulate General in the
country where the non-resident customer resides / Notary Public / /Court
Magistrate/Judge/authorised officials of overseas branches of Scheduled
Commercial Banks registered in India).
ii. Where the Passport of an NRI subscriber contains both the permanent and current
address as Indian, the same shall be accepted as valid Proof of Address for Indian
Page 2 of 6address only. However, since the subscriber is residing outside India, a separate
document evidencing the current overseas address shall be obtained.
iii. In case the officially valid document presented by a foreign national does not contain
the details of address, in such case the documents issued by the Government
departments of foreign jurisdictions and letter issued by the Foreign Embassy or
Mission in India shall be accepted as proof of address. All such documents shall be
self-attested by the subscriber and attested by an authorised official (Indian Embassy
/ Consulate General in the country where the non-resident customer resides / Notary
Public / /Court Magistrate/Judge/authorised officials of overseas branches of
Scheduled Commercial Banks registered in India).
B. For Overseas Citizen of India (OCI):
a) The following documents shall be accepted as PoI:
i. The OCI Card; and
ii. The foreign passport
b) The following documents shall be accepted as PoA only if it contains current
overseas address:
i. The foreign passport; or
ii. The driving licence (issued by foreign authorities)
5. Where the Passport submitted as Proof of Identity also contains the current overseas
address, the same shall be accepted as valid Proof of Address.
6. In case the officially valid document presented by a foreign national does not contain
the details of address, in such case the documents issued by the Government
departments of foreign jurisdictions and a letter issued by the Foreign Embassy or Mission
in India shall be accepted as proof of address. All PoA documents shall be self-attested
by the subscriber, and also attested by an authorised official (Indian Embassy / Consulate
General in the country where the non-resident customer resides / Notary Public / /Court
Magistrate/Judge/authorised officials of overseas branches of Scheduled Commercial
Banks registered in India).
7. Where a proof of address document is submitted in a foreign language, the regulated
entity must confirm that a duly translated English version is additionally provided.
8. RE shall ensure that the Passport, Visa, Residence Permit and other supporting
documents are valid as on the date of onboarding, and expired documents shall not be
accepted unless permitted under applicable PML Rules.
9. The subscriber shall be responsible for providing correct and authentic documents to
establish their NRI/OCI status. Submission of forged, falsified, or misleading documents
Page 3 of 6shall result in rejection of the application and may be reported to the appropriate
authorities as required under applicable PMLA provisions
C. Option of NPS Tier II account will not be available for both NRI and OCI
subscribers.
11. In this respect, Para 8.4.3 regarding ‘Provisions for KYC updation’, a para 8.4.3.2
may be substituted as under:
8.4.3.2 All modes of KYC as permitted for on-boarding of new subscriber including NRI
and OCI subscribers, shall be applicable for such updation.
Insertion of Para-
8.4.3.2 (a) In case of NRI/OCI subscribers, the updation/periodic updation of KYC records
are allowed to be carried out at any overseas branch of the RE with which subscriber
maintains the NPS account
Insertion of Para-
8.4.3.10 In case of existing NRI/OCI subscribers, the requirement of physical location of
subscriber being in India shall be relaxed for re-KYC / KYC modification for existing
subscribers.
8.4.3.11 In case of no change in the KYC information, a self-declaration from the NRI
subscriber shall be obtained through subscriber’s email-id / mobile number registered
with the RE, letter and other means of communication as prescribed from time to time.
This is permitted only in case of periodic updation of KYC and not at the time of exit or
withdrawal from the system.
8.4.3.12 The updation/periodic updation of KYC records are allowed to be carried out at
any overseas branch of the RE with which subscriber maintains the NPS account.
8.4.3.13 The periodic updation of KYC may be undertaken through digital or electronic
means, or by submission of self-attested and duly attested copies of the latest KYC
documents (Passport, OCI Card, overseas address proof, etc.).
Attestation may be carried out by any of the following authorities:
i. Indian Embassy; or
ii. Consulate General in the country where the non-resident customer resides; or
iii. Notary Public in the country of residence; or
iv. Court Magistrate; or
v. Judge; or
vi. Authorised officials of overseas branches of Scheduled Commercial Banks
registered in India.
Page 4 of 6Such attestation shall be deemed compliance with the requirement of “Original Seen and
Verified (OSV)” under the PML Rules.
8.4.3.14 During periodic updation, the subscriber shall reconfirm FATCA/CRS
declarations, tax residency details, and current residency status (NRI/OCI/Resident) to
ensure compliance with applicable FEMA and PMLA provisions.
8.4.3.15 The RE shall verify the validity of the Passport, Visa, Residence Permit, and OCI
Card during each periodic updation and obtain updated documents where required.
In this respect, Para 8.4.5 regarding provisions ‘Enhanced Due Diligence (EDD), a
para 8.4.5.5 (c), (d), (e), (f), (g) may be inserted as under:
c. In order to prevent frauds, alternate mobile numbers shall not be linked post CDD with
such accounts for transaction OTP, transaction updates, etc. Transactions shall be
permitted only from the mobile number used for account opening. RE shall have a Board
approved policy delineating a robust process of due diligence for dealing with requests
for change of registered mobile number.
d. In case the RE suspects that the documents furnished for establishing NRI/OCI status
are forged, tampered, or otherwise unreliable, the RE shall classify the subscriber as high-
risk, undertake enhanced due diligence, reject the KYC application, and file a Suspicious
Transaction Report (STR) with FIU-IND in accordance with Rule 9 of the PML Rules and
other applicable regulatory guidelines.
e. RE shall obtain PAN from the customer and the PAN shall be verified from the
verification facility of the issuing authority.
f. First transaction in such accounts shall be a credit from existing KYC-complied bank
account of the customer.
g. Such customers shall be categorized as high-risk customers and accounts opened in
non-face to face mode shall be subjected to enhanced monitoring until the identity of the
customer is verified in face-to-face manner or through VCIP.
New provision may be inserted as under:
10. 8.4.3 (a) Contributions, Remittances & FEMA Compliance for NRI and OCI
subscribers
(i) The contribution amounts shall be paid by the NRIs and OCIs either by inward
remittance through normal banking channels or out of funds held in their own
NRE/FCNR/NRO accounts.
Page 5 of 6(ii) At the time of withdrawal/exit, the proceeds of NPS shall be credited to NRO/NRE
account of the NRI/OCI subscriber and repatriation will be as per applicable FEMA
guidelines.
(iii) Once the NRI Status of the subscriber changes to Resident status, the subscriber will
inform the same to CRA/PoP for updating the same in CRA system within 3 months from
such change
11. Further, various other provisions stated in the aforesaid Master Circular on
KYC/AML/CFT as applicable in the case of NRIs/OCIs shall continue to be in effect.
12. Where the sectoral regulator of a Regulated Entity prescribes KYC/AML requirements
that are more recent or comprehensive than those specified herein, the Regulated Entity
may comply with such updated requirements.
13. This circular is issued in exercise of powers conferred under section 14 (1) of The
Pension Fund Regulatory & Development Authority Act, 2013 and shall be effective from
the date of its issuance.
Yours faithfully
(Ashish Kumar)
Chief General Manager
Copy to: All Central Record Keeping Agencies
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