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**1. Executive Summary:**
This report analyzes SEBI Circular SEBI/HO/IMRSD/POD/FATF/CIR/2025/62, dated May 06, 2025, which mandates that all KYC Registration Agencies (KRAs) publish an Investor Charter on their websites. The core purpose is to facilitate investor awareness regarding KRA activities, investor rights, and grievance redressal mechanisms. Key findings include a focus on enhanced transparency, data protection, and improved investor service concerning KYC processes within the securities market.
**2. Introduction:**
This report aims to provide a comprehensive overview of SEBI Circular SEBI/HO/IMRSD/POD/FATF/CIR/2025/62 concerning the publication of an Investor Charter for KYC Registration Agencies (KRAs). The analysis is based solely on the information provided within the text of the circular.
**3. Policy Overview:**
* This is a new policy initiative (not an amendment).
* **Core Objective(s):** As inferred from the text, the core objectives are:
* To increase investor awareness about the roles, responsibilities, and services provided by KRAs.
* To enhance investor protection through increased transparency and clear articulation of investor rights.
* To establish a standardized grievance redressal mechanism for investors dealing with KRAs.
* To enable centralised management and safekeeping of KYC data while reducing the burden of repeat KYC and ensuring uniform KYC compliance.
**4. Background and Rationale:**
Since this is a new policy, the text suggests that the policy addresses a perceived gap in investor awareness and protection related to KYC processes. The circular likely responds to a need for greater clarity and accessibility of information regarding investor rights and KRA responsibilities, indicating a potential for previous confusion or difficulty for investors navigating the KYC process. The drive towards centralised management also suggests an existing problem of efficiency.
**5. Key Provisions / Changes:**
As a new policy, the key provisions are:
* **Mandatory Publication of Investor Charter:** All registered KRAs are required to publish the Investor Charter (as provided in Annexure A) on their websites and display it prominently in their offices.
* **Dissemination via Multiple Channels:** KRAs must disseminate the Investor Charter through their websites, email, and physical displays in offices.
* **Investor Charter Content:** The Investor Charter details the services provided by KRAs (KYC registration, modification, status tracking, solicited/unsolicited feeds, alert mechanism and verification of KYC attributes), investor rights (assurance of privacy, KYC accuracy, grievance redressal), Dos and Don'ts for investors, and the grievance redressal mechanism.
* **Grievance Redressal Mechanism:** The policy outlines a three-tiered grievance redressal mechanism: direct complaint to KRA (within 21 days), escalation via SEBI Complaints Redress System (SCORES), and dispute resolution via the SMART Online Dispute Resolution (ODR) Portal.
* **Data Protection and Privacy:** KRA implements safeguards to maintain KYC data privacy, security, and confidentiality.
**6. Target Audience and Stakeholders:**
* **Primary Target Audience:** Investors in the securities market who are required to undergo KYC processes.
* **Key Stakeholders:**
* KYC Registration Agencies (KRAs).
* SEBI Registered Intermediaries.
* Securities and Exchange Board of India (SEBI).
**7. Implementation Aspects (Inferred):**
* **Responsible Agency/Bodies:** KYC Registration Agencies (KRAs) are primarily responsible for implementing the policy by publishing and disseminating the Investor Charter. SEBI oversees compliance and handles escalated grievances through SCORES.
* **Timelines/Procedures:** The circular comes into effect from the date of the circular (May 06, 2025). KRAs are required to take "necessary steps" to bring the Investor Charter to the notice of investors. A 21-day timeline is specified for KRAs to respond to direct complaints.
* Alerts are to be sent to investors at concurrent intervals at the time of processing registration, modification or download of KYC records.
**8. Expected Outcomes / Impact of Changes:**
The likely intended outcomes of this policy are:
* Increased investor awareness and understanding of KYC processes.
* Improved investor confidence and protection in the securities market.
* More efficient and transparent KYC operations by KRAs.
* Reduced investor grievances related to KYC processes.
* Enhanced data security and privacy protection of investor KYC information.
* Streamlined grievance redressal, with defined escalation pathways.
**9. Conclusion:**
SEBI Circular SEBI/HO/IMRSD/POD/FATF/CIR/2025/62 represents a significant step towards enhancing investor protection and transparency in the securities market. By mandating the publication of an Investor Charter, SEBI aims to empower investors with the knowledge and resources necessary to navigate KYC processes effectively and address any grievances that may arise. This policy is likely to improve the overall investor experience and foster greater confidence in the securities market.
Key Entities Referenced
CIRCULAR SEBIHOMIRSDPODFATFPCIR202562: Circular identifier issued by SEBI.
May 06, 2025: Date of the circular.
KYC Know Your Client Registration Agencies KRAs: Full form of KRAs, the entities to whom the circular is addressed and the subject of the circular.
SEBI: Securities and Exchange Board of India, the regulator that developed the Investor Charter for KRAs.
Investor Charter: A document detailing services provided to investors, their rights, KRA activities, Dos and Donts, and grievance redressal mechanisms.
Annexure A: Attachment containing the Investor Charter.
Section 11(1) of Chapter IV of the Securities and Exchange Board of India Act, 1992: Legal basis for the circular's issuance.
www.sebi.gov.in: SEBI's website where the circular is available.
Legal Circulars: Section on SEBI's website where the circular is located.
Sapna Sinha: Deputy General Manager at SEBI, contact person for the circular.
02226449748: Telephone number of Sapna Sinha.
sapnassebi.gov.in: Email address of Sapna Sinha.
PAN: Permanent Account Number. KRA verifies KYC attributes with official databases for PAN except for PAN exempt records.
Aadhaar: KRA verifies KYC attributes of investors' KYC records with official databases for Aadhaar.
SEBI Registered Intermediary: Entities registered with SEBI through which investors interact with KRAs.
Alert Mechanism: KRA sends alerts SMSEmailphysical at concurrent interval to the investors at the time of processing registration, modification of download of KYC records.
Investor Grievance Redressal Mechanism: Mechanism for investors to raise and resolve grievances.
One Time Password OTP: Investors are advised not to share One Time Password OTP, specimen signature, KYC documents etc. with unknown persons.
SCORES: SEBI Complaints Redress System, a web-based centralized grievance redressal system of SEBI at https:scores.gov.in.
https:scores.gov.in: Website for the SEBI Complaints Redress System SCORES.
SMART Online Dispute Resolution ODR Portal: A portal where investor may initiate dispute resolution through the SMART Online Dispute Resolution ODR Portal to seek the resolution at https:smartodr.inlogin.
https:smartodr.inlogin: Website for the SMART Online Dispute Resolution ODR Portal.
CIRCULAR
SEBI/HO/MIRSD/PODFATF/P/CIR/2025/62 May 06, 2025
To,
All KYC (Know Your Client) Registration Agencies (KRAs)
Dear Sir/Madam,
Subject: Publishing Investor Charter for KYC (Know Your Client) Registration
Agencies (KRAs) on their Websites.
1. In order to facilitate investor awareness about various activities where an
investor/client has to deal with KRAs for availing Investor Service Requests,
SEBI has developed an Investor Charter for KRAs, inter-alia, detailing the
services provided to Investors, Rights of Investors, various activities of KRAs,
Dos and Don’ts for Investors and Grievance Redressal Mechanism.
2. In this regard, all the registered KRAs shall take necessary steps to bring the
Investor Charter, as provided at ‘Annexure – A’ to the notice of existing and
new investors by way of:
a) disseminating the Investor Charter on their websites / through e-mail;
b) displaying the Investor charter at prominent places in offices etc.
3. These disclosure requirements are in addition to those already mandated by
SEBI.
4. This circular is issued in exercise of powers conferred under Section 11(1) of
Chapter IV of the Securities and Exchange Board of India Act, 1992 to protect
the interests of investors in securities and to promote the development of, and
to regulate the securities markets and shall come into effect from the date of
this circular.
Page 1 of 65. The Circular is issued with the approval of the competent authority.
6. This circular is available at www.sebi.gov.in under the link “Legal --- Circulars”.
Yours faithfully,
Sapna Sinha
Deputy General Manager
Tel. No. 022-26449748
sapnas@sebi.gov.in
Page 2 of 6ANNEXURE – A
INVESTOR CHARTER – KYC {KNOW YOUR CLIENT} REGISTRATION AGENCIES
(KRAs)
VISION
To be investor service oriented, market wide repository, facilitating timely
processing, storage and incidental services of KYC records in the securities
market, maintaining the highest standards of data security and record quality.
MISSION
To enable centralized management and safekeeping of KYC data and reducing
the burden of repeat KYC while ensuring uniform KYC compliance across the
securities market.
To enable seamless and efficient client on-boarding, ensuring real-time updation
of unique client’s KYC record and automated dissemination of updates to all linked
SEBI Registered Intermediaries
To foster a secure, efficient, and compliance-driven ecosystem, setting global
benchmark for data integrity and operational excellence.
SERVICES PROVIDED BY KRAs TO INVESTORS
KYC Registration and Modification: KRA facilitates registration and modification
of KYC records of investors in securities market through SEBI Registered
Intermediaries, ensuring verification and validation of the investor’s identity.
KYC Status Tracking: KRA provides ease of access to investors/ SEBI
Registered Intermediaries to track status of KYC registration and modification,
online.
Page 3 of 6 Solicited/ Unsolicited Feeds: KRA empowers investor to update their KYC
information with any of the SEBI Registered Intermediary for utilisation of their
KYC details across the securities market at the behest of the investor. For this
purpose, KRAs promptly disseminates updated KYC information of an investor to
the relevant linked SEBI Registered Intermediary for further processing.
Alert Mechanism KRA sends alerts (SMS/Email/physical) at concurrent interval
to the investors at the time of processing registration, modification of download of
KYC records.
Verification of KYC attributes KRA verifies KYC attributes of investors' KYC
records with official databases for PAN (except for PAN exempt records),
Aadhaar, Name, Address. Additionally Email Id and Mobile Number are also been
verified. Depending on the status of verification/validation of KYCs attributes, KRA
assigns status to KYC as either:
o KYC Validated: The validated records are allowed portability i.e. the
client need not undergo the KYC process again when he approaches
different intermediary in securities market and the intermediary shall
fetch the validated records from the KRA database.
o KYC Registered: Investor is required to perform KYC each time,
investor approach a new SEBI Registered Intermediary.
o KYC On-Hold/Rejected: This may be owing to deficiency in the KYC
documents such as PAN validation failure, Mobile number and Email Id
not verified, etc. Such clients shall be allowed to transact further in the
securities market subject to verification of attributes.
Data Protection and Privacy: KRA implements safeguards to maintain KYC data
privacy, security, and confidentiality.
Page 4 of 6INVESTORS have RIGHT to:
Assurance of privacy and protection for KYC data, with limited access to
authorized Registered Intermediaries only.
Verify and ensure that KYC information is accurate and updated.
Access to prompt grievance redressal mechanism for complaints or issues arising
from KYC process in securities market.
Avail guidance from KRA on KYC related processes for securities market.
Access to privacy policy, use of information policy, website policy of KRA for
awareness of the investors.
View their KYC status online and carry out necessary updates through SEBI
Registered Intermediary.
Avail facility of delinking the KYC record through an intermediary on reporting
closure of account based relationship by such intermediary.
DOs AND DON’Ts FOR INVESTORS: Investors are encouraged to take the following
actions to ensure seamless KYC compliance:
DO's for Investors:
Submit valid, accurate, and complete documentation during KYC registration or
modification process.
Notify SEBI Registered Intermediary of any changes in KYC details (such as
address, contact details, etc.) to maintain the accuracy of the KYC information and
perform re-KYC, as and when required.
In case investor receives alert from KRAs, about registration, modification or KYC
record download, which is not associated with any of the investor-induced
transaction(s), investors should promptly communicate to KRA on the designated
email ID.
Know about the Investor Grievance Redressal Mechanism and ensure that
grievances are taken up with the concerned entities within the time limits
prescribed.
Page 5 of 6DONT's for Investors:
Do not deal with unauthorized person(s) for any investor service request such as
updation of KYC details (address, email ID, mobile number etc).
Do not share One Time Password (OTP), specimen signature, KYC documents
etc. with unknown person(s)
GRIEVANCE REDRESSAL - MODES AND ESCALATION MECHANISM
I] DIRECT COMPLAINT TO KRA:
Investor can dial on helpline numbers of KRA for any query or concern.
Investor shall check the website of KRAs for the dedicated grievance e-mail ID
and other relevant details of the grievance redressal division / compliance officer
for registering grievance(s).
The investor may initially lodge their grievance directly with the KYC Registration
Agency (KRA) on dedicated e-mail ID or through physical letter with the details of
issue being faced.
Upon receipt of the grievance, KRA after due verification shall send intimation of
redressal of complaint via e-mail / physical letter as applicable, within 21 days from
the date of receipt of such grievance.
II] ESCALATION VIA SCORES PORTAL:
In case the grievance remains unresolved or the investor is not satisfied with the
redressal, then they may escalate the issue to SEBI electronically through SEBI
Complaints Redress System - SCORES (a web based centralized grievance
redressal system of SEBI at (https://scores.gov.in/)
III] DISPUTE RESOLUTION VIA ODR PORTAL:
In case the grievance continues to be unresolved even after utilizing the
SCORES escalation process, the investor may initiate dispute resolution
through the SMART Online Dispute Resolution (ODR) Portal to seek the
resolution at (https://smartodr.in/login)
Page 6 of 6