On December 10, 2025, the Securities and Exchange Board of India (SEBI) issued Circular HO/38/30/12(1)2025-MIRSD-SEC-FATF to intermediaries registered with SEBI under Section 12 of the Securities and Exchange Board of India Act, 1992, and to Stock Exchanges, regarding the relaxation of geo-tagging requirements in India for Non-Resident Indians (NRIs) undertaking re-KYC.
Based on stakeholder references, SEBI has decided to modify KYC provisions under the Master Circular on KYC dated October 12, 2023, to ease the re-KYC process for NRIs. The requirement of physical location being in India for NRI clients to undertake due diligence through digital mode has been relaxed. Para 51 of the Master Circular on KYC will be modified accordingly.
The App will have features like random action initiation for client response, time stamping, and geo-location tagging. The GPS location captured by the intermediary must match the latitude and longitude of the country given in the Proof of Address provided by the client. The app shall prevent connections from spoofed IP address.
The circular is issued under Section 11(1) of the Securities and Exchange Board of India Act, 1992 and is available at www.sebi.gov.in under “Legal -> Circulars”.
For inquiries, contact Sapna Sinha, Deputy General Manager, Phone No. 022-2644 9748, Email id: sapnas@sebi.gov.in.
Key Entities Referenced
Securities and Exchange Board of India (SEBI): Regulator that issued the circular, responsible for governing securities markets in India.
Securities and Exchange Board of India Act, 1992: The Act under which SEBI is operating and issuing the circular, specifically mentioned in Section 12 and Section 11(1).
Non-Resident Indians (NRIs): The individuals who are the beneficiaries of the policy relaxation related to KYC.
KYC Master Circular: The existing policy being modified to ease re-KYC process for NRIs.
India: The country where the geo-tagging requirement is being relaxed for NRIs.
CIRCULAR
HO/38/30/12(1)2025-MIRSD-SEC-FATF December 10, 2025
To,
1. Intermediaries registered with SEBI under Section 12 of the Securities and
Exchange Board of India Act, 1992
2. Stock Exchanges
Dear Sir/Madam,
Subject: Relaxation on geo-tagging requirement in India for NRIs while
undertaking re-KYC
1. Based on references received from multiple stakeholders to ease KYC access for
Non-Resident Indians (NRIs), SEBI has decided to modify the existing provisions
under Master Circular on KYC dated October 12, 2023 to ease re-KYC process for
NRIs.
2. In this respect, the requirement of physical location being in India shall be relaxed
for NRI clients to undertake due diligence through digital mode.
3. Accordingly, Para 51 of Master Circular on KYC shall be modified as under;
The App shall also have features of random action initiation for client
response to establish that the interactions are not pre-recorded along with
time stamping and geo-location tagging to ensure the requirement like
physical location being in India etc. are also implemented. The requirement
of physical location of client being in India during digital on boarding shall
be relaxed for undertaking re-KYC for existing clients.
The App shall also 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 given by the client. The app shall prevent
connections from spoofed IP address.
Page 1 of 24. This circular is being issued in exercise of the powers confined under Section 11(1)
of the Securities and Exchange Board of India Act, 1992
5. This circular is available at www.sebi.gov.in under the link “Legal -> Circulars”
Yours faithfully,
Sapna Sinha
Deputy General Manager
Phone No. 022-2644 9748
Email id: sapnas@sebi.gov.in
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