**Executive Summary**
The Reserve Bank of India (RBI) has issued amendment directions, effective immediately, to the "Reserve Bank of India (Non-Banking Financial Companies – Know Your Customer) Directions, 2025" dated November 28, 2025. These amendments clarify the responsibility of entities uploading and downloading customer records from the Central KYC Records Registry (CKYCR). The clarification addresses the verification of customer identity and address.
**Key Points / Main Content**
* **Amendment Directions:**
* These directions are called the "Reserve Bank of India (Non-Banking Financial Companies – Know Your Customer) Amendment Directions, 2025."
* They modify the "Reserve Bank of India (Non-Banking Financial Companies – Know Your Customer) Directions, 2025"
* These Directions come into force with immediate effect.
* **Clarification on KYC Verification:**
* The RE (Regulated Entity) that last uploaded or updated a customer's KYC records in the CKYCR is responsible for verifying the customer's identity and/or address.
* NBFCs downloading and relying on KYC records from CKYCR are not required to re-verify the authenticity of the customer's identity and/or address, provided the KYC records are current and compliant with the PML Act, 2002 / PML Rules, 2005.
* NBFCs downloading and relying on KYC records from CKYCR remain responsible for all aspects of CDD (Customer Due Diligence) procedures and provisions of these Directions, except for the verification of identity and/or address.
**Impact Analysis**
**Regulated Entities (REs) that upload/update KYC records to CKYCR**
* **Impact:** They bear the responsibility of verifying the customer's identity and/or address during the initial upload or subsequent update of the KYC records in the CKYCR.
* **Action Required:** Ensure robust processes are in place for verifying customer identity and address before uploading or updating records in the CKYCR.
**Non-Banking Financial Companies (NBFCs) that download KYC records from CKYCR**
* **Impact:** They can rely on KYC records downloaded from CKYCR without re-verifying identity or address, provided the records are current and compliant. However, they are still responsible for other CDD procedures.
* **Action Required:** Ensure downloaded KYC records are current and compliant with PML Act and Rules. Maintain robust CDD procedures beyond identity and address verification.
Key Entities Referenced
Reserve Bank of India (Non-Banking Financial Companies – Know Your Customer) Directions, 2025: Original directions being amended by the current document
Reserve Bank of India (Non-Banking Financial Companies – Know Your Customer) Amendment Directions, 2025: The primary subject of the document, amending KYC guidelines for NBFCs
PML Act, 2002: Prevention of Money Laundering Act, 2002, the original legislation that these directions are in compliance with
Reserve Bank of India Act, 1934: Act that grants the Reserve Bank of India the power to make these directions
CKYCR: Central KYC Records Registry; the document clarifies the responsibilities of uploading and downloading customer records to/from CKYCR
RBI/2025-26/160
DOR.AML.REC.364/14.01.003/2025-26 December 29, 2025
Reserve Bank of India (Non-Banking Financial Companies – Know Your
Customer) Amendment Directions, 2025
Reserve Bank had issued Reserve Bank of India (Non-Banking Financial Companies –
Know Your Customer) Directions, 2025 dated November 28, 2025 (hereinafter referred to
as the Directions) in compliance of the provisions of the PML Act, 2002 and the Rules
made thereunder. There is a need to amend the Directions to clarify the responsibility of
entities uploading customer records to and downloading the same from CKYCR, based
on the office memorandum (OM) titled “CKYCR and the ultimate responsibility of REs –
reg.” issued by the Department of Revenue, Govt of India, dated September 18, 2025.
2. Accordingly, in exercise of the powers conferred by sections 45JA, 45K, and 45L of
the Reserve Bank of India Act, 1934, section 10(2) read with section 18 of Payment and
Settlement Systems Act 2007 (Act 51 of 2007), section 11(1) of the Foreign Exchange
Management Act (FEMA), 1999, section 30A of the National Housing Bank Act, 1987,
Rule 9(14) of the Prevention of Money-Laundering (Maintenance of Records) Rules,
2005, and all other enabling laws in this regard, the Reserve Bank being satisfied that it
is necessary and expedient in the public interest so to do, hereby issues the Amendment
Directions hereinafter specified.
3. Short Title and Commencement
(1) These Directions shall be called the Reserve Bank of India (Non-Banking Financial
Companies – Know Your Customer) Amendment Directions, 2025.
(2) These Directions shall come into force with immediate effect.
4. These Amendment Directions modify the Reserve Bank of India (Non-Banking
Financial Companies – Know Your Customer) Directions, 2025 as under:(1) In paragraph 63, the following “Explanation” is being inserted after sub-paragraph
(9):
“Explanation: The RE that has last uploaded or updated the customer’s KYC records in
the CKYCR shall be responsible for verifying the identity and / or address of the customer,
as applicable. Accordingly, any NBFC downloading and relying on such records from the
CKCYR shall not be required to re-verify the authenticity of the customer’s identity and /
or address, provided the KYC records downloaded from CKYCR are current and
compliant with the PML Act, 2002 / PML Rules, 2005. The NBFC downloading and relying
on KYC records downloaded from the CKCYR shall remain responsible for all aspects of
CDD procedure and provisions of these Directions, except verification of identity and / or
address of the customer.”
(Veena Srivastava)
Chief General Manager