**Executive Summary**
This document is an amendment to the Reserve Bank of India (Non-Banking Financial Companies – Know Your Customer) Directions, 2025. It clarifies the responsibility for verifying customer KYC records uploaded to and downloaded from the Central KYC Records Registry (CKYCR), based on an office memorandum issued by the Department of Revenue. These Amendment Directions are effective immediately, as of December 29, 2025.
**Key Points / Main Content**
* **Amendment Scope:**
* Modifies the Reserve Bank of India (Non-Banking Financial Companies – Know Your Customer) Directions, 2025.
* **Clarification on KYC Verification Responsibility:**
* 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 KYC records from CKYCR do not need to re-verify the customer's identity and/or address if the downloaded records are current and compliant with the PML Act, 2002 / PML Rules, 2005.
* NBFCs downloading and relying on KYC records from the CKYCR remain responsible for all aspects of the CDD procedure and provisions of these Directions, except for the verification of identity and/or address of the customer.
**Impact Analysis**
**Non-Banking Financial Companies (NBFCs)**
* **Impact:** Reduced burden of re-verifying KYC for customers whose records are already uploaded and verified in CKYCR, streamlining the KYC process.
* **Action Required:** Ensure adherence to all CDD procedures, excluding re-verification of identity and/or address when relying on current and compliant KYC records downloaded from CKYCR.
**Regulated Entities (REs) Uploading/Updating KYC Records**
* **Impact:** Greater accountability for the accuracy and validity of KYC information uploaded to the CKYCR.
* **Action Required:** Implement robust processes for verifying customer identity and address before uploading or updating KYC records in the CKYCR.
Key Entities Referenced
Reserve Bank of India (Non-Banking Financial Companies – Know Your Customer) Directions, 2025: Original directions being amended
Reserve Bank of India (Non-Banking Financial Companies – Know Your Customer) Amendment Directions, 2025: Amendment Directions being issued by RBI
Reserve Bank of India: Regulatory body issuing the amendment directions.
Prevention of Money-Laundering Act, 2002: Act to which compliance is referred.
CKYCR: Central KYC Records Registry, from which customer records are downloaded.
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