**Executive Summary**
The Reserve Bank of India (RBI) has issued Amendment Directions to the "Reserve Bank of India (Non-Banking Financial Companies – Know Your Customer) Directions, 2025". These amendments, effective immediately, clarify the responsibilities of entities uploading and downloading customer records from the Central KYC Records Registry (CKYCR), based on a Department of Revenue memorandum. The clarification addresses KYC verification responsibilities for NBFCs using CKYCR data.
**Key Points / Main Content**
* **General Information**
* Document Title: Reserve Bank of India (Non-Banking Financial Companies – Know Your Customer) Amendment Directions, 2025.
* Effective Date: Immediately.
* The amendment modifies the existing "Reserve Bank of India (Non-Banking Financial Companies – Know Your Customer) Directions, 2025."
* **Amendment to Paragraph 63**
* An explanation is inserted after sub-paragraph (9) in paragraph 63 of the original directions:
* The RE that last uploaded/updated KYC records in CKYCR is responsible for verifying customer identity/address.
* NBFCs downloading KYC records from CKYCR are not required to re-verify identity/address if records are current and compliant with the PML Act, 2002 / PML Rules, 2005.
* NBFCs remain responsible for all other aspects of CDD procedures except identity/address verification.
**Impact Analysis**
**Reporting Entities (RE) that Upload KYC data to CKYCR**
* **Impact**: The RE is responsible for ensuring verification of the authenticity of a customer’s identity and address.
* **Action Required**: Verify the KYC records that will be/are uploaded to the CKYCR.
**Non-Banking Financial Companies (NBFCs)**
* **Impact**: NBFCs downloading KYC records from CKYCR are not required to re-verify the customer's identity and address, provided the KYC records are current and compliant with the PML Act, 2002 / PML Rules, 2005, although the other aspects of CDD procedure should still be followed.
* **Action Required**: Ensure downloaded KYC records from CKYCR are current and compliant. Adhere to CDD procedures, except verification of identity and address.
Key Entities Referenced
Reserve Bank of India (Non-Banking Financial Companies – Know Your Customer) Directions, 2025: Original directions amended by this document.
Reserve Bank of India (Non-Banking Financial Companies – Know Your Customer) Amendment Directions, 2025: Amendment directions issued by RBI related to KYC for NBFCs.
Prevention of Money-Laundering Act, 2002: The original act that defines money laundering offences and sets frameworks to combat money laundering.
Reserve Bank of India Act, 1934: Act that establishes and governs the Reserve Bank of India.
CKYCR: Central KYC Records Registry referred to in the document.
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