**Executive Summary**
The Reserve Bank of India issued Amendment Directions on December 29, 2025, for Small Finance Banks regarding Know Your Customer (KYC) procedures. These directions, effective immediately, modify the existing directions of November 28, 2025, to clarify the responsibility of entities uploading and downloading customer records from the Central KYC Records Registry (CKYCR). The amendments address the verification of customer identity and address when using CKYCR data.
**Key Points / Main Content**
* **Amendment Directions:**
* These directions are called the "Reserve Bank of India (Small Finance Banks – Know Your Customer) Amendment Directions, 2025."
* These directions come into force with immediate effect.
* These directions modify the Reserve Bank of India (Small Finance Banks- Know Your Customer) Directions, 2025.
* **CKYCR Clarification:**
* An "Explanation" is added to paragraph 66 of the original directions to clarify responsibilities related to CKYCR.
* 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 address.
* Banks downloading and relying on KYC records from CKYCR are not required to re-verify identity or address if the records are current and compliant with the PML Act, 2002 / PML Rules, 2005.
* Downloading banks remain responsible for all other aspects of CDD procedures and provisions.
**Impact Analysis**
**Small Finance Banks**
* **Impact:** SFBs are impacted by the clarification on KYC responsibilities when using the CKYCR.
* **Action Required:** SFBs must adhere to the amended directions, ensuring that the RE that uploads/updates KYC records is responsible for verification. Downloading SFBs must ensure KYC records are current and compliant but are not required to re-verify already verified details.
**Reserve Bank of India**
* **Impact:** The RBI is responsible for enforcing these directions and ensuring compliance.
* **Action Required:** Oversee and monitor Small Finance Banks' adherence to the updated KYC norms and procedures.
**Customers of Small Finance Banks**
* **Impact:** Customers may experience a smoother KYC process if their data is already verified on CKYCR.
* **Action Required:** No direct action required from customers.
Key Entities Referenced
Reserve Bank of India (Small Finance Banks – Know Your Customer) Directions, 2025: The primary directions being amended by this document.
Prevention of Money-Laundering Act, 2002: Mentioned as the legislation in compliance with which the original Directions were issued.
Banking Regulation Act, 1949: Mentioned as a source of power for the current amendment.
CKYCR: Central KYC Records Registry, a database for customer KYC records relevant to the amendment regarding verification of downloaded records.
Reserve Bank of India: The issuing authority of the circular.
RBI/2025-26/164
DOR.AML.REC.368/14.01.007/2025-26 December 29, 2025
Reserve Bank of India (Small Finance Banks – Know Your Customer)
Amendment Directions, 2025
Reserve Bank had issued Reserve Bank of India (Small Finance Banks– 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 35A of the Banking
Regulation Act, 1949, the Banking Regulation Act (AACS), 1949, read with section 56 of
the Act ibid., 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, 1999,
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 (Small Finance Banks
– 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 (Small Finance Banks–
Know Your Customer) Directions, 2025 as under:(1) In paragraph 66, the following “Explanation” is being inserted after sub-paragraph
(10):
“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 bank 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 bank 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