The requirement for an individual Person Resident Outside India to be in India during digital onboarding has been relaxed when the client is located in a Financial Action Task Force (FATF) compliant country. The revised provisions take effect on December 3, 2026, for onboarding individual PROI clients other than clients in FATF non-compliant countries.

Who can use the revised process

An individual PROI client means a Non-Resident Indian, an Overseas Citizen of India or a foreign national. For a client located in a FATF-compliant country, an intermediary may accept KYC information and supporting documents through digital submission.

Records and documents

When a client approaches an intermediary to initiate an account-based relationship or update KYC, the intermediary must seek the client's PAN and CKYC ID, if available. It must then retrieve KYC information and documents from the KRA and CKYCRR. The intermediary must collect the PAN and verify it against the Income Tax Database without insisting on the original PAN or a copy.

The KRA must also verify the PAN and the name stated in the KYC form against the Income Tax Database and tag that attribute as validated in the KYC record. The intermediary must collect a copy of the client's passport and, where applicable, the OCI card. It must verify the passport if feasible. For proof of identity and address, the intermediary must collect one of the specified officially valid documents or deemed officially valid documents; the current address for an individual PROI client must be an overseas address.

Contact and video verification safeguards

The intermediary must verify the client's email address and, if feasible, mobile number through an OTP or another verifiable mechanism. If the mobile number cannot be verified, the intermediary must ensure that all communications are sent to the verified email address.

Where a specimen signature is submitted digitally, the client must provide a wet signature before the intermediary during Video In Person Verification (VIPV), and the intermediary must check that it matches the submitted signature. The VIPV infrastructure must have features for initiating random actions for the client to respond to, to establish that the interactions are not pre-recorded. The uninterrupted video recording must contain the client's live GPS coordinates and a date and time stamp using tamper-proof technology.

The infrastructure must prevent connections from spoofed IP addresses using VPNs or proxy servers. The captured IP address must originate in India or a FATF-compliant country and match the country specified by the client in the KYC form and the officially valid or deemed officially valid document. The client's photo must be clearly captured during VIPV and match the photo submitted in the form and the relevant document.

Data between the client's device and the intermediary's application or digital-platform hosting point must be encrypted end to end, and an authorised official of the intermediary must be present during VIPV. The infrastructure must use components to verify face liveness and detect spoofs; the liveness check must not exclude persons with special needs. The VIPV process is also subject to concurrent audit.

Portability and continuing responsibility

A KRA must tag individual KYC attributes as validated when they are verified against an official or source database. All KYC records can be shared with another intermediary, whether or not every individual attribute has been validated. An intermediary may also rely on KYC undertaken by an entity regulated by another financial sector regulator, based on the record obtained from CKYCRR.

The intermediary remains ultimately responsible for its clients' KYC, including enhanced due diligence appropriate to their risk profiles.

What continues to apply

For clients residing in FATF non-compliant countries, the existing KYC process continues to apply. KYC undertaken by intermediaries before the circular takes effect continues to be governed by the existing KYC provisions. Where an individual foreign national seeks registration as a Foreign Portfolio Investor, the specified FPI master circular or its amendments apply.

This article is general information, not legal advice.