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Every article (“Regulated Entity” or “RE”) adapted by the Reserve Bank of India (“RBI”) is appropriate to conduct chump due activity (“CDD”) on individuals (i) while establishing an account-based relationship; or (ii) while ambidextrous with a benign owner, an accustomed signatory, or a ability of advocate holder accompanying to any acknowledged entity. For this purpose, an RE charge attach to the guidelines as provided by RBI beneath the Know Your Chump (KYC) Directions, 2016 (“KYC Directions”) as adapted from time to time.



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In January 2020, with a appearance to use of agenda channels for the chump identification action (“CIP”) by REs, RBI adapted the KYC Directions, amidst added things, to additionally acquiesce ‘Video-based Chump Identification Process’ (“V-CIP”). The V-CIP is a consent-based alternating adjustment of establishing the customer’s character for chump onboarding. In fact, RBI’s contempo amendments to the KYC Directions indicates its intentions to abridge chump onboarding and to accommodate to the agreement of the ‘Digital India’ campaign. Though a few lapses may action , RBI is absolutely afterpiece to a complete online action for chump onboarding.  



A arbitrary of the CDD action currently followed by all REs as appropriate beneath the KYC Directions and some notable implications of the said action follows.



As per the KYC Directions, REs charge admission the afterward information/documents from individuals while administering CDD:

1. Aadhaar number; or

2. Affidavit of control of Aadhaar cardinal area offline analysis can be agitated out; or

3. Affidavit of control of Aadhaar cardinal area offline analysis cannot be agitated out; or

4. Any Officially Valid Document (“OVD”) (the RBI has accustomed Passport, Driving License, Voter ID, Pan Card, Aadhar Agenda and NREGA Job Agenda as OVDs), or the agnate e-document thereof, giving the capacity of character and address; and

5. Permanent Account Cardinal (PAN), or the agnate e-document thereof, or Anatomy No. 60 as authentic in Income-tax Rules, 1962; and

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6. abstracts certifying the client’s attributes of business and banking status, or the agnate e-documents thereof as may be appropriate by the RE.

The KYC Directions accept assigned assertive guidelines to be followed by REs back the above-mentioned documents/data are calm from a customer. Some of the key appearance are:

Aadhaar Number:

When a chump has voluntarily submitted his/her Aadhaar Cardinal to  banks or assertive added REs (which accept been acceptable to undertake affidavit of an individual’s Aadhaar Number), such banks or REs charge backpack out affidavit of the customer’s Aadhaar Number, appliance the e-KYC ability provided by the Unique Identification Ascendancy of India (“UIDAI”).

Alternatively, a chump may accept to accommodate affidavit of control of his Aadhaar agenda instead of appointment his Aadhaar Cardinal to the RE. In such an instance, the RE will be appropriate to advance by the afterward routes:

1. Area offline analysis can be agitated out: This avenue requires an alone to accomplish his/her digitally active Aadhaar capacity (using XML) by accessing the UIDAI portal. The capacity generated will accommodate name, address, photo, gender, date of birth, registered buzz cardinal (hidden), and registered e-mail abode (hidden). While it is binding for the alone to allotment his name and abode in the digitally-signed XML, he/she has the advantage to specify which of the bristles actual demographic capacity he/she chooses to allotment with the RE.  

Offline analysis helps to absolute abstracts sharing. In today’s apple area the aegis of abstracts is of ascendant importance, the offline analysis adjustment gives an alone the advantage to complete his/her onboarding action after accepting to acknowledge capacity of his/her Aadhaar Cardinal or allotment his/her biometrics with the RE. By accession bound advice in affiliation to a customer’s Aadhaar, REs absolute their acknowledgment to a abeyant abstracts breach.

2. Area offline analysis cannot be agitated out: Back offline analysis cannot be agitated out, Agenda KYC charge be conducted. Agenda KYC is a action of capturing alive photo of a chump with his/her OVD or the affidavit of control of Aadhaar, forth with the breadth and breadth of the area area such alive photo is actuality taken by the authorised administrator of the RE. Analysis through agenda KYC involves the afterward these steps:

• The RE gives above-mentioned sanction to a person/persons for admission to its agenda appliance for administering the agenda KYC;

• The RE authorizes an administrator to booty a alive photograph of the chump forth with breadth and breadth of the area area the said photograph is actuality taken;

• Once the capacity  collected    are entered in the assigned form, the chump has to affirm the advice by appliance the OTP generated;

• Lastly, the accustomed actuality  attests to the definiteness of these details.

While agenda KYC does abridge the onboarding process, the claim of a agent (i.e. a actuality accustomed by the RE) to complete the action defeats the purpose of accepting a agenda KYC. Ideally, a agenda action should appreciably abate the charge for animal interaction. RBI should accede introducing a apparatus that permits REs to acquiesce an alone to anon log into the RE’s agenda appliance and complete his/her agenda KYC instead of accepting a actuality accustomed by the RE to complete this process. This could potentially save added time and amount for REs.

Notably, RBI has additionally provided for an alternating advantage instead of administering agenda KYC. As per the KYC Directions, REs may additionally accept to admission a certified archetype of affidavit of control of Aadhaar or OVD and a contempo photograph. However, back a chump submits his/her Aadhaar as proof, the RE charge ensure that the customer’s Aadhaar Cardinal is redacted. While several REs may abort to accomplish this exercise (due to the aggregate of chump onboarding affidavit they action on a circadian basis), it would be absolutely bigger if RBI could acquaint a apparatus for an alone to ascertain that the RE has absolutely redacted capacity of the Aadhaar Cardinal back   a archetype of his/her Aadhaar is submitted.

OVD: If an alone prefers to accommodate any of the OVDs (instead of his/her Aadhaar) for the purpose of CDD, the KYC Directions accept assigned that the aforementioned action  as that for Aadhaar analysis be followed for OVD verification.

V-CIP: By the contempo alteration in January 2020, the RBI alien a consent-based V-CIP as addition adjustment for chump identification. As per this method, an RE opts for seamless, secure, real-time, accord based acoustic alternation with an alone to admission identification information, including the abstracts appropriate for CDD purpose, and to ascertain the accurateness of the advice furnished by the customer. The V-CIP charge be agitated out alone by an official accustomed by the RE. Notably, the KYC Directions accept assertive agreement that charge be adhered to by the REs back V-CIP is undertaken. These include:

1. The official accustomed by the RE to conduct the V-CIP charge almanac a video and abduction a photograph of the alone for identification and additionally admission the afterward identification information:

• Banks can use OTP based Aadhaar e-KYC affidavit or offline analysis of Aadhaar for identification. Additionally, banks may additionally use the casework of business correspondents to abetment in the V-CIP mechanism.

•  All added REs can alone accomplish offline analysis of Aadhaar for identification.

2. Alive area of the alone charge be captured to ensure that the chump is physically present in India.

3. REs charge abduction a bright angel of the PAN agenda displayed by the alone during the process, except in cases area the chump provides e-PAN.  The PAN capacity charge additionally be absolute from the database of the arising authority.

4. REs charge ensure that the video recording is stored in a defended address and bears a brand of the date and time.

REs accept accustomed the addition of V-CIP  as it allows alien onboarding, which saves time both for themselves and their customers.  

By the addition of these methods of analysis in the KYC Directions, RBI is acutely alive appear simplifying the CDD exercise. With these amendments,  the age-old assurance on bulky paper-work for the purpose of chump identification is actuality replaced with technology-based identification. In fact, several start-ups in India accept already developed agenda identification solutions. It  remains to be apparent whether RBI encourages REs to coact with these start-up entities to ensure achievement of V-CIP in a seamless manner; and what is more, whether RBI    streamlines the chump analysis action by introducing  a centralized agenda appliance for REs to complete chump onboarding.  

Kavya Katherine Thayil, the columnist is an Associate with J Sagar & Associates, a law firm. Views bidding are claimed and should not be construed as the official appearance of this publication.

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Last Updated: May 8th, 2020 by admin
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