Last Updated on: 29th September 2026 | Last Reviewed on: 29th September 2026
Key Takeaways at a Glance
- An OVD is used to establish identity and may also establish address where it contains the customer’s current address. Where the OVD does not contain an updated address, the applicable deemed OVD provisions may be used for current address verification, subject to their specific conditions.
- The RBI’s OVD definition specifies six documents. Other documents accepted for KYC purposes should not automatically be treated as OVDs. Deemed OVDs and other permitted documents under the PML Rules should be considered separately.
- The deemed-OVD address list is not identical across regulators. The admissibility of a bank account or Post Office savings bank account statement as address evidence differs across regulatory frameworks. The PFRDA and IFSCA frameworks contain provisions permitting such statements in specified circumstances, while the RBI deemed-OVD provision applicable to banks and NBFCs does not include a bank account statement in its corresponding list.
- The NREGA job card is an OVD for banks, NBFCs, securities market intermediaries and pension-sector customers. It does not appear in the IFSC guidelines’ definition.
- PAN is not an OVD. It is a separate, parallel requirement. Where the customer has no PAN, Form 60 is the substitute; it must be obtained in accordance with the applicable requirements.
- Aadhaar is not mandatory for KYC under the RBI Directions. Where a customer submits proof of possession of an Aadhaar number, and the applicable requirements require retention of a copy, the Aadhaar number must be redacted or blacked out in the retained copy in accordance with the applicable provisions.
- Where the OVD furnished by the customer does not contain the current address, the applicable deemed-OVD provision may be used for current-address verification, subject to its conditions. The customer must subsequently furnish an OVD containing the current address within the prescribed three-month period.
- Banks may open a Small Account subject to the conditions and limits prescribed in the RBI Directions and the PML Rules. NBFCs have a separate simplified procedure under their KYC Directions. These are reduced document regimes and are subject to prescribed operating limits and completion of full CDD within the applicable period.
- For entities, the operative question is rarely which certificate to collect. It is who the beneficial owners are and whether the entity qualifies for the listed-company exemption that switches the beneficial-owner exercise off.
- Periodic KYC updation is not necessarily a fresh document-collection exercise. Where there is no change in the KYC information, the RBI Directions permit a self-declaration. Where only the address has changed, a self-declaration of the new address is followed by positive confirmation within two months, subject to the applicable provisions and exceptions.
- Where the CDD documents available in the records have expired, the RBI Directions require the customer to be onboarded as a new customer in accordance with the applicable provisions.
- Transaction records must generally be retained for five years from the date of the transaction. Identity records must be retained for five years after the business relationship ends or the account is closed, whichever is later, as provided under Section 12(4) of the PMLA.
Quick Answer: What Are the KYC Documents Required in India?
For an individual commencing an account based relationship with a bank, the required KYC documents and information depend on the applicable identification route. Under the RBI framework, the bank may obtain Aadhaar number where the applicable conditions are met, proof of possession of Aadhaar number, an OVD or equivalent e-document containing identity and address details, or a KYC Identifier with explicit consent to download records from CKYCR.
PAN or the equivalent e-document or Form 60 is also required as provided under the applicable requirements. The bank may also require other documents relating to the nature of the business and financial status of the customer. A recent photograph is not a universal standalone document requirement for every individual onboarding route.
The six OVDs for an individual are passport, driving licence, proof of possession of Aadhaar number, Voter’s Identity Card issued by the Election Commission of India, NREGA job card duly signed by an officer of the State Government, and the NPR letter containing name and address.
For an entity, the documents depend on its legal form and the applicable regulatory framework. The regulated entity generally needs the entity’s constitutional and registration documents, PAN or Form 60 where applicable, information and documents relating to beneficial owners, and identification and verification of persons authorised to act on the entity’s behalf. The applicable beneficial ownership thresholds and exemptions must be assessed separately for each type of legal person or arrangement.
Sources: Reserve Bank of India (Commercial Banks – Know Your Customer) Directions, 2025, master direction reference RBI/DOR/2025-26/169, DOR.AML.REC.No.88/14.01.002/2025-26 dated 28 November 2025 and updated as on 29 December 2025, paragraph 5(1)(xiv) and paragraph 23; Prevention of Money-laundering (Maintenance of Records) Rules, 2005, rule 2(1)(d) and rule 9.
Why "KYC Documents" Is Really Three Lists, Not One
The KYC framework includes the OVD definition, along with separate deemed OVD provisions for specified identity and address purposes. These categories should not be treated as one interchangeable list. A document may also have a separate role under a regulator’s sector specific KYC framework.
Here is the structure that the law uses.
List | What it proves | Where it comes from | How wide it is |
1. Officially valid documents (OVDs) | Identity, and address as well if the document carries a current address | Rule 2(1)(d) of the PML (Maintenance of Records) Rules, 2005; paragraph 5(1)(xiv) of the RBI KYC Directions | Six documents. Closed list. |
2. Deemed OVDs for address | Address only, and only where the OVD produced does not carry a current address | Rule 9(18) of the PML Rules; the second proviso to rule 2(1)(d); proviso (b) to paragraph 5(1)(xiv) of the RBI Directions | Four to five documents, and the count varies by regulator. |
3. Deemed OVDs for identity under simplified measures | Identity only, and only where simplified due diligence is permitted | First proviso to rule 2(1)(d) of the PML Rules | Two additional categories of documents are available where simplified measures are applied for verifying the identity of the customer. |
Alongside those three lists sits a fourth requirement that is not a list at all and is not an OVD: PAN, or Form 60, where the customer has no PAN. It runs in parallel to the OVD requirement, not instead of it. A customer who hands over a passport has satisfied the OVD requirement and satisfied nothing about PAN.
A private rent agreement should not be treated as an OVD or as a universally accepted deemed OVD. Its acceptability depends on the applicable sector-specific KYC framework and circumstances. A Municipal tax receipt may qualify as a deemed OVD for the limited purpose of current address verification where the prescribed conditions are satisfied. A gazetted officer’s letter with an attested photograph is a separate document recognised for identity verification where the applicable simplified measures permit its use.
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The Six Officially Valid Documents (OVDs)
The definition is worth reading in the regulator’s own words before it is paraphrased, because the paraphrases in circulation are where the errors creep in. Paragraph 5(1)(xiv) of the Reserve Bank’s KYC Directions defines an officially valid document as:
“the passport, the driving licence, proof of possession of Aadhaar number, the Voter’s Identity Card that the Election Commission of India issues, the job card that NREGA issues and an officer of the State Government duly signs, and the letter that the National Population Register issues containing details of name and address.”
The RBI Directions currently list six OVDs for the commercial-bank framework. The parent definition in rule 2(1)(d) of the PML Rules contains related wording and also provides for any other document as may be notified by the Central Government in consultation with the Regulator. The article should therefore describe the six documents as the current list under the RBI Directions, rather than implying that the statutory definition can never change.
# | Officially valid document | Proves identity | Proves address | Practical notes |
01 | Passport | Yes | Yes, if the address page is current | The most complete single OVD. Carries photograph, name, date of birth, address and, for foreign nationals, the visa position. |
02 | Driving licence | Yes | Yes, if the address printed is current | An expired driving licence is not a valid OVD. |
03 | Proof of possession of Aadhaar number | Yes | Yes, if the Aadhaar address is current | Must be submitted in a form issued by the Unique Identification Authority of India. The number must be redacted in the copy retained. |
04 | Voter’s Identity Card issued by the Election Commission of India | Yes | Yes, if the address is current | If document address changes, applicable deemed OVD provisions apply and are used for current address verification. |
05 | NREGA job card signed by an officer of the State Government | Yes | Yes, if the address is current | The signature of the State Government officer is part of the definition. An unsigned card does not qualify. |
06 | Letter issued by the National Population Register containing details of name and address | Yes | Yes | The definition itself requires the letter to contain name and address, so a letter without both is outside the definition. |
01. Passport
A passport is one of the most comprehensive OVDs and can provide identity and other personal details, including an address where the passport contains an address. It is particularly important for non-resident customers, although the precise documentary requirements depend on the customer’s status and the applicable regulatory framework. Two points are worth flagging for onboarding teams.
02. Driving Licence
A driving licence can establish identity and address where it contains the relevant details and is valid for reliance under the applicable KYC framework. The Directions specifically address expired CDD documents at periodic updation. Where the CDD documents available in the bank’s records have expired, the bank is required to undertake the KYC process equivalent to that applicable to onboarding a new customer.
03. Proof of Possession of Aadhaar Number
The phrasing is deliberate, and it matters. The OVD is “proof of possession of Aadhaar number”, rather than Aadhaar being treated as a separate OVD category. Where a customer submits proof of possession of Aadhaar number as an OVD, the RBI Directions permit the customer to submit it in a form issued by the Unique Identification Authority of India, subject to the applicable verification requirements.
Two specific Aadhaar safeguards are particularly important. Where the customer submits proof of possession of Aadhaar number and Aadhaar authentication is not required, the Aadhaar number must be redacted or blacked out through appropriate means in the copy retained by the regulated entity. In the securities market, SEBI also requires registered intermediaries not to store or save the clients Aadhaar number.
04. Voter’s Identity Card Issued by the Election Commission of India
The Voters Identity Card, commonly known as the EPIC, is an officially valid document when issued by the Election Commission of India. The issuer is an important part of the definition. An electoral roll extract, voter list entry or other electoral document should not be treated as the Voters Identity Card specified in the OVD definition.
05. NREGA Job Card Signed by an Officer of the State Government
The NREGA job card is an officially valid document when issued under NREGA and duly signed by an officer of the State Government. It is one of the documents recognised under the KYC framework and can be used where the customer does not have another OVD, subject to the applicable KYC requirements.
06. Letter Issued by the National Population Register
The National Population Register letter is an officially valid document when it contains the customers name and address. These details are expressly required by the OVD definition. The letter must still be subject to the applicable KYC verification requirements.
Why This List Is Closed, and What That Means Operationally
A regulated entity cannot treat a PAN card as an officially valid document because PAN is not included in the current OVD definition. PAN is a separate requirement under the applicable KYC framework and, where applicable, under Rule 114B of the Income-tax Rules, 1962. An employer identity card is not an OVD merely because it may be relevant under the limited simplified measures applicable in specified circumstances. A rent agreement is also not an OVD under the PML Rules definition, although a particular sectoral KYC framework may permit other forms of address evidence in specified circumstances.
One Point on Names That Changed
The applicable KYC provisions address situations where the customers name has changed after an OVD was issued. Where the name has subsequently changed, the document can continue to qualify as an officially valid document if the change is supported by a marriage certificate issued by the State Government or a Gazette notification indicating the change of name. The OVD therefore does not necessarily need to be reissued in the customers new name, provided the required supporting document is furnished.
Deemed OVDs: The Address-Only Fallback Most Pages Get Wrong
The documents treated as deemed officially valid documents should not be presented as though they are ordinary OVDs. They are recognised for a specific purpose under the applicable KYC framework and in defined circumstances. Utility bills and certain other documents may therefore be accepted as address documents where the prescribed conditions are satisfied, but they do not become OVDs for all purposes.
The relevant trigger under the RBI provision is that the OVD furnished by the customer does not contain an updated address. In that situation, the prescribed additional documents may be used for the limited purpose of establishing the current address, subject to the applicable requirements under RBI KYC provisions and Rule 9 of the PML Rules. These documents should not be treated as a general substitute for an OVD in every KYC situation.
The Deemed-OVD Address List Applied to Banks and NBFCs
Where the trigger condition is met, the following documents are deemed to be officially valid documents for the limited purpose of proving the current address.
# | Deemed OVD (address only) | Condition attached |
(i) | Utility bill of any service provider: electricity, telephone, post-paid mobile phone, piped gas or water bill | Not more than two months old. This is the only item with an age limit, and it is the item most often accepted stale. |
(ii) | Property or Municipal tax receipt | No age limit stated in the provision. |
(iii) | Pension or family Pension Payment Orders (PPOs) issued to retired employees by Government Departments or Public Sector Undertakings | Only if they contain the address. A PPO without an address does not qualify. |
(iv) | Letter of allotment of accommodation from an employer, and leave and licence agreements with such employers allotting official accommodation | The employer must be a State or Central Government Department, a statutory or regulatory body, a public sector undertaking, a scheduled commercial bank, a financial institution or a listed company. A private unlisted employer’s letter does not qualify. |
The Two-Month Rule, and the Illustration the Regulator Gives
The utility bill used as a deemed OVD must not be more than two months old. A three month old electricity bill therefore does not satisfy the specified age condition. The RBI Directions illustrate the address situation by referring to a customer staying in Chennai whose OVD contains an address in New Delhi. The illustration permits the use of a deemed OVD for the limited purpose of proof of current address, subject to submission of an OVD containing the current address within three months.
The Three-Month Cure
The RBI Directions require the customer to submit an OVD containing the current address within three months of submitting the documents used as the deemed OVD for the limited purpose of proof of address. The three months should therefore be tracked as a compliance deadline, with appropriate reminders and escalation procedures built into the institution’s onboarding or KYC systems.
Where the Deemed-OVD List Diverges Between Regulators
Document | RBI (banks, NBFCs) | PML Rules, rule 9(18) | PML Rules, second proviso to rule 2(1)(d) | PFRDA (pension) | IFSC guidelines |
Utility bill, not more than two months old | Yes | Yes | Yes | Yes | Yes |
Property or Municipal tax receipt | Yes | Yes | Yes | Yes | Yes |
Bank account or Post Office savings bank account statement | No | No | Yes, where conditions for simplified measures and limited proof of address are satisfied | Yes | Yes, including a statement of a foreign bank |
Pension Payment Orders containing the address | Yes | Yes | Yes | Yes | Yes |
Employer allotment letter / leave and licence with a qualifying employer | Yes | Yes | Yes | Yes | Yes |
Deemed OVDs for Identity: The Third List
The first proviso to rule 2(1)(d) creates a separate and much narrower category. Where simplified measures are applied for verifying the identity of the customer, two further documents are deemed to be officially valid documents:
- An identity card with the applicant’s photograph issued by Central or State Government Departments, Statutory or Regulatory Authorities, Public Sector Undertakings, Scheduled Commercial Banks or Public Financial Institutions.
- A letter issued by a gazetted officer with a duly attested photograph of the person.
Note what this list is not. It is not an alternative that a customer can elect. These documents are available where simplified measures are applied for verifying the identity of the customer, subject to the applicable regulatory framework and the regulated entity’s risk based approach. SEBI’s KYC master circular carries the same two documents in its proof-of-identity provisions, alongside the rule 2(d) OVDs, and the IFSC guidelines carry them in identical terms.
The reason this third list is so often merged into the others is that an employer identity card feels like an obviously reasonable identity proof. It is, in ordinary life. In KYC, it is admissible in one defined circumstance and inadmissible in every other, and the difference between those two states is a documented risk determination sitting in the customer file.
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PAN, Form 60 and the Documents That Sit Beside the OVD
Paragraph 23 of the RBI Directions sets out what a regulated entity obtains from an individual at the commencement of an account-based relationship. Reading it as a list makes the architecture obvious: the OVD is one input among several, not the whole requirement.
Input | Requirement | Source |
Aadhaar number | Obtained where the customer is desirous of receiving a benefit or subsidy under a scheme notified under section 7 of the Aadhaar Act, or where the customer decides to submit it to a bank notified under section 11A of the PMLA | Paragraph 23(a)(i) |
Proof of possession of Aadhaar number | Where offline verification can be carried out | Paragraph 23(a)(ii) |
Proof of possession of Aadhaar number, or any OVD, or the equivalent e-document | Where offline verification cannot be carried out | Paragraph 23(a)(iii) |
KYC Identifier | Where the customer submits a KYC Identifier with explicit consent to download records from the Central KYC Records Registry | Paragraph 23(a)(iv) |
PAN, or the equivalent e-document, or Form No. 60 | Obtained in every case, as defined in the Income-tax Rules, 1962 | Paragraph 23(b) |
Recent photograph | Obtained from the individual | Paragraph 23 |
Other documents on the nature of business and financial status | Such other documents as the regulated entity may require pertaining to the nature of business and financial status of the customer | Paragraph 23(c) |
PAN Is Not an OVD, and Form 60 Is Not Optional
PAN is not included in the RBI definition of an officially valid document. It is a separate requirement under the applicable KYC and income tax framework. Paragraph 76 of the RBI Directions requires PAN or the equivalent e-document to be obtained and verified for transactions covered by the applicable income tax requirements and provides for Form 60 for persons who do not have PAN or the equivalent e-document. The income tax framework applicable from 1 April 2026 should also be considered where the transaction falls under the Income Tax Act, 2025 and Income Tax Rules, 2026.
The reference to “PAN or Form 60” does not make Form 60 a general alternative for a customer who has a PAN but chooses not to provide it. The RBI Directions require PAN or the equivalent e-document, or Form 60 from persons who do not have PAN, in accordance with the applicable Income-tax Rules. Form 60 should therefore not be presented as an alternative available merely because a customer does not wish to disclose an existing PAN.
Existing Customers Without PAN, and What "Temporarily Cease Operations" Means
Paragraph 43 requires the bank to obtain PAN or the equivalent e document or Form 60 from existing customers by the date notified by the Central Government. If the customer fails to provide the required document, the bank shall temporarily cease operations in the account after giving accessible notice and a reasonable opportunity to be heard.
The bank must provide appropriate relaxations for customers who are unable to provide PAN or the equivalent e document or Form 60 because of injury, illness, infirmity due to old age or similar causes, and such accounts are subject to enhanced monitoring. In the case of asset accounts such as loan accounts, only credits are permitted while operations are temporarily ceased.
The Recent Photograph
A recent photograph is required in specified KYC processes rather than as a universal standalone document for every individual customer. For example, the RBI Digital KYC process requires the authorised officer to capture a live photograph of the customer. A Small Account also requires a self attested photograph from the customer. The bank’s internal KYC policy may additionally prescribe a recent photograph as an exceptional measure for periodic KYC updation.
Documents on the Nature of Business and Financial Status
Paragraph 23(6) allows the regulated entity to require such other documents pertaining to the nature of the business and the financial status of the customer as it considers necessary. This is the clause that supports salary slips, income tax returns, audited accounts and source-of-funds evidence.
Aadhaar: What You Must Do, What You Must Not Do, and What Is Optional
Route | What it is | What the customer provides | Key constraint |
Aadhaar authentication (e-KYC) | Online authentication with the Unique Identification Authority of India | Aadhaar number and biometric or OTP consent | Available only to entities permitted to authenticate: section 11A notified entities, and section 7 benefit or subsidy cases |
Offline verification | Verification of the Aadhaar XML or Secure QR code without contacting the Authority online | The offline verification file or QR code | Available more widely than online authentication |
Proof of possession as an OVD | The Aadhaar document used as a document, like any other OVD | A form issued by the Unique Identification Authority of India | Aadhaar number must be redacted in the retained copy |
Biometric e-KYC including Face Authentication | Aadhaar Face Authentication performed by a bank official, business correspondent or business facilitator | Presence and facial biometric | Recognised in Explanation 2 to paragraph 23 |
Aadhaar Is Not Mandatory
Explanation 4 to paragraph 23 of the RBI Directions states that the Aadhaar number is not mandatory for purposes of KYC. Subject to the applicable identification route and requirements, an individual may use the other permitted identification documents or the applicable KYC Identifier route instead.
Redaction Is an Obligation, Not a Courtesy
Where the customer submits proof of possession of an Aadhaar number, and the applicable provisions require a retained copy, the Aadhaar number must be redacted or blacked out through appropriate means where Aadhaar authentication is not required. In the securities market, SEBI’s KYC framework separately provides that registered intermediaries shall not store or save the client’s Aadhaar number in their systems.
The insurance guidelines require insurers to redact or black out the Aadhaar number as per the extant provisions, and where verification is performed through a video-based process, they contemplate capture of only the redacted Aadhaar number, being the last four digits.
The V-CIP provisions in the RBI Directions carry the same requirement at paragraph 27(2)(vii). Any document repository that holds full Aadhaar numbers in scanned KYC packs is carrying an unredacted-data problem that predates any question about whether the KYC itself was adequate.
The Limits on OTP-Based Aadhaar e-KYC
Where an account is opened using Aadhaar OTP based e KYC in non face to face mode, paragraph 25 imposes specified limits and conditions. The aggregate balance of the customer’s deposit accounts must not exceed Rs 1 lakh, aggregate credits in a financial year must not exceed Rs 2 lakh, and for borrowal accounts only term loans may be sanctioned subject to the prescribed annual limit of Rs 60,000. If the prescribed limits are breached, the account cannot continue to operate until the required full CDD is completed.
Accounts opened using Aadhaar OTP based e KYC in non face to face mode cannot operate for more than one year unless the bank completes identification under paragraph 23 or the applicable V CIP provisions. If the bank does not complete the required CDD within one year, a deposit account must be closed immediately, and no further debits may be permitted in a borrowal account. The account must be flagged in the Central KYC Records Registry as an Aadhaar OTP-based e-KYC account.
One specific provision applies to periodic KYC updation. Paragraph 42(3)(vi) permits the bank to use Aadhaar OTP based e KYC in non face to face mode for updation or periodic updation, and the conditions specified in paragraph 25 do not apply to such updation or periodic updation.
Where the current address differs from the address in Aadhaar, paragraph 42(3)(vii) also provides that positive confirmation is not required in this Aadhaar OTP based updation route, subject to the specified condition concerning the mobile number used for Aadhaar authentication.
KYC Documents for Foreign Nationals, NRIs, Foreign Students and Foreign Investors
The OVD list was drafted around documents issued by Indian authorities. Once the customer is not an Indian resident, the framework switches to a set of specific carve-outs. These are the provisions most often missing from generic document lists, and they are the ones that generate the largest volume of rejected files, because the failure is usually structural rather than a single missing paper.
Foreign Nationals: The Address Problem
A passport is an OVD under the RBI framework. Where the OVD presented by a foreign national does not contain address details, the RBI Directions provide that documents issued by government departments of foreign jurisdictions and a letter issued by the Foreign Embassy or Mission in India shall be accepted as proof of address.
Proviso (d) to paragraph 5(1)(xiv) of the RBI Directions addresses this directly. Where the officially valid document presented by a foreign national does not contain the details of address, the following are accepted as proof of address:
Non-Residents and Certified Copies: The Closed List of Certifying Authorities
A customer who is outside India cannot walk into a branch with originals. The mechanism that solves this is the certified copy, and paragraph 5(1)(v) of the Directions defines it. Ordinarily a certified copy means comparing the copy of the officially valid document so produced by the customer with the original and recording it on the copy by the authorised officer of the regulated entity. Where records are authenticated outside India, the Prevention of Money-laundering (Manner of Receiving the Records Authenticated Outside India) Rules, 2005 govern the manner of receipt.
# | Authority competent to certify for NRIs and PIOs |
1 | Authorised officials of overseas branches of Scheduled Commercial Banks registered in India |
2 | Branches of overseas banks with whom Indian banks have correspondent relationships |
3 | Notary Public abroad |
4 | Court Magistrate |
5 | Judge |
6 | Indian Embassy or Consulate General in the country where the non-resident customer resides |
Foreign Students: The 30-Day Window
Paragraph 48 of the RBI Directions creates one of the few genuinely time-boxed document regimes in the framework, and it is worth setting out precisely because it is a self-contained answer to a question a lot of banks handle badly.
- Foreign remittances into the account must not exceed USD 1,000.
- The aggregate of withdrawals must not exceed Rs 50,000 during the 30-day period.
Foreign Portfolio Investors: Simplified KYC on a Category Matrix
Paragraph 49 of the RBI Directions sets out simplified KYC norms for eligible Foreign Portfolio Investors opening accounts with authorised dealer banks for investment under the Portfolio Investment Scheme. The prescribed KYC documents differ according to FPI Category I, Category II and Category III, and the requirements are subject to the applicable Income tax FATCA and CRS requirements.
SEBI’s Additional Rules for Non-Residents and Foreign Nationals
Customer situation | Document position | Instrument |
Foreign national, OVD carries no address | Foreign Government department documents, or a letter from the Foreign Embassy or Mission in India, accepted as proof of address | RBI Directions, proviso (d) to para 5(1)(xiv); PML Rules, rule 2(1)(d) |
NRI or PIO unable to present originals | Certified copy from one of six named authorities | RBI Directions, para 5(1)(v) |
Foreign student, newly arrived | Passport with visa and immigration endorsement, photograph, admission letter; local address declared and verified within 30 days; USD 1,000 remittance cap and Rs 50,000 withdrawal cap in the interim | RBI Directions, para 48 |
Foreign portfolio investor | Simplified KYC by FPI category | RBI Directions, para 49 |
Non-resident securities-market client | Passport, PIO Card or OCI Card, plus mandatory overseas address proof; English translation of foreign-language address proof; proof of both correspondence and permanent address where they differ | SEBI KYC master circular, paras 20 to 23 |
Foreign national in an International Financial Services Centre | Foreign national identity card and voter identification card treated as officially valid documents | IFSC guidelines, proviso to clause 1.3.30 |
For a document-by-document treatment of the identity and address positions inside an International Financial Services Centre, see our companion pieces on identity verification documents and address verification documents for individuals, and on documents required for identity verification of a legal person. Those pages are the jurisdiction variants of the tables on this page.
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KYC Documents for Entities: Companies, Firms, Trusts and Everything Else
Entity KYC is where the “list of documents” framing breaks down most completely. There is no single entity list. Paragraphs 30 to 38 of the RBI Directions run a separate document set for each legal form, and each set is only the first of three layers.
Every entity file has the same three-layer structure:
- Layer one, the entity itself. Constitutional and registration documents specific to the legal form, plus PAN or Form 60 of the entity.
- Layer two, the beneficial owners. Individual CDD for each natural person identified as a beneficial owner, using the applicable identification and verification requirements for individuals, together with the other information and documents required under the applicable legal and regulatory framework.
- Layer three, the authorised signatories. Full individual CDD for every person holding an attorney to transact on behalf of the entity, together with the instrument granting that authority.
A file that has layer one and no layers two and three is the most common entity KYC deficiency in the market. It looks complete because the folder is thick, and it is missing the part the law actually cares about.
Sole Proprietary Firms: CDD of the Proprietor Plus Two Activity Proofs
# | Activity proof for a sole proprietary firm |
1 | Registration certificate, including the Udyam Registration Certificate issued by the Government |
2 | Certificate or licence issued by the municipal authorities under the Shop and Establishment Act |
3 | Sales and income tax returns |
4 | CST, VAT or GST certificate, including the GST identification number provided or issued |
5 | Certificate or registration document issued by the Sales Tax, Service Tax or Professional Tax authorities |
6 | Importer Exporter Code issued to the proprietary concern by the office of the Director General of Foreign Trade, or a licence, certificate of practice or registration document issued in the name of the proprietary concern by a professional body incorporated under a statute |
7 | Complete Income Tax Return in the name of the sole proprietor where the firm’s income is reflected, duly authenticated and acknowledged by the Income Tax authorities |
8 | Utility bills such as electricity, water or landline telephone bills |
Companies
For a company, paragraph 33 requires certified copies of the following.
# | Document for a company |
1 | Certificate of incorporation |
2 | Memorandum and Articles of Association |
3 | Permanent Account Number of the company |
4 | A resolution from the Board of Directors and power of attorney granted to its managers, officers or employees to transact on its behalf |
5 | Documents relating to beneficial owners, managers, officers or employees holding an attorney to transact on the company’s behalf, being the documents specified for individuals |
Partnership Firms
Paragraph 34 requires certified copies of the following for a partnership firm.
# | Document for a partnership firm |
1 | Registration certificate |
2 | Partnership deed |
3 | Permanent Account Number of the partnership firm |
4 | Documents relating to beneficial owners, managers, officers or employees holding an attorney to transact on its behalf, being the documents specified for individuals |
Trusts
Paragraph 35 requires certified copies of the following for a trust.
# | Document for a trust |
1 | Registration certificate |
2 | Trust deed |
3 | Permanent Account Number or Form No. 60 of the trust |
4 | Documents relating to beneficial owners, managers, officers or employees holding an attorney to transact on its behalf, being the documents specified for individuals |
Unincorporated Associations and Bodies of Individuals
Paragraph 36 covers unincorporated associations and bodies of individuals, and requires the following.
# | Document for an unincorporated association or body of individuals |
1 | Resolution of the managing body of such association or body of individuals |
2 | Permanent Account Number or Form No. 60 of the unincorporated association or body of individuals |
3 | Power of attorney granted to the person transacting on its behalf |
4 | Documents relating to beneficial owners, managers, officers or employees holding an attorney to transact on its behalf, being the documents specified for individuals |
5 | Such information as may be required by the regulated entity to collectively establish the legal existence of such an association or body of individuals |
Other Juridical Persons
Paragraph 37 is the residual category, covering societies, universities and local bodies including village panchayats. The file requires documents showing the person authorised to act, the documents specified for individuals in respect of that person, and such documents as establish legal existence.
Beneficial Owner Documents and the Thresholds That Trigger Them
Layer two of every entity file turns on identifying the beneficial owner, and paragraph 5(1)(iv) sets the thresholds. Getting this wrong is the single most consequential entity KYC error, because it determines whether individual document sets are collected at all.
Entity type | Beneficial owner threshold | Fallback where no owner is identified |
Company | A natural person who, whether acting alone or together, or through one or more juridical persons, has a controlling ownership interest of more than 10 per cent of shares or capital or profits, or who exercises control through other means | The senior managing official |
Partnership firm | A natural person who, whether acting alone or together, or through one or more juridical persons, has ownership of or entitlement to more than 10 per cent of the capital or profits | The senior managing official |
Unincorporated association or body of individuals | A natural person who, whether acting alone or together, or through one or more juridical persons, has ownership of or entitlement to more than 15 per cent of the property or capital or profits | The senior managing official |
Trust | The author of the trust, the trustee, the beneficiaries with 10 per cent or more interest in the trust, and any other natural person exercising ultimate effective control over the trust through a chain of control or ownership | Not applicable; the categories are enumerated |
The Listed-Entity Exemption: When Beneficial Owner Documents Are Not Required at All
Paragraph 38(1) provides that where the customer or the owner of the controlling interest is an entity listed on a stock exchange in India, an entity resident in a jurisdiction notified by the Central Government and listed on a stock exchange in that jurisdiction, or a subsidiary of such a listed entity, it is not necessary to identify and verify the identity of shareholders or beneficial owners of such entities. The exemption applies only in the circumstances specified in the provision.
The requirement to identify and verify beneficial owners does not apply in the circumstances specified under the applicable PML Rules, including where the customer or the owner of the controlling interest:
- Is a company listed on a stock exchange in India.
- The entity is resident in a jurisdiction notified by the Central Government and listed on a stock exchange in that jurisdiction; or
- The entity is a subsidiary of any such listed entity.
The regulated entity should document the basis on which the exemption is applied.
Authorised Signatories: Layer Three
The requirements concerning persons authorised to act on behalf of an entity vary according to the legal form. The applicable provisions generally require documents specified for individuals in respect of relevant beneficial owners and persons authorised to transact on behalf of the entity, together with the applicable authority documents and other information prescribed for that legal form.
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Opening an Account with No OVD at All: Small Accounts and Simplified Procedures
Every article on KYC documents in India starts from the assumption that the customer has documents. A meaningful number do not, and the framework has two answers for them. Both are underused, and both are frequently described inaccurately as “no KYC” accounts, which they are not. They are accounts opened on a reduced document set in exchange for hard operating caps.
The Small Account: Banks
Paragraph 28 of the RBI Directions, read with rule 9(5) of the PML Rules, provides for a Small Account as an alternative to the normal individual CDD route. The account is subject to an aggregate credit limit of Rs 1 lakh in a financial year, an aggregate withdrawal and transfer limit of Rs 10,000 in a month and a balance limit of Rs 50,000 at any point in time, subject to the specified exception for certain government related deposits.
The bank must obtain a self attested photograph, and the designated officer must certify the customer’s signature or thumb impression. The account is initially operational for 12 months and may be extended for another 12 months where the account holder applies for an OVD and provides evidence of the application. The bank must review the relaxation provisions after 24 months.
The NBFC Divergence: A Simplified Procedure, not a Small Account
Parameter | Bank small account (RBI banks Directions, para 28) | NBFC simplified procedure (RBI NBFC Directions, para 28) |
Name of the route | Small Account | Simplified procedure for opening accounts |
Balance cap | Not more than Rs 50,000 at any point of time | Balances not exceeding Rs 50,000 |
Credit cap | Aggregate credits not more than Rs 1 lakh in a financial year | Total credit in the account not exceeding Rs 1 lakh in a year |
Monthly withdrawal cap | Rs 10,000 per month | Not stated in the same terms |
Time limit to complete full CDD | 12 months, extendable by 12 on evidence of having applied for an OVD | 12 months, within which the applicable CDD or V-CIP identification requirements must be completed in accordance with the RBI Directions applicable to NBFCs. |
Customer notification triggers | Not framed as notification triggers | Customer to be notified when the balance reaches Rs 40,000 or the total credit in a year reaches Rs 80,000, KYC documents should be submitted, failing which operations will be stopped when the prescribed limits are exceeded |
Foreign remittance | Not permitted until full identity is established | Not framed in the same terms |
When None of This Applies
The small-account routes exist for customers who genuinely lack documents, not as a shortcut for an incomplete file. The caps bind from day one, and a capped population must reach full customer due diligence within twelve months.
How KYC Documents Are Submitted and Verified
Having the right document is only one part of the requirement. The other part is the way the document is submitted and the verification performed by the regulated entity. The applicable KYC process determines what additional verification or documentation is required.
Original Seen and Verified, and the Certified Copy
Where a certified copy is required, the authorised officer compares the copy of the applicable OVD or proof of possession of Aadhaar, where applicable, with the original and records the comparison on the copy. This is the process described by the RBI Directions for a certified copy. The applicable KYC method may instead permit an equivalent e-document, Digital KYC, V-CIP or retrieval of KYC records from CKYCR.
Equivalent e-Documents and DigiLocker
- The document must be issued by the issuing authority. A scan the customer made of their own passport is not an equivalent e-document. An e-passport file issued by the passport authority that satisfies the regulatory definition is.
- It must carry the issuing authority’s valid digital signature. A scanned copy created by the customer is not an equivalent e-document merely because it is in electronic form. Documents issued through DigiLocker can also qualify where they meet the applicable requirements.
Digital KYC Under Paragraph 24
- The regulated entity develops an application for digital KYC, made available at customer touch points and accessible only to authorised officials.
- The customer visits the location of the authorised official, or the official visits the customer’s location, for the purpose of the process.
- A live photograph of the customer is taken by the authorised official, and the system embeds a watermark in it containing the Customer Application Form number.
- The application captures latitude and longitude of the location where the live photograph is taken.
- The photograph carries the name of the authorised official, the employee code, and the date and timestamp.
- The live photograph is taken against a white background with no other person in the frame.
- The customer provides an OTP as their signature on the completed form, and the authorised official provides a declaration about the process having been carried out in accordance with the requirement.
- The authorised officer verifies that the information in the captured document matches the information entered in the Customer Application Form, that the customer’s live photograph matches the photograph in the document, and that the required details in the Customer Application Form have been properly completed.
Video-Based Customer Identification Process (V-CIP)
Paragraphs 26 and 27 govern V-CIP, which is the route that has done the most to change onboarding economics in India. For document purposes, the relevant provision is paragraph 27(2)(vi), which permits identification through any one of four routes:
The Central KYC Records Registry: The Route That Can Avoid Repeated Submission of the Same KYC Records
Obligation | Requirement | Clause |
Initial upload | KYC records to be uploaded within 10 days of the commencement of the account-based relationship | Para 65(2), reflecting rule 9(1A) |
Communicating the identifier | The KYC Identifier must be communicated to the customer | Para 65(7) |
Incremental updates | Updated information to be furnished to the Registry within seven days | Para 65(8), reflecting rule 9(1C) |
No repeat requests | Where the regulated entity retrieves KYC records from CKYCR using the KYC Identifier, it shall not require the customer to submit the same KYC records or information again, subject to the specified exceptions | Para 65(10) |
Responsibility for verification | The regulated entity that last uploaded or updated the customer’s KYC records in the CKYCR is responsible for verifying the customer’s identity and address, as applicable. A bank downloading and relying on current and compliant KYC records from CKYCR is not required to re-verify the authenticity of the customer’s identity or address. The downloading bank remains responsible for all other aspects of the customer due diligence requirements, except that verification of identity and address. | Explanation to para 65, inserted with effect from 29 December 2025 |
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KYC Documents Required for Re-KYC (Periodic Updation)
Re-KYC does not necessarily require a fresh document set in every case. The RBI Directions provide different procedures depending on whether there has been no change in KYC information, only a change of address, or a more substantive change requiring updated CDD. The applicable procedure should therefore be determined by the nature of the change and the institution’s approved KYC policy.
When Re-KYC Falls Due
Risk category | Periodic updation interval |
High risk | At least once every two years |
Medium risk | At least once every eight years |
Low risk | At least once every ten years |
Where Nothing Has Changed: A Self-Declaration Is Enough
Paragraph 42(3)(i) is the provision that should be quoted back to every branch that asks a ten-year customer to bring a fresh passport copy. Where there is no change in the KYC information, a self-declaration from the customer is obtained to that effect.
No fresh document is required where there is no change in the KYC information, subject to the applicable provisions. The regulated entity obtains a self-declaration through the permitted channels, including registered email, registered mobile number, digital channels, letter or other permitted means. An institution may adopt additional exceptional measures where its Board approved KYC policy permits them.
Where Only the Address Has Changed: Declaration Plus Two-Month Confirmation
Paragraph 42(3)(ii) applies where there is a change only in the customer’s address details. The customer gives a self-declaration of the new address, and the entity verifies the declared address through positive confirmation within two months. The entity may also obtain an OVD, deemed OVD or equivalent e-document for proof of the declared address where this requirement is specified in its Board-approved internal KYC policy.
Minors Becoming Majors
Paragraph 42(3)(iv) of the NBFC KYC Directions 2025 requires the NBFC to obtain fresh photographs when a customer whose account was opened while they were a minor becomes a major. At that time, the NBFC must also ensure that CDD documents as per the current CDD standards are available with the NBFC. Wherever required, the NBFC may carry out fresh KYC of such customers upon becoming a major.
Expired Documents Mean a New Onboarding
Paragraph 42(5)(i) states the position bluntly: where the customer due diligence documents available in the records have expired, the customer is to be onboarded as a new customer.
The 30-Day Submission Rule and the Reminder Discipline
Two obligations at the operational edge of paragraph 42 tend to be overlooked because they read as administration rather than compliance.
Paragraph 42(6) requires the customer to submit updated documents within 30 days. That is an obligation on the customer, and it is a term the institution should communicate at the point of the request rather than leaving it implicit.
Paragraph 42(7) requires the entity to give at least three advance intimations before the due date, including at least one intimation by letter, and at least three reminders after the due date to customers who have not complied, including at least one reminder by letter. The issue of these intimations and reminders must also be recorded in the entity’s system for audit trail. The requirement was to be implemented not later than 1 January 2026.
Re-KYC scenario | Documents required | Additional step | Clause |
No change in KYC information | None. Self-declaration only | Declaration may be received through digital channels | 42(3)(i) |
Address changed, nothing else | Self-declaration of the new address | Positive confirmation within two months | 42(3)(ii) |
Address changed, entity policy requires proof | Copy of an OVD or deemed OVD for address | Only where the board-approved policy so specifies | 42(3)(iii) |
Minor becomes a major | Fresh photographs | CDD at current standards | 42(3)(v) |
CDD documents expired | Full new-customer document set | Onboard as a new customer | 42(5)(i) |
PAN held on record | PAN | Verify from the database of the issuing authority | 42(5)(ii) |
Any updation completed | Acknowledgement to the customer | Intimation of the updation | 42(5)(iii) |
Non-individual customers | Per the applicable entity list | Periodic updation on the same risk cycle | 42(4) |
KYC Documents by Regulator: Where the Rules Actually Differ
Sector | Instrument | Reference and date |
Commercial banks | Reserve Bank of India (Commercial Banks – Know Your Customer) Directions, 2025 | RBI/DOR/2025-26/169; DOR.AML.REC.No.88/14.01.002/2025-26; 28 November 2025, updated as on 29 December 2025 |
NBFCs | Reserve Bank of India (Non-Banking Financial Companies – Know Your Customer) Directions, 2025 | RBI/DOR/2025-26/361; DOR.AML.REC.No.280/14.01.003/2025-26; 28 November 2025, updated as on 29 December 2025 |
Securities market | SEBI Guidelines on Anti-Money Laundering Standards and Combating the Financing of Terrorism | SEBI/HO/MIRSD/MIRSDSECFATF/P/CIR/2024/78; 6 June 2024 |
Securities market | SEBI Master Circular on Know Your Client Norms for the Securities Market | SEBI/HO/MIRSD/SECFATF/P/CIR/2023/169, modified by SEBI/HO/MIRSD/MIRSDSECFATF/P/CIR/2024/79; 12 October 2023, modified 6 June 2024 |
Insurance | IRDAI Master Guidelines on Anti-Money Laundering and Counter Financing of Terrorism, 2022 | IRDAI/IID/GDL/MISC/160/8/2022; issued 1 August 2022, in force 1 November 2022 |
Pension | PFRDA Master Circular on Prevention of Money Laundering | PFRDA/Master Circular/2024/04/PoP-02; originally 23 January 2023, last updated 25 September 2025 |
IFSC entities | International Financial Services Centres Authority (Anti Money Laundering, Counter-Terrorist Financing and Know Your Customer) Guidelines, 2022 | IFSCA/2022-23/GN/GL001; 28 October 2022, updated as on 26 February 2026 |
DNFBPs | Notifications bringing designated non-financial businesses and professions within the PMLA reporting regime | G.S.R. 798(E) and G.S.R. 799(E), 28 December 2020; S.O. 2036(E), 3 May 2023 |
The Four Divergences Worth Configuring For
Point of divergence | What differs | Why it matters |
NREGA job card in the OVD list | Present in the PML Rules, the RBI Directions for banks and NBFCs, the SEBI master circular and the PFRDA master circular. Absent from the definition of officially valid document in the IFSC guidelines | A group operating a domestic book and an IFSC book cannot run one OVD table |
Bank or Post Office savings account statement as address proof | Admissible under the second proviso to rule 2(1)(d), in the PFRDA master circular and in the IFSC guidelines, including a foreign bank statement in the IFSC context. Absent from rule 9(18) and from the RBI deemed-OVD list for banks and NBFCs | The most common single misconfiguration in shared onboarding platforms |
The no-OVD route | Banks operate a Small Account under paragraph 28 with a monthly withdrawal cap. NBFCs operate a simplified procedure with an 80 per cent customer-notification trigger and no equivalent monthly cap | Same paragraph number, different regime; copy-paste policies fail here |
Retention wording | Section 12(4) of the PMLA reads five years after the business relationship has ended or the account has been closed, whichever is later. Paragraph 50(2) of the RBI Directions expresses the identity-record period as five years after the business relationship has ended, without the closure limb | The statute is the higher instrument and its wording is the safer operating rule |
Sector-Specific Document Additions
The SEBI KYC framework contains sector specific requirements for non residents and foreign nationals, including requirements relating to overseas address proof and translation of documents in a foreign language. SEBI’s online KYC process also provides that a registered intermediary shall not store or save the Aadhaar number of an investor where Aadhaar authentication is used under the specified process. These requirements should be presented as SEBI securities market requirements and not as universal RBI requirements.
IRDAI adopts rule 2(d) by reference, recognises six KYC methods, treats PAN or Form 60 as conjunctive, and for existing customers with aggregate premium not exceeding Rs 50,000 in a financial year defers it to such date as the Central Government may notify.
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Why KYC Documents Get Rejected, and How to Fix Each One
Rejection reason | The rule behind it | The fix |
Utility bill more than two months old | The deemed-OVD provision fixes the age limit at two months with no discretion | Ask for the latest bill. Most providers allow instant download from the customer portal |
PAN card submitted as an address or identity OVD | PAN is not in the OVD definition. It is a separate requirement | Collect a genuine OVD alongside the PAN. Both are needed, neither substitutes |
Rent agreement submitted as address proof | A rent agreement appears in none of the three lists | Use a qualifying deemed OVD, or a leave and licence agreement with a qualifying employer, which is a different instrument |
Bank statement submitted as address proof to a bank or NBFC | It is absent from the RBI deemed-OVD list and from rule 9(18) | Use a utility bill, tax receipt, PPO with address, or qualifying employer allotment letter |
Expired driving licence or passport | An expired document is an expired CDD document | Renew, or use another OVD. At re-KYC this triggers new-customer onboarding |
NREGA job card without the State Government officer’s signature | The signature is written into the definition | Obtain the signed card. An unsigned card is outside the definition |
Only the acknowledgement page of an income tax return, for a proprietorship | The provision requires the complete return, duly authenticated and acknowledged | Obtain the full return, or substitute one of the other seven activity proofs |
Only one activity proof for a proprietary firm, with nothing else on file | The relaxation is conditional on contact point verification, further information and confirmation of the activity at the firm’s address | Perform and document all three conditions, and record the reasons in writing |
Corporate file with board resolution but no signatory OVD | Every entity list requires the documents specified for individuals for persons holding an attorney | Collect OVD, PAN or Form 60 and photograph for each authorised signatory |
Beneficial owner recorded as the managing director with no analysis | For a company, partnership firm or unincorporated association or body of individuals, no natural person is identified under applicable ownership or control tests, relevant natural person holding senior managing official position is identified as the beneficial owner. | Run and document the ownership and control tests first |
Foreign-language address proof without translation | SEBI requires translation into English | Obtain a translation before submission |
Notarised abroad by a certifier outside the six-authority list | The certified-copy definition contains a closed list for NRIs and PIOs | Re-certify through one of the six named authorities |
Full Aadhaar number visible in the retained copy | Redaction is required; SEBI prohibits storage of the number entirely | Redact at capture, and remediate the existing repository |
Deemed OVD accepted, no OVD received three months later | The three-month cure is mandatory | Diary the date at capture and chase it before it lapses |
How Long KYC Documents Must Be Retained
Retention is part of the document question, because a document you cannot produce on demand is, for supervisory purposes, a document you did not collect.
Record type | Retention period | Source |
Records of transactions | Five years from the date of the transaction between the client and the reporting entity | PMLA section 12(3); RBI Directions para 50(1) |
Records of the identity of clients | Five years after the business relationship has ended or the account has been closed, whichever is later | PMLA section 12(4) |
Records of the identity of clients, as expressed in the Directions | Five years after the business relationship has ended | RBI Directions para 50(2) |
Records relating to specified enhanced due diligence transactions | Five years | PMLA section 12AA(4) |
Section 12(4) of the PMLA requires the records relating to the identity of clients to be maintained for five years after the business relationship has ended or the account has been closed, whichever is later. The RBI Directions separately require banks to preserve identification and address records for at least five years after the business relationship has ended. The bank should therefore ensure that its retention policy complies with the applicable statutory and regulatory requirements.
The Explanation to paragraph 50 includes the results of any analysis undertaken within the meaning of identification records. The regulated entity should therefore retain the results of relevant analysis in accordance with the applicable retention requirements. Paragraph 50(5) also requires records to permit reconstruction of individual transactions in line with Rule 3 of the PML Rules.
Two Checklists You Can Work From
Checklist One: Individual Resident Customer
□ | Item | Detail |
1 | One officially valid document | Passport, driving licence, proof of possession of Aadhaar, Voter’s Identity Card, signed NREGA job card, or NPR letter |
2 | Address currency check | Does the OVD carry a current address? If yes, stop here. If no, proceed to item 3 |
3 | Deemed OVD for address | Utility bill not older than two months, property or Municipal tax receipt, PPO with address, or qualifying employer allotment letter |
4 | Three-month cure diarised | Where a deemed OVD was used, diary the date by which an OVD with the current address is due |
5 | PAN or Form 60 | Required where applicable. Verify PAN against the issuing authority’s database |
6 | Recent photograph | Live capture where the digital KYC route is used |
7 | Aadhaar redaction applied | Where proof of possession of Aadhaar was submitted, the number is redacted in the retained copy |
8 | Nature of business and financial status | Collected where the risk profile calls for it, not by default |
9 | Risk categorisation recorded | Drives the periodic updation cycle |
10 | CKYCR upload | Within 10 days of commencement; KYC Identifier communicated to the customer |
11 | Re-KYC due date set | Two, eight or ten years by risk category, from account opening or last updation |
12 | Document expiry dates captured as data | So that expiry can be detected before re-KYC rather than at it |
Checklist Two: Entity Customer
□ | Item | Detail |
1 | Legal form identified | Company, partnership, LLP, trust, unincorporated association, body of individuals, society, other juridical person, or sole proprietorship |
2 | Constitutional documents | Per the list for that legal form, as certified copies |
3 | Entity PAN or Form 60 | Note that the trust and unincorporated association lists expressly permit Form 60 |
4 | Proprietorship activity proofs | Any two of the eight. If only one, record reasons in writing, perform contact point verification and confirm the activity at the firm’s address |
5 | Listed-entity exemption tested | Listed in India, or resident in a notified jurisdiction and listed there, or a subsidiary of such an entity. Record the test either way |
6 | Beneficial owners identified | More than 10 per cent of shares, capital or profits for companies, more than 10 per cent of capital or profits for partnership firms, and more than 15 per cent of property, capital or profits for unincorporated associations or bodies of individuals. For trusts, identification includes the author, trustee, beneficiaries with 10 per cent or more interest and any other natural person exercising ultimate effective control. |
7 | Control limb analysed | Board appointment rights, management or policy control, shareholders and voting agreements |
8 | Senior managing official fallback documented | Used only where the ownership and control analysis identified nobody, with that analysis on file |
9 | Individual CDD for each beneficial owner | OVD, PAN or Form 60, recent photograph |
10 | Authority to transact | Board resolution or power of attorney identifying each authorised signatory |
11 | Individual CDD for each authorised signatory | OVD, PAN or Form 60, recent photograph |
12 | Trustee capacity disclosed | Where a person acts on behalf of a trust, the trustee capacity is disclosed and recorded |
13 | Legal existence established | For unincorporated associations and other juridical persons, whatever collectively establishes existence |
14 | Re-KYC cycle set for the entity | Periodic updation applies to non-individual customers on the same risk-based cycle |
Conclusion
The question “what KYC documents are required in India” does not have a single document list that applies uniformly to every regulated entity. For an individual customer, the applicable KYC framework may permit an OVD or equivalent e-document, a KYC Identifier retrieved from CKYCR, Aadhaar-based methods where permitted, or other prescribed KYC routes, together with any additional requirements applicable to the regulated entity and the customer.
The long answer exists because the applicable requirements differ according to the customer, the KYC method and the type of regulated entity. A customer whose OVD does not contain the current address may use the applicable deemed-OVD route, subject to the prescribed three-month period for furnishing an updated OVD. Customers unable to produce the prescribed documents may, where the applicable framework permits it, use a simplified account-opening route subject to the applicable conditions and limits. Additional requirements may apply to foreign nationals, trusts and other non-individual customers.
AML India works with banks, NBFCs, securities-market intermediaries, insurers and DNFBPs on document acceptance matrices, onboarding rule configuration and KYC file remediation. If your matrix has not been reviewed against the November 2025 Directions and the December 2025 update, that is the place to start.
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Frequently Asked Questions
No. PAN is not an officially valid document under the PML Rules. PAN requirements are separate from the OVD requirement and may arise under the applicable RBI KYC framework and the Income-tax Rules. Whether PAN or Form 60 must be furnished depends on the applicable regulatory and tax requirements.
No. The RBI KYC framework does not make Aadhaar mandatory for KYC. Customers may use other permitted KYC methods and documents, subject to the requirements applicable to the relevant regulated entity. Where Aadhaar is used, the regulated entity must follow the applicable requirements governing the use and retention of the Aadhaar number.
It depends on the applicable regulatory framework. A bank or Post Office savings account statement should not be treated as a deemed OVD for banks and NBFCs under the RBI framework. Other regulators may prescribe different requirements for address verification, so the applicable sector-specific rules should be checked.
A private rent agreement is not included in the deemed OVD list under Rule 9(18) of the PML Rules. Separately, the Rules recognise a letter of allotment of accommodation and a leave and licence agreement with specified qualifying employers for the limited purpose of proof of address. Acceptance of other address documents depends on the applicable regulatory framework.
For the limited purpose of proof of address under Rule 9(18) of the PML Rules, the utility bill must not be more than two months old. The provision covers electricity, telephone, post-paid mobile phone, piped gas and water bills. The deemed OVD route applies where the OVD furnished by the customer does not contain an updated address, and the customer must subsequently furnish an updated OVD with the current address within three months.
Usually not. Where there is no change in KYC information, the regulated entity may obtain a self-declaration from the customer through the permitted channels. Where only the customer’s address has changed, the customer may provide a self-declaration of the new address, and the regulated entity verifies the declared address through positive confirmation within two months. Where the CDD documents available in the records have expired at the time of periodic updation, the customer is treated as a new customer for CDD purposes. Where a customer whose account was opened while they were a minor becomes a major, fresh photographs must be obtained, and the regulated entity must ensure that CDD documents as per current CDD standards are available. Fresh KYC may be carried out wherever required.
Transaction records are retained for five years from the date of the transaction, subject to the applicable statutory and regulatory requirements. Under section 12(4) of the PMLA, identity records are retained for five years after the business relationship has ended or the account has been closed, whichever is later. The RBI Directions also include the results of any analysis undertaken within the scope of identification records. Retention should therefore be implemented in accordance with the applicable statutory and regulatory requirements.
The passport is the officially valid document for identity. For address, submit a deemed OVD or a letter from the Foreign Embassy or Mission in India.
About the Author
Pathik Shah
FCA, CAMS, CISA, CS, DISA (ICAI), FAFP (ICAI)
Pathik is a Chartered Accountant with more than 26 years of experience in governance, risk, and compliance. He helps companies with end-to-end AML compliance services, from conducting Enterprise- Wide Risk Assessments to implementing the robust AML Compliance framework. He has played a pivotal role as a functional expert in developing and implementing RegTech solutions for streamlined compliance.
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