SEBI’s circular dated 4 November 2026 removes a practical barrier for individual Persons Resident Outside India: an eligible investor will no longer have to be physically in India to complete digital securities-market KYC. The revised process applies to NRIs, Overseas Citizens of India and foreign nationals, with detailed safeguards for documents, location, live video verification and record reuse.
Who can use the overseas digital-KYC route?
The circular covers an individual Person Resident Outside India, defined for this purpose as an NRI, an OCI or a foreign national. The person must be located in a country treated as FATF compliant, based on details published by the Financial Action Task Force.
This is not a blanket waiver of KYC. It changes where and how eligible clients can complete the process. The intermediary must still identify the client, verify identity, understand the purpose and intended nature of the relationship, build a risk profile and perform enhanced due diligence where required.
A foreign national seeking registration as a Foreign Portfolio Investor remains governed by the separate FPI framework. The new individual-client process should not be used to replace those rules.
What changes on 3 December?
| Issue | Revised treatment |
|---|---|
| Location | An eligible individual non-resident may complete digital onboarding from a FATF-compliant country instead of being physically in India. |
| Existing records | The intermediary first seeks PAN and the CKYC ID, if available, and retrieves records from the KRA and Central KYC Records Registry. |
| Portability | KYC records can be shared with another intermediary even when every individual attribute has not been tagged as validated. |
| Live verification | Video In-Person Verification is allowed with location, liveness, security, authorised-official and concurrent-audit controls. |
| KRA reporting | After KYC is completed, the intermediary must provide the information to the KRA within three working days. |
Start with PAN and CKYC
When a client approaches an intermediary for a new account or a KYC update, the intermediary must seek the PAN and CKYC ID, if available. It must then retrieve the client’s information and documents from the KRA and CKYCRR.
If a record already exists, fresh details should be requested only where the record has changed, is incomplete or does not meet current rules, an identity or address document has expired, verification is considered necessary, or enhanced due diligence or risk profiling requires it. This is intended to reduce repetitive document collection without shifting the final KYC responsibility away from the intermediary.
PAN is checked against the Income Tax database; the client need not produce the original PAN card or a copy. Passport details and the OCI card, where applicable, are collected, and the passport is verified where feasible.
Documents and signatures
- KYC form. It may be a physical original, an electronically signed scan, or an electronically signed digital form using the CKYCRR individual template.
- Specimen signature. A wet signature may be provided on the physical form. A digitally submitted cropped signature must be matched with a wet signature made before the intermediary during video verification.
- Identity and address. The client must provide an accepted officially valid document or deemed officially valid document. For an individual non-resident, the current address is the overseas address.
- Foreign-national address. If the official document does not contain an address, the intermediary may collect a document issued by a foreign government department or a letter from a foreign embassy or mission in India.
- Language. Documents must be in English. A document in another language must be translated into English and attested by a permitted certifying authority before submission.
If the original document cannot be shown
The circular permits alternatives to physical original-seen-and-verified checks. Depending on availability, the intermediary may collect an equivalent e-document through DigiLocker, a verifiable e-document issued by the issuing authority, permitted Aadhaar e-KYC authentication, or a copy attested by an approved authority.
Approved certifiers include a notary public, an authorised official of an overseas branch of an Indian scheduled commercial bank, a branch of an overseas bank having a relationship with an Indian bank, a court magistrate or judge, or the Indian embassy or consulate in the client’s country. The certified copy must carry the date, location, name and licence number or employee code, if any, of the certifier.
How video verification must work
If physical in-person verification is not feasible, the intermediary may conduct Video In-Person Verification. It is more than an ordinary video call. The process must:
- record client consent in an auditable, alteration-proof manner;
- use random actions and liveness checks to show that the interaction is live;
- capture an uninterrupted recording with live GPS coordinates, date and time through tamper-proof technology;
- block spoofed IP addresses, VPNs and proxy servers;
- confirm that the IP address comes from India or an eligible FATF-compliant country and matches the country disclosed in the form and documents;
- clearly capture and match the client’s face;
- use end-to-end encryption;
- have an authorised official of the intermediary present; and
- subject the process to concurrent audit.
Email, mobile number and KRA records
The intermediary collects both a mobile number—Indian or international—and an email address. Email must be verified by OTP or another verifiable method. Mobile verification is required where feasible; if the mobile number cannot be verified, all communications must go to the verified email address.
KRAs will mark each attribute as “validated” where it has been checked with an official or source database. A record remains portable even if every attribute is not validated. An intermediary may rely on a KRA record created by another SEBI intermediary or a CKYCRR record created by an entity regulated by RBI, IRDAI, PFRDA or IFSCA—but remains ultimately responsible for its client’s KYC and risk-based due diligence.
What should overseas investors do?
- Check your location. Confirm with the broker, depository participant or other intermediary that the country from which you will complete KYC is eligible.
- Keep identifiers ready. Provide PAN and your CKYC ID, if you have one, so existing records can be retrieved before you send fresh documents.
- Review expiry and address. Check that your passport and address evidence are current and that the overseas address is consistent across the form and supporting records.
- Arrange certification where needed. If the original or a verifiable e-document is unavailable, use only a certifier recognised by the circular and ensure the required certification details appear on the copy.
- Translate before submission. Obtain an English translation and proper attestation for any non-English document.
- Prepare for a controlled video session. Avoid VPNs or proxy servers, allow location capture, use a stable encrypted connection and keep original documents and a pen available.
- Use a verified email address. This becomes especially important if an international mobile number cannot be verified.
What should intermediaries complete before go-live?
- update onboarding and re-KYC workflows to distinguish eligible and FATF non-compliant locations;
- retrieve KRA and CKYCRR records before seeking additional information;
- configure document, electronic-signature, attestation and English-translation checks;
- test IP-location matching, geo-tagging, liveness, anti-spoofing, encryption and recording controls;
- ensure an authorised official is present during every VIPV and establish concurrent audit;
- track the three-working-day deadline for submitting completed KYC information to the KRA; and
- retain risk-based controls because record portability does not remove the intermediary’s ultimate responsibility.
Reviewed on 10 November 2026. The revised process starts on 3 December 2026. Investors should also check the onboarding instructions of their chosen intermediary, which may apply additional safety measures under its risk policy.