SEBI Digital KYC for NRIs, OCI Cardholders and Foreign Nationals Abroad: Circular of 4 November 2026
SEBI’s circular of 4 November 2026 lets registered intermediaries onboard an individual NRI, OCI cardholder or foreign national digitally, even when the client is abroad, if the client is in a FATF compliant country. It adds video-verification safeguards and a 3-working-day KRA upload. In force from 3 December 2026, the date the circular names.
Dev is an invented NRI living in a country that FATF counts as compliant. In December 2026 he wants to open an account with an Indian intermediary without flying home. Until now the firm had to be sure he was physically in India during digital KYC. What would the new route ask of it?
| Before the call | The firm asks for his PAN and CKYC ID and pulls any existing record (5.2) |
|---|---|
| Documents | Passport, overseas current address and proof, digital KYC form under e-signature (5.5) |
| Video verification | The firm’s authorised official is present. If his specimen signature was sent digitally, he signs on paper on camera. His IP address must come from India or a FATF compliant country and match his form (5.5.8) |
| After KYC | If the firm completes KYC on Monday 7 December 2026, the KRA upload is due within 3 working days, so by Thursday 10 December 2026 (our counting, assuming no holiday) |
What is KYC in this setting, and what did the earlier rule say?
A SEBI-registered firm must know its client before it opens an account. SEBI’s Master Circular on KYC norms (SEBI/HO/MIRSD/SECFATF/P/CIR/2023/169, 12 October 2023) sets how, and how a KRA validates the records. The 4 November circular says the extant text requires the firm to ensure that, during digital KYC, the client’s physical location is in India. In effect, a client abroad could not complete the process digitally at onboarding.
KYC (Know Your Client)
The identity and address checks a SEBI-registered firm must complete before it opens an account for a client.
PROI (Person Resident Outside India)
The circular uses it for a Non-Resident Indian (NRI), an Overseas Citizen of India (OCI) cardholder or a foreign national. This post says “overseas client”.
KRA and CKYCRR
A KYC Registration Agency (KRA) and the Central KYC Records Registry (CKYCRR) hold KYC records so one client check can be reused. The CKYCRR gives each client a CKYC ID.
FATF compliant country
The circular points to details published by the Financial Action Task Force (FATF), the global anti-money-laundering body. It does not list countries itself.
VIPV (Video In Person Verification)
A live video check of the client, used when meeting in person is not feasible. IPV is the in-person version.
The circular’s stated purpose is to ease onboarding of an individual overseas client, after representations from market participants.
What changed?
BEFORE
Digital KYC needed the client to be physically in India. A client abroad at onboarding could not complete it digitally.
NOW
For an individual overseas client in a FATF compliant country, the firm may accept digital submission of KYC information and documents.
The circular lists four modifications (paragraph 4):
- Location rule relaxed for individual overseas clients in a FATF compliant country (4.1).
- “Validated” tags. The KRA tags an attribute “validated” if verified with an official or source database. Records stay portable either way (4.2).
- Reliance. A firm may rely on KYC done by another SEBI-registered intermediary or an entity of another financial sector regulator, using the KRA or CKYCRR record (4.3).
- VIPV. An authorised official of the firm must be present, and the process is subject to concurrent audit (4.4).
Who stays on the old process?
- Individual NRI, OCI cardholder or foreign national
- Client in a FATF compliant country
- Re-KYC of such a client (5.10)
- Client in a FATF non-compliant country: extant KYC process continues (8.4)
- Foreign national seeking FPI registration: the FPI Master Circular of 30 May 2024 or its amendments (6)
- KYC done before the effective date: extant provisions (8.5)
What must the firm do, step by step?
-
Identify and retrieve5.1 to 5.3
Identify the client, verify identity, and learn the purpose of the relationship. Fetch any existing record from the KRA and CKYCRR. Ask for more only if details changed, are incomplete or lapsed, the firm considers it necessary to verify identity or address, or enhanced due diligence is needed.
-
Collect the documents5.5.1 to 5.5.7
PAN (checked against the Income Tax database), passport and OCI card where applicable, the individual KYC form, specimen signature, one proof of identity and one of address, mobile number and email.
-
See the original, or use a substitute5.5.6
See and verify the original and record the official, date and time. If none is produced, use a route in the table below.
-
Verify the person5.5.8
In-person verification, or VIPV if that is not feasible.
-
Send the record to the KRA5.7
Within 3 working days from completion of KYC. The KRA updates the record and informs other firms using it (5.4).
| If the original is not produced (5.5.6(b)) | The firm may collect |
|---|---|
| Digital locker | An equivalent e-document through DigiLocker |
| Issuing authority | An e-document through a verifiable mechanism |
| Aadhaar | OTP, biometric or face-authentication based Aadhaar e-KYC authentication |
| Attested copy | A copy attested by a Notary Public, a Court Magistrate, a Judge, the Indian Embassy or Consulate General where the client lives, or a listed bank official (5.5.6(b)(iv)) |
What safeguards apply to a video verification?
Paragraph 5.5.8(b) lists ten. In short: auditable consent; random actions so the call is not pre-recorded; an uninterrupted recording with live GPS and a tamper-proof time stamp; no spoofed IP addresses, VPNs or proxies; an IP address from India or a FATF compliant country matching the form and document; a clear matching photo; end-to-end encryption; the authorised official present; face-liveness and spoof detection that does not exclude persons with special needs; and concurrent audit.
Also: the firm stays responsible for KYC it relies on (5.6.3); the infrastructure must meet SEBI’s Cyber Security and Cyber Resilience Framework (5.8); documents must be in English or carry an attested translation (5.9).
What should intermediaries do before 3 December 2026?
Our suggestions, not requirements of the circular:
- Build the new route into onboarding: country check against FATF details, IP-address match, overseas address capture.
- Confirm the video vendor meets the ten safeguards and appoint a concurrent auditor.
- Set a 3-working-day KRA upload alert.
When does it apply?
From 3 December 2026, for onboarding every individual overseas client other than one in a FATF non-compliant country. Paragraph 7 words it as “thirty (30) days from the date of issue of this circular i.e. from December 03, 2026”. This post uses the date the circular names. A plain count of 30 days from 4 November would reach 4 December, so a firm planning to the last day may wish to confirm the start date with SEBI.
Legal basis
- Power used
- Section 11(1), Securities and Exchange Board of India Act, 1992 (paragraph 9)
- Supersedes, to the extent stated
- KYC Master Circular of 12 October 2023; circular CIR/MIRSD/16/2011 of 22 August 2011 (“Simplification and Rationalization of Trading Account Opening Process”); circular HO/38/30/12(1)2025-MIRSD-SEC-FATF of 10 December 2025 (paragraph 8)
Key facts
| Authority | Securities and Exchange Board of India (SEBI) |
|---|---|
| Instrument | Circular, Review of Know Your Client process for individual Person Resident Outside India clients |
| Reference | HO/38/30/12(3)2026-MIRSD-POD2/I/25175/2026 |
| Issue date | 4 November 2026 |
| Effective date | 3 December 2026, as named in paragraph 7 |
| Addressed to | Intermediaries registered with SEBI, recognised stock exchanges, recognised clearing corporations and depositories |
| Applies to | Onboarding of individual NRIs, OCI cardholders and foreign nationals, except clients in FATF non-compliant countries |
| Last verified | 5 November 2026, against the sebi.gov.in circular page and PDF |
Frequently asked questions
Can an NRI now complete KYC fully online from abroad?
Yes, if the client is in a FATF compliant country: the firm may accept digital submission (paragraph 4.1). In-person or video verification with the paragraph 5.5.8 safeguards still applies.
What if the client lives in a FATF non-compliant country?
The extant KYC process continues for such clients (paragraph 8.4).
Does it apply to a foreign national registering as an FPI?
No. The FPI Master Circular of 30 May 2024, or its amendments, applies (paragraph 6).
Do firms have to redo KYC already completed?
No. KYC undertaken before the circular comes into effect continues to be governed by the extant KYC provisions (paragraph 8.5).
Sources (official)
- SEBI Circular HO/38/30/12(3)2026-MIRSD-POD2/I/25175/2026, Review of Know Your Client process for individual Person Resident Outside India clients, 4 November 2026 (PDF) https://www.sebi.gov.in/sebi_data/attachdocs/nov-2026/1793791897866.pdf
- Same circular, SEBI legal page https://www.sebi.gov.in/legal/circulars/nov-2026/review-of-know-your-client-process-for-individual-person-resident-outside-india-clients_105603.html
- SEBI Master Circular SEBI/HO/MIRSD/SECFATF/P/CIR/2023/169, Master Circular on Know Your Client (KYC) norms for the securities market, 12 October 2023 (PDF) https://www.sebi.gov.in/sebi_data/attachdocs/oct-2023/1697120943335.pdf
- SEBI
- Capital Market Regulations
- KYC
- NRI
- PROI
- VIPV
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