SEBI KYC for NRIs, OCIs and Foreign Nationals From 3 December 2026: Digital On-Boarding From FATF Compliant Countries
Quick Summary
- SEBI Circular HO/38/30/12(3)2026-MIRSD-POD2/I/25175/2026 dated 4 November 2026 lets NRIs, OCIs and foreign nationals complete KYC with a SEBI intermediary digitally from outside India, if they are located in a FATF compliant country.
- It applies to the on-boarding of every individual PROI client, other than a client in a FATF non-compliant country, from 3 December 2026.
- Video In Person Verification (VIPV) must capture the client’s live GPS location, and the client’s IP address must come from India or a FATF compliant country and match the country in the KYC form and the document.
- The intermediary may rely on KYC already done by another SEBI intermediary (through the KRA) or by an entity regulated by RBI, IRDAI, PFRDA or IFSCA (through CKYCRR), but keeps ultimate responsibility.
- KYC done before 3 December 2026 stays governed by the earlier provisions.
SEBI KYC for NRIs, OCIs and foreign nationals changes on 3 December 2026. Until now, SEBI’s KYC Master Circular of 12 October 2023 required an intermediary to ensure that, during digital KYC, the client was physically in India. As SEBI’s circular of 4 November 2026 puts it, this “in effect restricts a client outside India, at the time of on-boarding, to submit the KYC documents and complete the KYC process digitally.” The new circular removes that restriction for individual clients located in FATF compliant countries and lays down a full on-boarding process for them. This matters to any NRI or foreign national opening a demat or trading account or otherwise on-boarding with a SEBI registered intermediary, and to the CAs and family offices who handle these accounts.
Who is an individual PROI client under the SEBI circular?
Paragraph 3 of the circular defines an individual Person Resident Outside India (PROI) client as a Non-Resident Indian (NRI), an Overseas Citizen of India (OCI) or a foreign national. PROI takes its meaning from section 2(w) of the Foreign Exchange Management Act, 1999: “a person who is not resident in India”. An OCI cardholder is a person registered as such under section 7A of the Citizenship Act, 1955.
Where an individual foreign national seeks registration as a Foreign Portfolio Investor (FPI), paragraph 6 says the FPI Master Circular of 30 May 2024 (or its amendments) applies instead.
What changes for SEBI KYC of NRIs from 3 December 2026?
Paragraph 4 of the circular lists the modifications:
- Digital on-boarding from abroad (para 4.1): the requirement that a client be in India during digital on-boarding is relaxed for an individual PROI client located in a FATF compliant country. The intermediary may accept digital submission of KYC information and documents from such a client. A FATF compliant country is read “as per details published by FATF”.
- Validated attributes and portability (para 4.2): the KYC Registration Agency (KRA) tags each attribute in the KYC record as “validated” if it is verified with an official or source database. All KYC records are portable, whether or not every attribute is validated.
- Reliance on earlier KYC (para 4.3): the intermediary may rely on KYC done by a SEBI registered intermediary or by an entity regulated by another financial sector regulator, based on the record obtained from the KRA or the Central KYC Records Registry (CKYCRR).
- VIPV safeguards (para 4.4): the intermediary’s authorised official must be present during VIPV, and VIPV is subject to concurrent audit.
What documents does an NRI or foreign national submit?
Paragraph 5.5 sets out the KYC components:
| Item | What the circular requires |
|---|---|
| PAN (5.5.1) | Intermediary collects the PAN and verifies it with the Income Tax database, without insisting on the original or a copy. The KRA also verifies PAN and name. |
| Passport (5.5.2) | Copy of the passport; the OCI card where applicable. The intermediary and the KRA verify the passport “if feasible”. |
| KYC form (5.5.3) | CKYCRR template for individuals: original physical form, scanned physical form under electronic signature, or digital form under electronic signature. |
| Specimen signature (5.5.4) | Wet signature on the physical form, or a cropped image under electronic signature. A digitally submitted signature must be signed wet before the intermediary during VIPV and matched. |
| Proof of identity and address (5.5.5) | Any one officially valid document or deemed officially valid document. The current address of an individual PROI client is an overseas address. If a foreign national’s document has no address, a document from a foreign government department and a letter from a foreign embassy or mission in India can be collected. |
| Mobile and email (5.5.7) | Indian or international mobile number and email id, verified by OTP or another verifiable mechanism. If the mobile number cannot be verified, all communication goes to the verified email. |
Under paragraph 5.9, every document must be in English. A document in any other language must be translated into English and attested by a certifying authority before submission.
How does “original seen and verified” work for a client abroad?
Paragraph 5.5.6 requires the intermediary to see the original document and collect self-attested physical copies. Where the original is not produced, the intermediary collects any one of:
- the equivalent e-document through DigiLocker;
- the equivalent e-document issued by the issuing authority through any verifiable mechanism;
- OTP, biometric or face authentication based Aadhaar e-KYC; or
- a copy attested by a certifying authority: a Notary Public, an authorised official of an overseas branch of a Scheduled Commercial Bank registered in India, a branch of an overseas bank with which Indian banks have relationships, a Court Magistrate, a Judge, or the Indian Embassy or Consulate General of the country where the client resides.
A certified copy must carry the date, location, name and licence number or employee code, if any, of the certifying authority. The intermediary records the official who did the verification and a date and time stamp.
What must the video verification capture?
If physical In-Person Verification is not feasible, paragraph 5.5.8 requires VIPV with these safeguards, among others:
- client consent recorded in an auditable, alteration-proof manner;
- random action prompts, to establish that the interaction is not pre-recorded;
- an uninterrupted recording with the client’s live GPS co-ordinates and a date and time stamp, through tamper-proof technology;
- blocking of connections from spoofed IP addresses, VPNs or proxy servers;
- the client’s IP address must emanate from India or a FATF compliant country and match the country stated in the KYC form and the document;
- a clear photo matched with the form and the document, face liveness and spoof detection (without excluding persons with special needs), and end-to-end encryption;
- the intermediary’s authorised official present, and concurrent audit of the process.
What are the intermediary’s other obligations?
- Retrieve before asking (5.2, 5.3): the intermediary seeks the client’s PAN and CKYC ID and retrieves the existing records from the KRA and CKYCRR. It asks for more only where records have changed, are incomplete, a document’s validity has lapsed, it needs to verify identity or address, or for enhanced due diligence.
- Upload in 3 working days (5.7): after completing KYC, the intermediary provides the KYC information to the KRA within 3 working days.
- Cyber security (5.8): the KYC infrastructure must comply with SEBI’s Cyber Security and Cyber Resilience Framework.
- Responsibility stays (5.6.3): even when relying on third-party KYC, the intermediary has “the ultimate responsibility for the KYC of its clients”, including enhanced due diligence.
- Re-KYC (5.10): the same process applies to re-KYC of a client in a FATF compliant country.
What does the circular supersede?
From 3 December 2026, under paragraph 8:
- the KYC Master Circular of 12 October 2023 and circular CIR/MIRSD/16/2011 dated 22 August 2011 stand superseded to the extent of this circular;
- circular HO/38/30/12(1)2025-MIRSD-SEC-FATF dated 10 December 2025, “Relaxation on geo tagging requirement in India for NRIs while undertaking re KYC”, stands superseded;
- clients residing in FATF non-compliant countries continue under the extant KYC process; and
- KYC undertaken before the circular comes into effect continues to be governed by the extant provisions.
What should NRI investors and their advisers do?
- Check the country. The relaxation depends on the client being located in a FATF compliant country, and the VIPV IP address and GPS must match the country in the KYC form and document.
- Get the PAN and CKYC ID ready. The intermediary starts from these, and an existing validated record may mean fewer documents.
- Prepare English documents. Arrange attested translations for anything not in English, and a certifying authority attestation where the original cannot be shown.
- Plan for 3 December 2026. The circular states its own effective date; on-boarding before that date follows the earlier process.
For other recent rules affecting NRIs, see our notes on TDS on property purchased from an NRI without TAN and RBI’s FCNR(B) and NRE deposit window.
Sources
- Source: Securities and Exchange Board of India, Circular HO/38/30/12(3)2026-MIRSD-POD2/I/25175/2026 dated 4 November 2026, “Review of Know Your Client process for individual Person Resident Outside India clients”, sebi.gov.in.
Onboarding NRI or foreign clients?
If you advise NRIs, OCIs or foreign nationals investing in India, get expert guidance from Tax Update India on the new process. Book a quick call to discuss your situation.
Disclaimer: This article is for general information only and reflects the SEBI circular cited above as on 10 November 2026. It is not legal advice. Please consult a qualified professional before acting on it.
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