Identification, third-party reliance and CKYCR responsibility

Third-party CDD reliance has conditions. The current CKYCR authenticity exception must be read alongside the bank’s remaining duties.

Published by Finin2min · Updated 24 October 2026

How this provision works

Identify customers when starting an account relationship, for specified international transfers, doubtful identity data and qualifying walk-in transactions. Linked transactions and deliberate structuring below the ₹50,000 threshold matter; an introduction is not required for account opening.
Paragraph 22 allows reliance on third-party CDD only with immediate records/information, timely access to copies, a suitably regulated/supervised third party, and exclusion of a high-risk-jurisdiction third party. The bank retains its stated CDD/EDD responsibility.
The specific paragraph 65(10) explanation assigns identity/address verification responsibility to the RE that last uploaded/updated CKYCR records. A downloader relying on current PML-compliant records need not re-verify authenticity of identity/address, while remaining responsible for other CDD obligations.
Do not turn that narrow exemption into a blanket release from risk assessment, sanctions screening, monitoring or resolving stale/incomplete records. CKYCR retrieval has its own listed exceptions allowing additional documents.

Practical illustration

A current compliant CKYCR download can remove needless re-verification of identity/address authenticity. A changed address, expired document, incomplete record or required EDD still triggers its own applicable branch.

The example is illustrative; it is not a reported company or court case.

Questions answered

Can a bank rely on any unregulated overseas introducer?

No. Paragraph 22 sets regulation, access and jurisdiction conditions.

Does downloading CKYCR transfer all CDD responsibility?

No. Only the specified identity/address-authenticity re-verification is exempted for qualifying current records; other duties remain.

Primary source and edition

Commercial Banks KYC Directions 2025, updated 1 October 2026; current tax-form transition cross-checked against the official e-filing department. Commercial Banks KYC Directions paragraphs 21–22 and 65(10), December 2025 CKYCR explanation.

Open the official instrument at this provision

Legal effect follows the instrument’s commencement and amendment provisions; a website upload date does not by itself change the law.

Related primary authorities

Scope and source editions

This explanation uses the Commercial Banks KYC Directions 2025, updated 1 October 2026, retrieved 24 October 2026. Its commercial-bank definition excludes Small Finance Banks, Payments Banks and Local Area Banks; those have separate directions. NBFCs also have a separate KYC direction and some paragraph numbers/procedures differ. Tax-form transitions are corroborated by current official e-filing guidance rather than copied from older tax-form references in the RBI consolidation.