SEBI Overseas Individual KYC Rules 2026: NRI, OCI and Foreign-National Digital Onboarding Checklist
The framework covers NRI, OCI and foreign-national clients, portable KYC records, attribute validation, Video IPV controls and a three-working-day KRA submission timeline.
Search intent and key terms
Primary keyword: SEBI overseas individual KYC rules 2026
Intent: Official-source compliance update for brokers, intermediaries, KRAs, depositories, exchanges, fintechs and overseas individual investors.
Direct answer
From 3 December 2026, SEBI’s revised framework allows eligible NRI, OCI and foreign-national clients in FATF-compliant countries to complete digital KYC without being physically located in India. Intermediaries may retrieve and rely on portable KYC records, but remain ultimately responsible for identity, risk profiling and enhanced due diligence.
The circular is HO/38/30/12(3)2026-MIRSD-POD2/I/25175/2026 dated 4 November 2026. The Best CS Firm In India implementation is to update onboarding journeys, Video IPV controls, KRA workflows, source verification and audit evidence before the effective date.
Scope and effective date
| Item | SEBI position |
|---|---|
| Covered individuals | NRI, OCI and foreign national who is a person resident outside India |
| Eligible location | FATF-compliant country |
| Effective date | 3 December 2026 |
| FATF non-compliant countries | Existing KYC process continues |
| Pre-effective-date KYC | Continues under existing provisions |
| FPI registration | Relevant FPI master-circular provisions continue to apply |
| Covered institutions | SEBI intermediaries, exchanges, clearing corporations and depositories |
What changes in the KYC process
| Area | New framework |
|---|---|
| Physical location | Client need not be in India for eligible digital onboarding |
| Portability | KYC records can be shared regardless of every attribute being validated |
| Attribute status | KRA tags attributes validated against official or source databases |
| Third-party reliance | KRA or CKYCRR records may support reliance on regulated-entity KYC |
| Existing records | Request more data only in specified circumstances |
| Responsibility | Intermediary retains ultimate KYC and EDD responsibility |
| KRA submission | KYC information within three working days after completion |
Documents and verification controls
| Component | Operational requirement |
|---|---|
| PAN | Verify against Income Tax database without insisting on original or copy |
| Passport/OCI | Collect passport copy and OCI card where applicable; verify if feasible |
| KYC form | Physical, scanned under electronic signature, or digital under electronic signature |
| Signature | Wet signature or cropped image under electronic signature; match during VIPV when digital |
| Address | Use overseas current address and applicable officially valid document |
| Mobile/email | Indian or international mobile plus email; verify through OTP or other mechanism where feasible |
| Language | Documents must be in English or translated and attested before submission |
Video In-Person Verification checklist
- Record client consent in an auditable and alteration-proof manner.
- Use random actions to establish that the interaction is not pre-recorded.
- Capture live geolocation, date and time through tamper-resistant technology.
- Prevent spoofed IP, VPN and proxy connections.
- Match the client IP country with the KYC form and identity/address document.
- Capture and match the live client image with submitted documents.
- Use end-to-end encryption between the client device and hosting point.
- Ensure an authorised intermediary official is present.
- Use inclusive liveness and anti-spoof controls.
- Subject the VIPV process to concurrent audit.
Implementation countdown
| Owner | Action before 3 December |
|---|---|
| Compliance | Update policy, country screening and exception handling |
| Product | Remove India-only journey restriction for eligible clients |
| Technology | Implement IP, geolocation, liveness, encryption and audit controls |
| Operations | Train reviewers on passport, address and translation evidence |
| KRA integration | Support attribute-level validation and three-day submission |
| Audit | Design concurrent VIPV review and evidence sampling |
| Risk | Define enhanced due-diligence triggers and escalation |
Important responsibility limits
Portability is not an automatic safe harbour. An intermediary may rely on KYC obtained through KRA or CKYCRR, but must obtain updates where records changed, are incomplete, have expired, require identity or address verification, or trigger enhanced due diligence. The intermediary remains ultimately responsible for the client’s KYC.
Founder / Business Takeaway
The circular expands remote access while tightening the evidence trail. Fintech and intermediary teams should treat country eligibility, attribute validation, VIPV integrity, concurrent audit and the three-day KRA hand-off as one end-to-end control system.
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Sources and verification
https://www.sebi.gov.in/legal/circulars/nov-2026/review-of-know-your-client-process-for-individual-person-resident-outside-india-clients_105603.html
https://www.sebi.gov.in/sebi_data/attachdocs/nov-2026/1793791897866.pdf
https://www.fatf-gafi.org/en/topics/high-risk-and-other-monitored-jurisdictions.html
Frequently Asked Questions
Who is an individual PROI client under the circular?
For this framework, it covers an individual Non-Resident Indian, Overseas Citizen of India or foreign national.
When do the new SEBI KYC rules take effect?
They apply from 3 December 2026 to onboarding of individual PROI clients except clients in FATF non-compliant countries.
Can an overseas client complete KYC digitally from outside India?
Yes, an eligible individual PROI client in a FATF-compliant country may digitally submit KYC information and supporting documents, subject to the circular’s controls.
Who remains responsible when an intermediary relies on existing KYC?
The intermediary retains ultimate responsibility, including enhanced due diligence appropriate to the client’s risk profile.
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