Equivalent e-document

A scan of a passport is a photograph of a document. An equivalent e-document is the document itself, in electronic form.

The difference is the signature. An equivalent e-document is issued by the authority that issues the document, and carries that authority's valid digital signature. A file downloaded to the client's digital locker account counts too, under the digital locker rules of 2016.

So it is not a copy the client makes. It is an original the issuer makes.

That is why the rules accept it everywhere they accept paper. Wherever the PML Rules ask for an officially valid document, a PAN or a proof of address, they add the words or the equivalent e-document thereof. The phrase turns up again and again in Rule 9, and it is easy to read past.

The entity receiving one still has work to do. It has to check the digital signature, and it has to take a live photo of the client.

Two definitions, one meaning, one extra limb.

Under the PML Rules (Chapter 3, footnote to Rule 9(4)): an electronic equivalent of a document, issued by the issuing authority of such document with its valid digital signature, including documents issued to the digital locker account of the client as per rule 9 of the Information Technology (Preservation and Retention of Information by Intermediaries Providing Digital Locker Facilities) Rules, 2016.

Under the IFSCA Guidelines (Chapter 6, footnote to clause 6.3.3.4): the same words, with customer in place of client — and one addition: or its equivalent in other jurisdictions, as may be recognised by the Authority. That addition is the IFSC-specific part, and it exists because an IFSC unit's customers are mostly foreign.

Where the phrase appears in Rule 9.

Clause 6.3.3.4 (Digital KYC Process for Indian Nationals) repeats the same list for a Regulated Entity, and it is written expressly for the CDD of Indian nationals — whether the individual is the customer, a beneficial owner, an authorised signatory or a power of attorney holder of a legal entity.

What the entity must do on receiving one (Rule 9(15)(c)). Where the client has submitted an equivalent e-document of any officially valid document, the reporting entity shall:

1. verify the digital signature as per the provisions of the Information Technology Act, 2000 and any rules made under it; and
2. take a live photo in the manner specified by the regulator.

The route for those who cannot supply one (Rule 9(15)(d)). Where an officially valid document or proof of possession of Aadhaar is given and offline verification cannot be carried out, the entity carries out digital KYC. And for a period not beyond a notified date, a class of reporting entity may instead obtain a certified copy of the document and a recent photograph — expressly where an equivalent e-document is not submitted. Obtaining a certified copy means the authorised officer compares the copy with the original and records that on the copy.

The address deadlines that travel with it (Rule 9(18), which runs on to the following page). Where the officially valid document carries no updated address, a utility bill not more than two months old, a property or municipal tax receipt, a pension payment order or an employer's letter of allotment — or the equivalent e-documents thereof — are deemed officially valid for proof of address, and the client must then submit an updated officially valid document or equivalent e-document with the current address within three months.

Illustrative. The rules, the clocks and the verification steps are the workbook's.

Narmada Bank (IFSC Banking Unit) onboards two clients on 5 May 2025.

Client 1 — Mr Kiran Desai, resident Indian. He pulls his driving licence and his PAN from his digital locker account and sends both.

Client 2 — Mrs Sunitha Rao. She brings a paper passport and no digital locker account, and offline verification of her Aadhaar cannot be carried out. No equivalent e-document has been submitted, so Narmada takes the other route: digital KYC, or, for the notified period and class, a certified copy — its authorised officer compares her passport copy against the original and records that on the copy, and takes a recent photograph.

The foreign client. In the same week the bank onboards a customer of a Singapore company, who offers a digitally signed certificate of incorporation issued by the Singapore registry. Under the IFSCA definition an equivalent in another jurisdiction may be accepted as recognised by the Authority — which is a decision for IFSCA, not for the bank, so the bank checks what the Authority has recognised before relying on it.

One rule, two clients, two entirely different files — and the deciding fact is who signed the document, not who scanned it.

Chapter 3 (The Prevention of Money-laundering (Maintenance of Records) Rules, 2005) carries the definition in the footnote to Rule 9(4), the phrase itself through Rule 9(4), 9(17) and 9(18), and the verification duties in Rule 9(15)(c) and 9(15)(d). Chapter 6 (IFSCA Guidelines for KYC Norms) repeats the definition at clause 6.3.3.4 with the extra other-jurisdictions limb, and requires it as proof of address at periodic updation under clause 6.10.

Expect a definition question turning on who signed it — the issuing authority, not the client. Expect a "what must the entity do on receiving an equivalent e-document of an OVD?" question, where the answer is both limbs: verify the digital signature under the IT Act, 2000 and take a live photo. And expect the two-month utility bill and three-month updated-document clocks.

• A scan is not an equivalent e-document. It must be issued by the issuing authority with that authority's valid digital signature. A client-made PDF of a passport page is an ordinary copy.
• Two duties, not one, on receipt. Verify the digital signature under the IT Act, 2000 and take a live photo. Candidates give only the first.
• The IFSCA definition has one extra limb — or its equivalent in other jurisdictions, as may be recognised by the Authority. The PML Rules version does not. If the question says "under the Guidelines", the extra limb is in play.
• Digital locker documents qualify, under rule 9 of the Information Technology (Preservation and Retention of Information by Intermediaries Providing Digital Locker Facilities) Rules, 2016.
• The certified-copy route exists precisely where an equivalent e-document is NOT submitted, is limited to a notified class and period, and means comparing the copy with the original and recording that on the copy.
• An equivalent e-document is not digital KYC. One is a form of document; the other is a process of capturing a live photo of the client and the document with the latitude and longitude of the place.
• Two months and three months are different clocks. Two months is the maximum age of a utility bill used as deemed proof of address; three months is the time the client then has to produce an updated officially valid document with the current address.
• Not producing the PAN or its equivalent e-document has a consequence. Under Rule 9(17) the account temporarily ceases to be operational — after an accessible notice and a reasonable opportunity to be heard.