Notifier

When an investor dies, someone has to tell the system. SEBI's demise-reporting mechanism gives that person a name: the notifier.

A notifier need not be the nominee, though it can be. The workbook keeps the definition wide. A joint account holder, a nominee, a legal representative, or a family member can all act as the notifier.

From Chapter 6, section 6.3.5, on the centralized KRA mechanism for reporting an investor's demise (effective 1 January 2024):

The notifier may inform the "concerned intermediary" of the investor's demise and provide the death certificate along with the deceased's PAN. The intermediary must then verify the death certificate within one day of receiving it — either online through the issuing government authority's website, or offline through the OSV (Original Seen and Verified) process.

The intermediary records and retains a self-certified copy of the notifier's proof of identity, relationship with the deceased, and contact details. Once the account is marked "Blocked Permanently" by the KRA, the intermediary must intimate the notifier or nominee within 5 days about the transmission procedure, and provide the transmission request form and the list of required documents.

Mr Krishnan dies, leaving a demat account with no registered nominee but a surviving spouse and an adult son. The son, as the notifier, informs the DP of his father's death on 10 June, providing the original death certificate and his father's PAN.

The DP must verify the death certificate by 11 June (within one day), choosing either the online government-portal route or the offline OSV process. Once the KRA marks the account "Blocked Permanently," the DP must intimate the son, as notifier, about the transmission procedure by within 5 days of that status update — providing the transmission request form and the full list of documents needed.

Chapter 6, section 6.3.5, defines the notifier in a footnote to the centralized demise-reporting mechanism introduced with effect from 1 January 2024. Expect a question on who can act as a notifier (joint holder, nominee, legal representative or family member — not limited to the nominee) and on the one-day verification and five-day intimation timelines.

• A notifier need not be the nominee. A joint holder, legal representative or family member can equally be the notifier.
• Verification of the death certificate is within one day; intimation to the notifier/nominee about the transmission procedure is within five days — two different timelines for two different steps.
• Offline verification uses the OSV process; online verification uses the issuing government authority's own website — the workbook offers both routes.