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Uniform KYC format

Also written Uniform KYC · Uniform KYC form

SEBI's rule that every registered intermediary uses the same KYC form and supporting documents — Part I of the account opening form built on CERSAI's templates, Part II left to the intermediary.

In plain language

Before KYC was standardised, an investor who dealt with a broker, a depository participant and three mutual funds could fill in five different KYC forms and hand over five sets of the same documents.

The uniform KYC format ends that. To bring about uniformity in the securities market, all SEBI registered intermediaries shall use the same KYC form and supporting documents, whether KYC is done in physical mode or digital (online or app based) mode.

The design is a split. The part every intermediary needs identically — who the client is — is common. The part that depends on what the intermediary does is left to it. That split is what makes a single central KYC record usable by everyone.

How it works

The two parts of the account opening form (AOF).

PartContentsWho designs it
Part I — the KYC formBasic details about the clientCommon: all intermediaries use the KYC templates provided by CERSAI (Central Registry of Securitisation Asset Reconstruction and Security Interest of India) — one for individuals, one for legal entities
Part IIAdditional information specific to the intermediary's area of activityThe intermediary, as it considers appropriate

SEBI's master circular deals with Part I.

How the common record travels.

  • KRA upload. After doing initial KYC of a new client, the intermediary shall forthwith upload the KYC information to the KRA system within 3 working days of completion of the KYC process.
  • KRA letter. The KRA sends the client a letter within 2 working days of receiving the initial or updated KYC documents, confirming the details, and keeps proof of dispatch.
  • Existing clients. Their KYC data is uploaded provided it conforms to the uniform KYC format, without duplication in the KRA system.
  • Electronic records. Intermediaries maintain electronic records of KYC; keeping physical records is not necessary.
  • Mobile and email. The client's own mobile number and email are uploaded on the KRA system — never those of employees, authorised persons or distributors.

The CKYC layer. Separately, Rule 9(1A) requires the electronic copy of the client's KYC records to be filed with the Central KYC Records Registry within ten days of commencement of an account-based relationship, and Rule 9(1C) bars asking the client for the same documents again when the record can be retrieved using the KYC Identifier, subject to the listed exceptions.

A worked example

Illustrative names and dates.

Monday. Ms Neha Kulkarni completes KYC with Pragati Broking Ltd in Pune. Part I is the CERSAI individual template; Part II records her trading preferences, segments and risk disclosures specific to broking.

By Thursday. The KYC information must be on the KRA system — 3 working days from Monday are Tuesday, Wednesday and Thursday. Pragati uploads Neha's own mobile number, not the sub-broker's.

Within 2 working days of the KRA receiving it. The KRA writes to Neha confirming the details and keeps proof of dispatch.

Within ten days of the relationship starting. Her KYC record is filed with the Central KYC Records Registry, which de-duplicates it and issues a KYC Identifier.

Three months later. Neha invests in a mutual fund through its AMC. Because Part I is common, the AMC does not start again: it uses the existing KYC record and collects only its own Part II information. If her address has changed since, that change is an exception under Rule 9(1C) and the updated information is obtained.

Why NISM asks about it

Chapter 7 (SEBI Guidelines for KYC Norms in Securities Market), section 7.1.1, sets out the uniform format and the Part I / Part II split, and sections 7.1.9, 7.4, 7.5 and 7.5.1 give the KRA upload and letter timelines. Chapter 3 carries the CKYCR filing in Rule 9(1A) to 9(1C). Expect "what does Part I capture and whose templates does it use?", and the 3-working-day and 2-working-day figures.

Common exam traps

  • CERSAI templates are for Part I, and there are two — individual and legal entity.
  • Part II is the intermediary's own, specific to its area of activity.
  • 3 working days to upload to the KRA; 2 working days for the KRA's letter to the client; 10 days to file with the CKYCR. Three different clocks, three different recipients.
  • The uniform format applies in physical and digital mode alike.
  • Physical KYC records are not necessary once electronic records are maintained.
  • Never upload an employee's or distributor's mobile number or email on behalf of a client.

Check yourself

  1. 1.Within what period must an intermediary upload a new client's KYC information to the KRA system?

    1. a)Within 3 working days from the date of completion of the KYC process
    2. b)Within 7 working days
    3. c)Within 15 days
    4. d)There is no fixed period
    Show the answer

    Answer: (a) Within 3 working days from the date of completion of the KYC process

    After doing the initial KYC of the new clients, the intermediary shall forthwith upload the KYC information on the system of the KRA within 3 working days from the date of completion of KYC process.

    "Forthwith... within 3 working days" — three days is the outer limit.

    The client does not wait for it: the client shall be allowed to open an account with intermediaries and transact in securities market as soon as the KYC process is completed.

    Then the KRA responds to the client: it shall send a letter to the client within 2 working days of the receipt of the initial/updated KYC documents from intermediary, confirming the details thereof and maintain the proof of dispatch.

    Three working days up; two working days out.

    If the papers are incomplete: the KRA shall inform the same to the intermediary who shall forward the required information / documents promptly to KRA.

    For existing clients, data is uploaded provided they are in conformity with details sought in the uniform KYC format, and the intermediary must ensure that there is no duplication of data in the KRA system.

    The KRA framework exists for centralisation. A mechanism of Know Your Client Registration Agency (KRAs) in the securities market has been developed for centralization of the KYC records. The KRAs shall be administered under SEBI KYC Registration Agency (KRA) Regulations, 2011.

    Two reliefs for the intermediary: the intermediaries shall maintain electronic records of KYCs of clients and keeping physical records would not be necessary.

    And two continuing duties: the intermediary shall promptly provide KYC related information to KRA, as and when required. The intermediary shall have adequate internal controls to ensure the security / authenticity of data uploaded by it.

Where this is taught

Free preparation for NISM Series XXIV

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