SEBI has taken a major step to simplify the re-KYC process for Non-Resident Indians (NRIs) by relaxing the earlier requirement of being physically present in India during digital KYC verification. This change was introduced after various stakeholders highlighted the difficulties NRIs faced while complying with re-KYC from abroad, particularly due to strict geo-tagging norms and app-based location restrictions. By removing this condition, SEBI has ensured that NRIs can conveniently complete re-KYC procedures from any country using a secure digital platform.
This updated guideline amends the Master Circular on KYC dated October 12, 2023, making the process more flexible and accessible for millions of NRIs participating in India’s securities markets. The reform not only enhances investor convenience but also strengthens the overall compliance framework by reducing barriers to participation. With smoother digital verification and improved regulatory clarity, SEBI’s decision supports a more inclusive, technology-driven financial ecosystem for global Indian investors.
Background: Why Re-KYC Needed Simplification for NRIs
NRIs have long faced difficulties while completing re-KYC because most digital KYC systems required users to be physically present in India for verification. This created practical challenges for those living abroad, including time-zone differences, travel limitations, and technical issues with apps that used strict geo-tagging features. As a result, many NRIs struggled to complete re-KYC smoothly despite being active investors in India.
SEBI acknowledged these genuine challenges and took a proactive step by easing the geo-location requirements. By removing the need for NRIs to be in India during the due-diligence process, SEBI has created a more convenient and accessible system. This approach maintains regulatory integrity while ensuring NRIs can complete re-KYC effortlessly from anywhere in the world, making compliance both secure and user-friendly.
Key Highlights of the SEBI Circular
NRIs No Longer Need to Be Physically Located in India for Digital Re-KYC
One of the most impactful reforms introduced by SEBI is the relaxation of the earlier rule that required clients to be physically present in India during digital due diligence. The circular clearly states that this requirement is now waived for existing NRI clients. This change was introduced to eliminate the practical difficulties NRIs faced while completing re-KYC from abroad.
With this update, NRIs can now complete their entire re-KYC process from any country, without needing to travel to India, as long as they use approved digital KYC platforms. This ensures greater convenience and encourages smoother compliance for global investors.
App-Based KYC Platforms Must Incorporate Enhanced Verification Features
SEBI has amended Para 51 of the Master KYC Circular to strengthen the security and reliability of digital KYC systems. All KYC applications must now include several upgraded verification features, such as:
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Random Action Prompts to ensure the user interaction is live and not pre-recorded.
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Time-Stamping of Client Activities to maintain a clear and auditable trail of the verification process.
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Geo-Location Tagging, which remains mandatory, though NRIs are no longer required to physically be in India.
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GPS Coordinates Must Match the Proof of Address Country, ensuring authenticity of the user’s location.
- Blocking Spoofed IP Addresses to prevent location manipulation and fraudulent verification attempts.
Together, these enhancements make the digital KYC system more secure, transparent, and resistant to misuse.
Applicability and Legal Authority
The circular is issued under Section 11(1) of the SEBI Act, 1992, which empowers SEBI to regulate the securities market and protect investor interests.
It applies to all intermediaries registered under Section 12, including stockbrokers, depository participants, portfolio managers, investment advisors, and other regulated entities. These intermediaries must update their systems and processes to comply with the new requirements.
Availability of the Circular
SEBI has made the circular accessible through its official website under the section:
Legal → Circulars.
This ensures that all intermediaries, market participants, and investors have timely access to the guidelines and can begin implementing the required changes without delay.
Impact of the Relaxation for NRIs
Greater Convenience in Compliance
SEBI’s relaxation makes the re-KYC process far more convenient for NRIs. They can now complete verification from any country without needing to travel to India or rely on VPN-based solutions. This removes major practical challenges and allows NRIs to stay compliant effortlessly.
Enhanced Participation in the Indian Securities Market
By reducing procedural barriers, SEBI has made it easier for NRIs to maintain their investment accounts and stay active in the Indian market. This step is expected to encourage higher engagement and wider participation from global investors.
Improved System Security
Although the physical presence requirement is relaxed, SEBI still mandates strong verification methods such as GPS tagging, time-stamping, and anti-spoofing checks. These measures ensure that digital KYC remains secure, transparent, and resistant to fraud.
Reduced Operational Burden for Intermediaries
With clearer rules and simplified KYC procedures for NRIs, intermediaries like brokers, depository participants, and advisors can process re-KYC faster and more efficiently. This saves time, reduces manual effort, and improves the overall compliance experience.
What Intermediaries Must Do Now
To comply with SEBI’s revised framework, intermediaries such as brokers, depository participants, and investment advisors must update their systems and processes accordingly. First, they need to upgrade their mobile apps and KYC platforms so that all new verification features such as geo-tagging, time-stamping, and random action prompts are properly integrated. They must also enable automatic location verification to ensure that the GPS coordinates captured during re-KYC match the country mentioned in the NRI client’s Proof of Address.
In addition, intermediaries should activate strong IP spoofing detection tools to prevent manipulation of location data and ensure secure digital verification. Compliance teams must be trained on the updated re-KYC procedures so they can handle NRI requests accurately. Finally, intermediaries should communicate the new guidelines proactively to NRI clients, helping them understand the updated process and avoid delays. These actions are crucial for smooth compliance and regulatory readiness.
Conclusion
SEBI’s decision to relax geo-tagging requirements under SEBI Circular No.: HO/38/30/12(1)2025-MIRSD SEC FATF marks a major step toward making India’s securities market more accessible and convenient for NRIs worldwide. By removing the need for NRIs to be physically present in India during digital re-KYC, SEBI has created a more inclusive, flexible, and user-friendly compliance environment, enabling global investors to participate without unnecessary hurdles.
At the same time, SEBI has maintained strong digital verification safeguards to ensure that security, transparency, and authenticity remain intact. This balanced approach modernizes the re-KYC process while continuing to protect against misuse and fraud. As a result, NRIs will experience fewer operational challenges, and intermediaries will be able to process re-KYC requests more efficiently. Overall, this circular strengthens SEBI’s vision of a digitally advanced, secure, and investor-centric financial ecosystem that supports seamless compliance for all stakeholders.
