CIRCULAR
HO/38/30/12(1)2025-MIRSD-SEC-FATF December 10, 2025
To,
1. Intermediaries registered with SEBI under Section 12 of the Securities and
Exchange Board of India Act, 1992
2. Stock Exchanges
Dear Sir/Madam,
Subject: Relaxation on geo-tagging requirement in India for NRIs while
undertaking re-KYC
1. Based on references received from multiple stakeholders to ease KYC access for
Non-Resident Indians (NRIs), SEBI has decided to modify the existing provisions
under Master Circular on KYC dated October 12, 2023 to ease re-KYC process for
NRIs.
2. In this respect, the requirement of physical location being in India shall be relaxed
for NRI clients to undertake due diligence through digital mode.
3. Accordingly, Para 51 of Master Circular on KYC shall be modified as under;
The App shall also have features of random action initiation for client
response to establish that the interactions are not pre-recorded along with
time stamping and geo-location tagging to ensure the requirement like
physical location being in India etc. are also implemented. The requirement
of physical location of client being in India during digital on boarding shall
be relaxed for undertaking re-KYC for existing clients.
The App shall also ensure that the GPS location (latitude and longitude)
captured by the intermediary matches with the latitude and longitude of
country given in Proof of Address given by the client. The app shall prevent
connections from spoofed IP address.
Page 1 of 2
4. This circular is being issued in exercise of the powers confined under Section 11(1)
of the Securities and Exchange Board of India Act, 1992
5. This circular is available at www.sebi.gov.in under the link “Legal -> Circulars”
Yours faithfully,
Sapna Sinha
Deputy General Manager
Phone No. 022-2644 9748
Email id: sapnas@sebi.gov.in
Page 2 of 2