Description

BSE mandates trading members to upload and validate all active client KYC records with KRAs by September 26, 2025, reducing timeline from 10 days to 3 working days.

Summary

BSE has issued a mandatory compliance notice requiring all trading members to upload and validate KYC records of active clients with KYC Registration Agencies (KRAs) by September 26, 2025. This follows non-compliance observations where trading members failed to adhere to SEBI’s reduced timeline of 3 working days for KYC uploads. Only clients with “KYC Registered” or “KYC Validated” status will be permitted to trade.

Key Points

  • Trading members must upload all active client KYC records to KRAs by September 26, 2025
  • Only clients with “KYC Registered” or “KYC Validated” status can trade
  • Sample comparison revealed non-compliance with SEBI circular requirements
  • Non-upload of KYCs violates regulatory requirements and affects market interoperability
  • Members must monitor open positions of non-compliant clients

Regulatory Changes

  • Timeline for KYC document submission reduced from 10 working days to 3 working days (SEBI Circular October 12, 2023)
  • Clients can open accounts and transact immediately after KYC completion
  • Clients with unverified attributes cannot transact until verification is complete

Compliance Requirements

  • Upload all active client KYC information to KRA systems
  • Send physical KYC documents to KRAs within 3 working days of KYC completion
  • Maintain proof of dispatch for KYC documents
  • Ensure only KYC Registered or KYC Validated clients are permitted to trade
  • Monitor open positions of non-compliant clients and take appropriate measures
  • Contact respective KRAs for queries regarding client status

Important Dates

  • September 26, 2025: Final deadline for all active client KYC records to be uploaded and validated/registered by KRAs
  • September 03, 2025: Notice issued date

Impact Assessment

High Impact: This circular affects all trading members and their active clients. Non-compliance will result in trading restrictions for clients whose KYC records are not properly uploaded and validated. Trading members face operational challenges in ensuring all historical client records are compliant within the given timeframe. The requirement ensures seamless interoperability across market participants and prevents investor inconvenience, but may temporarily restrict trading for non-compliant accounts.

Impact Justification

Critical compliance requirement with firm deadline affecting all trading members and their active clients' ability to trade