Description

SEBI Appellate Authority rejected RTI appeal seeking clarification on KYC name matching requirements with PAN and officially valid documents, ruling queries seek opinion rather than information under RTI Act.

Summary

SEBI’s Appellate Authority dismissed Appeal No. 6616 of 2025 filed by Suma against the Central Public Information Officer (CPIO). The appellant sought information on KYC name matching requirements between PAN, officially valid documents, and various financial accounts. The Authority upheld the CPIO’s response that the queries sought clarification/confirmation rather than ‘information’ as defined under Section 2(f) of the RTI Act, 2005, and directed the appellant to refer to SEBI’s Master Circular on KYC in Securities Market.

Key Points

  • Appeal filed on November 14, 2025 (Reg. No. SEBIH/A/E/25/00293) against CPIO’s response dated November 10, 2025
  • Original RTI application dated October 25, 2025 contained seven queries on KYC name matching requirements
  • Queries addressed: name matching between PAN and officially valid documents, acceptance of initials, latest SEBI instructions, Aadhaar-based e-PAN with initials, KYC completion with unexpanded initials, bank account name matching, and exemptions
  • CPIO responded that queries seek clarification/confirmation, not information under RTI Act definition
  • Appellate Authority concurred queries are not ‘information’ under Section 2(f) of RTI Act
  • Authority cited Central Information Commission precedent in Azad Singh vs. CPIO, Oriental Insurance Company Limited (March 23, 2021)
  • CPIO directed appellant to SEBI Master Circular on KYC in Securities Market available on SEBI website

Regulatory Changes

No regulatory changes introduced. This is a procedural order clarifying the scope of RTI Act obligations regarding queries seeking opinion versus factual information.

Compliance Requirements

No new compliance requirements. The order reaffirms that:

  • RTI Act does not obligate CPIOs to provide clarification, opinion, advice, confirmation, or interpretation
  • CPIOs are not required to analyze documents or create/compile information per appellant’s requirements
  • Applicants seeking KYC-related guidance should refer to SEBI Master Circular on KYC in Securities Market

Important Dates

  • October 25, 2025: RTI application filed by appellant
  • November 10, 2025: CPIO response provided
  • November 14, 2025: Appeal filed (Reg. No. SEBIH/A/E/25/00293)
  • December 10, 2025: Appellate Authority order issued (implied from document date)

Impact Assessment

Market Impact: None. This is an individual RTI appeal with no market-wide implications.

Regulatory Impact: Minimal. Reinforces existing RTI Act interpretation that distinguishes between seeking information versus seeking clarification/opinion.

Investor Impact: No direct impact. Investors seeking clarity on KYC name matching requirements should consult SEBI’s Master Circular on KYC in Securities Market rather than RTI mechanism.

Procedural Significance: Establishes precedent that KYC-related queries seeking confirmation on name matching protocols are not cognizable under RTI Act when seeking interpretation rather than existing documented information.

Impact Justification

Procedural RTI appeal order with no regulatory changes or market impact. Addresses individual query on KYC name matching clarifications, not actionable regulatory guidance.