NSE’s Inspection Department has issued a Master Circular containing FAQs on account opening and KYC procedures for persons with disability. The circular aims to make the securities market more inclusive by clarifying processes for intermediaries, including brokers and mutual funds, when establishing account-based relationships with persons with disability.

Key Points

• Persons with disability can establish account-based relationships in the securities market.
• Guardianship is only required where legally mandated; intermediaries may rely on Guardianship Certificates issued under the National Trust for Welfare of Persons with Autism, Cerebral Palsy, Mental Retardation and Multiple Disabilities Act, 1999.
• Accounts can be opened with the guardian’s signature if the person with disability is unable to sign.
• Both the guardian and the person with disability must comply with applicable KYC norms.
• Persons with disability are classified as minor or major based on age (18 years is the threshold for majority).
• Online/digital KYC is available to persons with disability, with intermediary assistance for video-based processes.
• Liveliness checks may use alternatives to eye-blinking, such as live facial expressions, head nodding, OTP display on screen, or real-time video recording.
• SEBI Master Circular on KYC dated October 13, 2023 governs the applicable account opening forms.

Regulatory Changes

No new regulations are introduced. This circular consolidates and clarifies existing SEBI KYC requirements under the SEBI Master Circular on KYC (October 13, 2023), the Mental Health Care Act, 2017, and the National Trust for Welfare of Persons with Autism, Cerebral Palsy, Mental Retardation and Multiple Disabilities Act, 1999.

Compliance Requirements

• Intermediaries (brokers, mutual funds, and all entities establishing account-based relationships) must follow the uniform KYC process in an accessible and inclusive manner for persons with disability.
• Intermediaries must extend assistance for video capturing in a live environment for online/digital KYC on client request.
• Liveliness verification must accommodate persons who cannot blink, using alternative parameters as outlined.
• Guardian KYC compliance is mandatory alongside the person with disability’s KYC where a guardian is involved.
• Intermediaries must refer to the SEBI Master Circular on KYC (October 13, 2023) for applicable account opening forms.

Important Dates

• Reference circular: SEBI Master Circular on KYC dated October 13, 2023.
• FAQs on demat and trading account opening for minors: September 25, 2018 (available on SEBI website).
• No new deadlines specified in this circular.

Impact Assessment

This circular has a medium compliance impact on all SEBI-registered intermediaries, particularly brokers and mutual funds. It does not impose new obligations but clarifies operational procedures for an underserved segment. Intermediaries may need to review and update their KYC onboarding workflows and staff training to ensure accessibility standards are met for persons with disability, including digital KYC and liveliness-check alternatives. No direct market or stock-price impact is expected.