BSE has issued guidelines pursuant to SEBI’s KYC Registration Agency (KRA) Regulations, 2011 amendment. Clients whose KYC records uploaded to KRAs between April 1–30, 2026 remain in ‘On Hold’ status (for both Aadhaar and Non-Aadhaar based OVDs) will be prohibited from trading and from squaring off open positions effective May 23, 2026. The Exchange will flag non-compliant PANs as ‘Not Permitted to Trade’ based on data provided by KRAs.

Key Points

• Clients with KYC ‘On Hold’ status for uploads made April 1–30, 2026 will be barred from trading on the Exchange from May 23, 2026
• Affected clients will also be unable to square off open positions; such positions will expire naturally on their respective contract expiry dates
• BSE will flag non-compliant PANs as ‘Not Permitted to Trade’ effective May 23, 2026, based on KRA-provided data
• Once a PAN becomes KRA-compliant, trading access is restored on T+1 from the date BSE receives the update from KRA on T Day
• Per SEBI Circular dated October 3, 2023, all Regulated Entities must block debit transactions and suspend/inactivate UCC in all Stock Exchanges for deceased investors; KRAs share demise data daily
• A list of non-compliant clients is available at the Exchange path: \EQ\Transaction\May-2026\12-05-2026\Non_Validated_Clients_by_KRAs_Clgno_xxxx.TXT

Regulatory Changes

• References SEBI Circular No. SEBI/HO/MIRSD/FATF/P/CIR/2023/0144 dated August 11, 2023 on simplification of KYC process and rationalisation of Risk Management Framework at KRAs
• References SEBI Circular SEBI/HO/OIAE/OIAE_IAD-1/P/CIR/2023/0000000163 dated October 3, 2023 on centralized mechanism for reporting investor demise through KRAs
• Continues monthly Exchange Circular series; latest prior notice was 20260415-22 dated April 15, 2026

Compliance Requirements

• Trading Members must ensure their clients’ KYC records uploaded to KRAs between April 1–30, 2026 are validated before May 23, 2026 to avoid trading restrictions
• Members must block debit transactions and suspend all trading account transactions for deceased investors and inactivate/close their UCC in all Stock Exchanges
• Members should review the non-compliant client list provided at the specified Exchange path and take corrective action
• Clients must comply with KRA validation requirements to resume trading access

Important Dates

• April 1–30, 2026: KYC upload window in scope for this circular
• May 23, 2026: Effective date from which non-validated clients will be barred from trading and squaring off positions
• T+1: Date on which trading access is restored after a PAN becomes KRA-compliant (based on KRA data received on T Day)

Impact Assessment

This circular has high operational impact on trading members with clients whose KYC validation is pending at KRAs. Affected clients face a hard trading ban including inability to manage or close open derivative positions, which will expire unmanaged. Members must proactively identify non-compliant clients using the provided file, communicate with them, and facilitate KRA validation before the May 23, 2026 deadline. The T+1 reinstatement mechanism provides a path for rapid restoration of trading access once compliance is achieved. Contact for clarifications: 022-2272 8435/5785 or ucc@bseindia.com.