Video-KYC Process Checklist for NBFCs (2026 Rules)
A compliant Video-KYC process for a Non-Banking Financial Company (NBFC) needs a live, consent-based video call in which a trained Regulated Entity (RE) official verifies identity with liveness detection, geotagging, random questions and a complete audit trail — exactly as the Reserve Bank of India (RBI) Master Direction on Know Your Customer (KYC) requires.
This is an explainer, not legal advice. NBFCs should confirm every step with their compliance and legal teams and the latest RBI circulars before going live.
Key fact: YuVerse platforms have processed 1 million+ documents across Indian lending journeys, so the identity and Video-based Customer Identification Process (V-CIP) checks below are drawn from real, high-volume onboarding.
What Does RBI's V-CIP Rule Require?
RBI introduced the Video-based Customer Identification Process (V-CIP) through an amendment to its KYC Master Direction on 9 January 2020, and has updated it since. RBI defines V-CIP as "a method of customer identification by an authorised official of the RE by undertaking seamless, secure, live, informed-consent based audio-visual interaction with the customer."
In plain terms, a V-CIP session is treated on par with a face-to-face KYC — it is not a shortcut. The rules apply to every NBFC that onboards customers remotely, whether for a ₹50,000 personal loan or a ₹5 lakh business loan.
The core requirements the RBI Master Direction sets out include:
- Live, real-time interaction — no pre-recorded video, screenshots or stored clips.
- Liveness detection to confirm a real person is present, not a photo or deepfake.
- Geotagging of the customer to confirm they are physically in India.
- An authorised, trained RE official driving the call (not an outsourced agent taking independent decisions).
- Random questions to establish the session is genuine and live.
- Explicit customer consent recorded at the start.
- A tamper-proof audit trail with date, time stamp and secure storage.
Why Is a V-CIP Checklist Critical for NBFCs?
Because a single missed step can invalidate the whole onboarding. If liveness is not captured, or the RE official is not the one asking the questions, the account can be treated as improperly verified — exposing the NBFC to regulatory action and rework.
A checklist also protects customers. Anti-Money Laundering (AML) and fraud controls depend on knowing the borrower is real, present and consenting. For an NBFC running thousands of digital loans a month, a repeatable checklist is the difference between clean books and expensive remediation. It also pairs well with a strong document workflow — see how lenders automate KYC document verification with AI.
Step-by-Step V-CIP Compliance Checklist
Use this checklist for every remote onboarding. Map each step to the RBI requirement it satisfies.
# | Step | What to do | RBI requirement it meets |
|---|---|---|---|
1 | Consent capture | Record the customer's explicit, informed consent to a video interaction and data use | Informed-consent based interaction |
2 | Live session start | Launch a real-time video call; block uploads of recorded video | Live, seamless audio-visual interaction |
3 | Liveness check | Run passive/active liveness to confirm a live human, not a photo, mask or deepfake | Liveness verification |
4 | Geotagging | Capture and store the customer's live location to confirm presence in India | Customer located in India |
5 | Identity verification | Verify Permanent Account Number (PAN), Aadhaar (offline/XML) and face match against the identity document | Customer Due Diligence (CDD) |
6 | Random questions | The RE official asks unscripted, random questions to confirm the session is genuine | Random-question integrity check |
7 | RE official action | An authorised, trained official conducts the call and takes the KYC decision | Authorised RE official |
8 | Document validation | Confirm documents are current and unaltered; check for tampering | Genuine, valid documents |
9 | Audit trail | Store the recording with date, time stamp, official ID and activity log | Time-stamped, auditable record |
10 | Secure storage | Keep records in encrypted, access-controlled storage | Data security and retention |
Compliance notes: Every field above must trace back to the RBI Master Direction on KYC and the 9 January 2020 V-CIP amendment. The RE official — not a third-party vendor — must make the KYC decision. Never store or reuse a recorded video as a substitute for a live call. If any critical step fails during the call, the session should be abandoned and restarted, not patched afterwards.
How AI Helps NBFCs Run Compliant Video-KYC
AI does the heavy, repeatable checks so your RE official can focus on judgement. YuAccess runs passive liveness, face match against the identity document, geotag capture and document-tampering checks in real time, and writes a time-stamped, tamper-evident audit trail for every session.
The official still drives the interaction and takes the final KYC decision — AI simply flags a fake face, a mismatched document or a missing geotag before the loan is disbursed. For NBFCs onboarding thousands of borrowers a month, that means fewer rejected files, faster turnaround and a cleaner trail if a regulator ever asks. To go deeper, see how NBFCs approach CKYC and VKYC automation and video KYC automation for banks and NBFCs.
FAQ
Q1. Is Video-KYC legally valid for NBFCs in India? Yes. RBI's KYC Master Direction treats a compliant V-CIP session on par with face-to-face KYC. The NBFC must follow every requirement — live interaction, liveness, geotagging, RE official, random questions, consent and audit trail.
Q2. Can an NBFC outsource the Video-KYC call to a vendor? Technology can be provided by a vendor, but the KYC decision and the live interaction must be handled by an authorised, trained official of the Regulated Entity. The RE remains fully responsible for compliance.
Q3. Why are liveness and geotagging mandatory? Liveness stops photos, masks and deepfakes from passing as a real customer. Geotagging confirms the customer is physically present in India. Together they anchor the identity check and reduce fraud.
Q4. How long must V-CIP records be retained? Records — including the recording, time stamp and activity log — must be stored securely and retained as per the RBI KYC Master Direction and applicable record-keeping rules. Confirm the exact retention period with your compliance team.
Q5. What happens if a step is missed during the call? Treat the session as incomplete. Do not patch it afterwards with a screenshot or recorded clip. Restart a fresh, live V-CIP session so the audit trail stays clean.
Q6. Does Video-KYC replace document checks entirely? No. V-CIP includes verifying valid, current documents and matching them to the live customer. It is an end-to-end identity process, not just a video call.
Conclusion
Video-KYC is now a mainstream way for NBFCs to onboard borrowers, but the rules are strict for good reason. Run the ten-step checklist above on every session, keep the RE official in control, and store a clean audit trail. Do that consistently and remote onboarding becomes both fast and defensible.
Bring compliant, AI-assisted Video-KYC to your onboarding. Talk to the YuVerse team to see YuAccess in action.
References
- Reserve Bank of India — Master Direction – Know Your Customer (KYC) Direction, 2016 (updated) — https://www.rbi.org.in/Scripts/BS_ViewMasDirections.aspx?id=11566
- Reserve Bank of India — Amendment to the Master Direction on KYC (V-CIP), 9 January 2020 — https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=11783&Mode=0
