KYC Framework in Light of Aadhaar 2025 Amendment Regulations
RBI’s recent supervisory reviews of NBFCs repeatedly highlight one area of non-compliance: Aadhaar misuse in KYC — especially accepting unmasked Aadhaar copies , failing to obtain mandatory consent , or performing unauthorised Aadhaar verification . On 9 December 2025 , UIDAI notified the Aadhaar (Authentication and Offline Verification) Amendment Regulations, 2025 to amend the 2021 Regulations . This blog summarises what NBFCs must do now — and what must immediately stop. Key Amendments: 1. New Definitions Introduced: (i) " Aadhaar Application" [Reg. 2(1)(ac)]- UIDAI now defines authorised mobile/web applications — including mAadhaar, Aadhaar App, QR Scanner App, myAadhaar Portal — which alone may be used to perform offline Aadhaar verification. NBFC implication: All offline Aadhaar verification must be done only through these UIDAI-approved apps/tools. (ii) "Aadhaar Verifiable Credential (AVC)" [Reg. 2(1)(be)]- A new digital do...