CKYC 2.0 Update: CERSAI Sets CKYCRR 1.0 Cut-Off for Reporting Entities

Table of Contents

CKYC 2.0 update explaining CERSAI’s CKYCRR 1.0 cut-off for Reporting Entities in India.

CKYCRR 1.0 Enters Its Final Transition Phase

CKYCRR 2.0 is an upgraded, API-driven overhaul of India’s Central KYC Records Registry, and the transition from CKYCRR 1.0 has reached an important operational stage for Reporting Entities in India.

On 12 October 2026, CERSAI issued Notification No. CERSAI/CKYCRR 2.0/26-27/11214, with the registry operated by CERSAI under India’s PMLA framework and the money laundering act, setting final cut-off dates for updating Reporting Entity user details, changing RE registration information and completing pending registration requests in CKYCRR 1.0. The notification follows the completion of UAT and pilot testing for CKYCRR 2.0, which is expected to become available tentatively in the first week of November 2026.

For banks, NBFCs, fintechs and other regulated financial institutions, the immediate focus is therefore shifting from preparation to transition. Reporting Entities need to understand which activities have now closed in CKYCRR 1.0, which registrations must be restarted, and what should be prepared before CKYCRR 2.0 becomes available as the move shifts from the legacy batch-upload system toward real-time data verification.

For a broader view of how the two environments differ, see ZIGRAM’s CKYC 2.0 vs CKYC 1.0 guide.

Key Takeaways

  • Changes to RE user and registration details in CKYCRR 1.0 were permitted only up to 13 October 2026.

  • Existing RE registration requests were to be approved or rejected by 14 October 2026.

  • Approved REs were required to complete testbed activity by 15 October 2026.

  • Registration requests marked “On Hold” are to be rejected.

  • Rejected registrations, including those with incomplete testbed activity, must be registered afresh in CKYCRR 2.0.

  • CKYCRR 2.0 is tentatively expected to become available in the first week of November 2026.

What Has CERSAI Announced for CKYCRR 1.0?

The latest CERSAI CKYC notification from the Central Registry of Securitisation Asset Reconstruction and Security Interest of India sets a clear end point for specific Reporting Entity registration and user-management activities in CKYCRR 1.0. The change applies to details relating to the:

  • Nodal Officer

  • Institutional Admin User

  • authorised Sub-Users

  • Reporting Entity registration information

Any request to modify these details had to be submitted through CKYCRR 1.0 by 13 October 2026, along with the required supporting documentation where applicable. After this date, such changes are no longer permitted in the existing system and will instead need to be processed through CKYCRR 2.0 once it becomes available.

The notification also closes pending RE registration activity in CKYCRR 1.0, creating separate outcomes depending on the status of each request.

CKYCRR 1.0 Cut-Off Dates at a Glance

CKYCRR 1.0 Activity

Cut-Off / Outcome

What Reporting Entities Need to Know

Update RE user or registration details

13 October 2026

Further changes must wait for CKYCRR 2.0

Existing RE registration requests

14 October 2026

Requests to be either approved or rejected

Testbed completion for approved REs

15 October 2026

Failure to complete testbed leads to rejection

Registration requests marked “On Hold”

Rejected

Fresh registration may be required

Rejected or incomplete registrations

CKYCRR 2.0

Must register afresh in the new environment

CKYCRR 2.0 availability

Tentatively first week of November 2026

REs should prepare for the next onboarding stage

This timetable effectively closes outstanding CKYC registration activity under the legacy Reporting Entity process before the new registry environment becomes available.

What Happens to Existing RE Registration Requests?

The outcome depends on how far the Reporting Entity had progressed before the cut-off.

Registration approved and testbed completed

Where registration was approved and the prescribed testbed activity was completed by the deadline, the Reporting Entity can shift its focus to CKYCRR 2.0 readiness and onboarding.

Registration approved but testbed incomplete

Approved REs that did not complete the required CKYCRR 1.0 testbed activity by 15 October 2026 will have their registrations rejected.

These entities will need to register afresh in CKYCRR 2.0.

Registration already rejected

Rejected registration requests will not simply carry forward into the new environment.

The Reporting Entity will need to begin a fresh CKYCRR 2.0 registration process once the new system is made available.

Registration marked “On Hold”

CERSAI has stated that registration requests with an “On Hold” status will be rejected.

This makes it important for Reporting Entities to confirm the final status of every CKYCRR 1.0 request rather than assume that unresolved applications will migrate automatically.

What Happens to RE User Details After the Cut-Off?

The notification also creates a firm break between the two systems for Reporting Entity user administration. Changes involving a Nodal Officer, Institutional Admin User, Sub-User or RE registration details are no longer permitted through CKYCRR 1.0 after 13 October.

If an institution still needs to make one of these changes, it will need to wait until the relevant CKYCRR 2.0 functionality becomes available. This has a practical implication: institutions should already know whether their current authorised-user structure is accurate.

A mismatch discovered only after CKYCRR 2.0 becomes operational could delay access, registration or subsequent CKYC activity.

Does the Cut-Off Apply to All Customer CKYC KYC Data Updates?

No. This is an important distinction. The October notification is specifically concerned with: Reporting Entity user details → RE registration details → completion of RE registration requests in CKYCRR 1.0

It should not be interpreted as a blanket deadline for every customer CKYC record or customer KYC update. Reporting Entities continue to have separate obligations for maintaining and updating applicable customer KYC information under the broader regulatory framework, even where ckyc data is retrieved from the central registry, because those customer records are verified KYC records stored centrally for reuse across institutions and are meant to reduce repeated document submissions, which is separate from the Reporting Entity administration cut-off discussed here. CKYC is a verification record, not a financial account.

For RBI-regulated entities, these continuing obligations are governed by the RBI Master Direction on Know Your Customer (KYC), which sets out requirements for customer identification, due diligence and maintenance of KYC information.

This distinction matters because the term CKYC update can refer to two very different activities:

  1. updating customer KYC information in the Central KYC Records Registry; and

  2. updating the administrative details of the Reporting Entity interacting with the registry.

The present CERSAI notification is primarily about the second category.

Why the Cut-Off Matters for CKYC 2.0

The notification is significant because it moves the CKYCRR 2.0 transition beyond testing and preparation. Earlier phases of the programm focused on Reporting Entity onboarding, API integration, customer consent through OTP for record retrieval, UAT, testbed activity and pilot testing, with data access designed to meet stronger privacy expectations under the DPDP Act. CERSAI has now completed UAT and pilot testing, while the latest cut-off closes specific legacy registration processes in CKYCRR 1.0.

This creates a much clearer operational transition:

CKYCRR 1.0 activities close → unresolved registrations are identified → CKYCRR 2.0 becomes available → fresh registration or pending changes move to the new environment, with improved data quality controls intended to reduce duplicate records and fraud.

That makes this period particularly important for Reporting Entities that still have administrative, registration or testbed issues outstanding.

Institutions looking at the wider technology and operating-model change can also refer to ZIGRAM’s CKYC 2.0 batch upload guide, which examines the shift from legacy file-based processing toward more structured, integrated CKYC workflows, alongside essential CKYC 2.0 API integration for loan origination in real-time digital lending journeys.

Regulatory and Practical Impact on Regulated Entities

Regulatory Impact

The cut-off creates a defined end point for specific CKYCRR 1.0 activities and gives Reporting Entities less room to leave registration or authorised-user issues unresolved.

Institutions across the financial sector need to ensure that their final CKYCRR 1.0 status is known and that any activity which must now move to CKYCRR 2.0 is clearly identified.

The notification also reinforces the need for accurate RE registration information and properly maintained user roles before institutions enter the next phase of the Central KYC Records Registry, which is intended to standardize KYC records across sectors, improve compliance consistency, support regulated entities, and help institutions meet evolving regulatory requirements when they rely on shared CKYC records, including those operating under IFSCA AML/CFT and KYC amendments 2026.

Practical Impact

Operationally, the transition may affect institutions differently depending on their current status.

Reporting Entities with approved registrations and completed testbed activity are primarily preparing for the new environment, including the workflow changes that support faster customer onboarding for a financial institution once the new setup is live. Before collecting fresh documents, the institution can first check the central registry for an existing record. Once customer verification is completed and the institution uploads the verified details, the reusable CKYC record supports faster onboarding across participating institutions. In successful digital flows, competitors often position the upgraded process as bringing onboarding time to under 5 minutes.

Entities with rejected or incomplete registrations, however, need to prepare for fresh registration in CKYCRR 2.0.

Institutions that missed a user-detail or RE-registration update should also record that requirement now rather than rediscover it after CKYCRR 2.0 goes live.

The practical challenge is therefore less about completing another broad CKYC migration exercise and more about ensuring that nothing unresolved in CKYCRR 1.0 becomes an access or registration problem in CKYCRR 2.0, while a cleaner transition can also help reduce operational costs tied to manual follow-up and document handling. Even with a CKYC record available, compliance teams still need to handle risk assessment and decide whether extra information is required.

What Reporting Entities Should Do Now

Reporting Entities should use the transition period before CKYCRR 2.0 availability to complete four immediate checks.

1. Confirm the final status of each RE registration

Identify whether each registration is:

Approved | Rejected | Testbed incomplete | On Hold

Any rejected or incomplete cases should be prepared for fresh registration in CKYCRR 2.0.

2. Review authorised-user details

Confirm the current Nodal Officer, Institutional Admin User and authorised Sub-Users.

Where a required change missed the 13 October deadline, record it as a CKYCRR 2.0 follow-up action.

3. Prepare supporting documents in advance

Rejected or fresh registrations should not begin with another round of document collection after CKYCRR 2.0 becomes available.

Reporting Entities can use the current transition period to verify entity details, authorisations and supporting documentation, especially because clean registration matters when CKYC is usable across banks, NBFCs, and mutual funds.

4. Track unresolved items centrally

Maintain one clear exception list covering registration status, testbed issues, user changes and supporting-document gaps.

Where the issue relates to customer-data quality, duplicate records or validation failures rather than RE registration, ZIGRAM’s data remediation for CKYC 2.0 guide covers that problem separately, including customer information cleanup before submission; CKYCRR 2.0 uses standardized data structures that make KYC record updates easier, and once those data issues are remediated, automated update and retrieval workflows are expected to improve operational efficiency.

Preparing for CKYCRR 2.0 Beyond CKYC Registration

Registration readiness is only one part of the wider CKYC 2.0 transition. Financial institutions also need to consider whether their existing KYC systems, customer data and operational processes are ready for a more structured digital environment. CKYCRR 2.0 introduces structured XML and JSON formats for customer data.

ZIGRAM’s earlier CKYC research highlights several areas institutions are already addressing, including cleaner customer data with mandatory Aadhaar masking as part of improved data quality controls, stronger validation through DigiLocker-based instant document validation and stricter document quality standards, improved exception handling and integration between onboarding systems and the Central KYC Records Registry. automated aadhaar masking also helps prepare records for submission while protecting sensitive customer information. The upgraded system also uses AI for deduplication and fraud prevention. The immediate notification, however, should be treated narrowly: first establish the final CKYCRR 1.0 position, then prepare the organisation to enter CKYCRR 2.0 cleanly, rather than relying on the more static document storage and batch processing common in CKYC 1.0.

That is the priority before the next phase begins.

What Happens Next?

According to the notification, CKYCRR 2.0 is tentatively expected to become available in the first week of November 2026. As outlined after the union budget announcement, implementation is phased, starting with banks and insurance providers.

Until then, Reporting Entities should focus on closing the gap between their final CKYCRR 1.0 status and what they will need in the new environment.

The transition is therefore no longer only about understanding CKYC 2.0.

It is about ensuring that:

registrations are accounted for, authorised users are known, unresolved cases are documented, and fresh-registration requirements are ready before CKYCRR 2.0 opens, with the longer-term direction being a unified, cross-sectoral network for KYC processes.

Frequently Asked Questions

What is the CKYCRR 1.0 cut-off date for Reporting Entity changes?​

Changes to Nodal Officer, Institutional Admin User, Sub-User and RE registration details in CKYCRR 1.0 were permitted only up to 13 October 2026.

CERSAI has indicated that CKYCRR 2.0 is tentatively expected to become available in the first week of November 2026.

Reporting Entities with rejected registration requests, including approved registrations where the required testbed activity was not completed, must register afresh in CKYCRR 2.0.

The notification states that registration requests marked “On Hold” will be rejected.

No. Changes to RE user and registration details are no longer permitted through CKYCRR 1.0 after 13 October 2026. Such changes will need to be made through CKYCRR 2.0 once available.

No. The notification focuses on Reporting Entity user details, RE registration details and completion of RE registration requests in CKYCRR 1.0. It should not be interpreted as a blanket freeze on all customer KYC updates. For CKYC registration, applicants typically need PAN, one of the required officially valid documents, and a recent photograph. Examples include Aadhaar, passport, and voter ID. Additional documents may be requested depending on customer type, and registration typically completes within 10 working days.

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