Re-KYC has become a recurring operational and compliance obligation for regulated entities in India. As customer profiles age, documents expire, and risk classifications change, regulators expect institutions to periodically revalidate customer information to ensure ongoing compliance with KYC norms.
With the RBI KYC Directions (Amendment), 2025, the Reserve Bank of India has introduced greater clarity—and greater accountability—around how regulated entities must communicate with customers during the Re-KYC process. A key emphasis of these amendments is the manner, frequency, and provability of customer outreach, particularly when customers remain non-responsive.
This article explains the communication-related expectations introduced by the 2025 amendments, with specific focus on the role of physical letters in Re-KYC compliance.
Why Communication Is Central to Re-KYC Compliance
Re-KYC is not limited to internal record updates or backend verification. From a regulatory perspective, it is a customer-facing process that requires demonstrable effort by the regulated entity to inform, remind, and follow up with customers whose KYC needs renewal.
RBI’s concern is not only whether Re-KYC was completed, but whether the institution made reasonable and documented efforts to engage the customer before taking restrictive actions such as account freezing, transaction limitations, or relationship termination.
As a result, communication has moved from being an operational task to a compliance requirement.
Key Communication Expectations Under RBI’s 2025 Amendments
The 2025 amendments to the KYC Directions reinforce three core expectations related to Re-KYC communication:
1. Multiple Communication Attempts Are Mandatory
Regulated entities are expected to initiate multiple reminders to customers whose Re-KYC is due or overdue. These reminders must be spread across the Re-KYC lifecycle—before the due date, around the due date, and after non-compliance is observed.
A single notification or one-time reminder is no longer sufficient to demonstrate compliance.
2. Physical Communication Is Explicitly Required
Even where digital communication channels are available, the amended directions require that at least one physical communication be sent to the customer if they remain non-responsive.
This requirement is particularly relevant for:
- Dormant or low-engagement accounts
- Customers with outdated contact details
- Legacy accounts where digital adoption is limited
The inclusion of physical communication reflects RBI’s position that digital channels alone may not be adequate in all cases.
3. Communication Must Be Provable and Auditable
Beyond sending reminders, regulated entities must be able to demonstrate evidence of outreach.
This includes:
- When communication was initiated
- Through which channel
- To which customer address or contact detail
- Whether the attempt was successfully executed
During supervisory reviews or audits, institutions may be required to produce this evidence at a customer or account level.
The Practical Challenges Institutions Face
While the regulatory expectations are clear, execution presents several challenges—especially with physical letters.
Non-Responsiveness to Digital Channels
Many institutions report that a significant portion of Re-KYC reminders sent via SMS, email, or app notifications receive no response. Customers may have changed phone numbers, stopped checking certain inboxes, or disengaged from digital platforms altogether.
This makes physical outreach a necessary escalation rather than an optional step.
Operational Complexity of Physical Letters
Physical letters introduce complexities that digital channels do not:
- Printing and dispatch coordination
- Dependency on third-party delivery partners
- Address accuracy concerns
- Delayed confirmation of dispatch or delivery attempts
As a result, physical communication is often handled outside core systems, increasing the risk of gaps in documentation.
Weak Audit Trails
In many cases, proof of letter dispatch exists only in fragmented forms such as:
- Vendor invoices
- Email confirmations
- Manual registers or spreadsheets
These artefacts are difficult to reconcile during audits and may not meet RBI’s expectation of system-recorded, easily retrievable evidence.
Why Physical Letters Continue to Matter to the Regulator
From a regulatory standpoint, physical letters serve a specific purpose.
They represent:
- A last-mile attempt to reach the customer
- Evidence that the institution did not rely solely on convenience-driven channels
- A defensible measure of “reasonable effort”
RBI does not assume customer intent. Instead, it evaluates whether the regulated entity followed due process before concluding non-compliance.
Physical letters help establish that due process.
Letter Delivery as Part of Re-KYC Infrastructure
Given the regulatory emphasis, physical letter delivery increasingly needs to be treated as part of Re-KYC infrastructure, rather than as an ad-hoc operational activity.
An effective approach typically includes:
- Automated triggering of letters for non-responsive Re-KYC cases
- Standardised dispatch processes
- Digital logging of dispatch and delivery attempts
- Centralised reporting for audit and compliance teams
This reduces dependency on manual coordination and improves consistency across portfolios.
OnGrid’s Letter Delivery Capability for Re-KYC
Within this regulatory context, OnGrid offers a structured approach to physical letter delivery specifically designed for Re-KYC compliance.
The capability focuses on enabling end-to-end traceability of physical communication, including:
- Triggered letter dispatch for Re-KYC pending customers
- Physical delivery through verified partners
- Digital proof of dispatch and delivery attempts
- System-level logs aligned to audit and supervisory needs
The intent is not customer engagement or marketing, but regulatory documentation and audit readiness.
Who This Matters For
The 2025 amendments have implications across multiple functions within regulated entities:
- Compliance teams, responsible for regulatory adherence
- Risk and governance teams, accountable for audit outcomes
- Operations teams, managing execution at scale
- Digital KYC and Re-KYC owners, integrating workflows
For these stakeholders, the ability to demonstrate compliant communication is as important as completing the Re-KYC itself.
What Physical Letter Delivery Is — and Is Not
It is important to distinguish regulatory letter delivery from other use cases.
This is:
- Not bulk postal advertising
- Not marketing communication
- Not customer engagement outreach
It is a compliance mechanism, activated when digital channels fail or are insufficient.
Closing Note
RBI’s 2025 Re-KYC amendments reinforce a broader regulatory trend: processes must be provable, not just designed.
For regulated entities, this means ensuring that every step of Re-KYC—especially customer communication—can withstand supervisory scrutiny. Physical letters, while operationally demanding, remain a required component of that process.
Understanding and systematising this requirement is essential for institutions operating under RBI regulation.
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