Video KYC compliance: SEBI / RBI / IRDAI rules and how Finovo handles them

Originally published at finovo.tech/blog/video-kyc-compliance — the canonical version has the latest updates.

Video KYC (also called V-CIP — Video-based Customer Identification Process) is permitted by all three Indian financial-sector regulators. The rules aren't identical, but a well-designed flow can satisfy all three.

SEBI's video KYC rules

SEBI permits V-CIP for individual KYC under specific conditions:

• The video call must be live, not pre-recorded
• The broker's authorised official conducts the call (not a chatbot, not the customer's spouse)
• The customer's geo-location must be verified during the call (in India)
• The customer's PAN must be visually confirmed during the call (held up to the camera)
• The customer's face must match the photo on file (visual + algorithmic match)
• The full video is recorded and stored
• The recording includes the broker's official's identification

Reference: SEBI Master Circular on KYC + Master Direction on V-CIP.

RBI's video KYC rules (for NBFCs and banks)

RBI's V-CIP rules are very similar but have one extra:

• Random questions to confirm the customer's identity (e.g. "what's your father's name?", asked verbally and matched against the form)
• The official can only conduct V-CIP from "an approved location" (typically the official's office or registered home location)

Reference: RBI Master Direction on Video-based Customer Identification Process.

IRDAI's video KYC rules (for insurers)

IRDAI followed RBI's V-CIP guidelines mostly. Specifics for insurance:

• For high-value policies (sum insured above a threshold), video KYC may be replaced by physical verification
• Insurance-specific declarations (occupation hazards, etc.) are part of the video conversation
• Recording must be tagged with the policy reference, not just the customer ID

Reference: IRDAI circular on V-CIP.

What a single flow needs to satisfy all three

A flow that hits all three regulators' requirements:

• Live video, both sides shown
• Customer's geo-fenced (we use IP + device-GPS + browser geolocation as triangulation)
• PAN held up + visually verified by the official
• Random question per RBI (we ask 2-3 standard questions: father's name, DOB, full address)
• Official's identification visible in the recording
• Recording stored with metadata (timestamp, duration, geo, customer ID, official's employee ID)
• Tagged for the right vertical (broker / NBFC / insurer) so audit retrieval works

What goes wrong in DIY video KYC

Brokers building their own video KYC tools usually miss:

• Geo-fencing — they ask for IP location only, which the customer can VPN around
• Random questions — they hard-code the same 3 questions; auditors notice
• Recording quality — they use stock WebRTC without proper resolution / codec settings; the recording can't establish identity later
• Storage retention — they store on their own server with no automatic 8-year retention
• Audit metadata — they record the video but don't tag it with the structured metadata regulators want

Operator side

Video KYC requires real humans on the operator side. We staff:

• IST business hours: full coverage with 30-90 second wait times
• IST early morning / late evening: limited coverage, customers can schedule a slot
• NRI customers: GMT + EST + AEST coverage for high-volume markets

Operator training is regulator-mandated: each operator goes through a 40-hour V-CIP curriculum + recurrent annual training. We maintain the training records for audit.

When video KYC isn't required

Video KYC is mandatory in some cases (high-risk customers, certain product categories) and optional in others (low-risk retail individual KYC). The regulators allow other PD methods:

• In-person verification at a branch (still common for HNI)
• Aadhaar e-sign + standard fields (for lowest-risk retail in some product categories)

A smart KYC flow uses video PD only when required, not by default. This drops cost and improves customer experience.

For a deeper dive, see our video kyc cost.

Cost considerations

Video KYC has a meaningful per-call cost — operator time + recording storage + bandwidth. Typical cost: ₹20-40 per video PD at scale, vs ₹6-8 for Aadhaar OTP.

For high-risk customer flows, mandatory. For low-risk retail, decisively skip when allowed.