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Rule 240 Indicia under Income-tax Rules 2026 — Individual Account Due Diligence

The rule 240 indicia search under the Income-tax Rules, 2026 tests six markers of foreign residence in a reporting financial institution's electronic records, with an enhanced...

Vikas Sharma Tax & Compliance Expert
11 min read 6 views Updated Sep 9, 2026 Expert Reviewed High Complexity In-Depth Guide 2,300+ words
Rule 240 Indicia under Income-tax Rules 2026 — Individual Account Due Diligence
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Last updated: September 2026Applies to: FY 2026-27 (AY 2027-28)Verified against: Government sources
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The rule 240 indicia search under the Income-tax Rules, 2026 tests six markers of foreign residence in a reporting financial institution's electronic records, with an enhanced paper and relationship-manager review for accounts above USD 1 million, and requires a self-certification at account open…

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The four populations the rule 240 indicia search covers

Rule 240 divides every account into one of four populations by when it was opened and who holds it, and applies a different procedure to each. The 1962 parallel is rule 114H. This article deals with the two individual populations; entity accounts and the aggregation rules are dealt with separately.

TermMeaning under rule 240(2)
Pre-existing accountMaintained as on 30 June 2014 (U.S.) or 31 December 2015 (other) — or 31 December 2025 where it is a financial account only by virtue of the CRS amendments
New accountOpened on or after 1 July 2014 (U.S.) or 1 January 2016 (other) — or 1 January 2026 for the CRS-amendment accounts
High value accountA pre-existing individual account exceeding the equivalent of USD 1 million as on 30 June 2014 or 31 December 2015 respectively, or any subsequent 31 December
Lower value accountA pre-existing individual account exceeding USD 50,000 but not USD 1 million as on 30 June 2014 (U.S.); or not exceeding USD 1 million as on 31 December 2015 (other)
The 31 December 2025 and 1 January 2026 dates are the new layer

Most of the dates in rule 240(2) are carried forward from the 2014 FATCA and 2016 CRS start. Two are new, and they are the ones a bank has to act on now: an account that becomes a financial account solely by virtue of the amendments to the Common Reporting Standard — principally accounts holding specified electronic money products and central bank digital currencies — is pre-existing if held at 31 December 2025 and new if opened on or after 1 January 2026. That population has its own cut-over, a decade after the original one, and it is easy to miss inside a data model built for 2016.

Which pre-existing individual accounts need no review

Sub-rule (3)(a): a pre-existing individual account is not required to be reviewed, identified or reported where, for a U.S. reportable account:

  • the balance does not exceed USD 50,000 as on 30 June 2014; or
  • it is a cash value insurance or annuity contract not exceeding USD 250,000 as on that date; or
  • it is such a contract which the institution is legally prevented from selling to a U.S. resident;

and, for other reportable accounts, where it is a cash value insurance or annuity contract the institution is legally prevented from selling to a person not resident in India. Note that the USD 50,000 and USD 250,000 de minimis thresholds exist only on the U.S. side; CRS has no equivalent for individual accounts.

The six rule 240 indicia

For a lower value account, sub-rule (3)(b)(i) requires an electronic search of the institution's searchable data for any of these rule 240 indicia:

ItemIndicium
(A)Identification of the holder as a resident of a foreign country for tax purposes, or an unambiguous indication of a place of birth in the United States
(B)A current mailing or residence address abroad, including a post office box
(C)One or more foreign telephone numbers and no Indian telephone number
(D)Standing instructions to transfer funds to an account abroad — for CRS, other than a depository account
(E)A currently effective power of attorney or signatory authority granted to a person with a foreign address
(F)A hold mail instruction or in-care-of address abroad, where the institution has no other address on file

The consequences follow directly:

  • No indicium found — no further action until a change in circumstances produces one, or the account becomes a high value account.
  • Any of (A) to (E) found — treat the holder as resident for tax purposes of each country for which an indicium is identified, unless the institution elects to apply the cure procedures.
  • Only (F) found — apply the paper record search, or seek a self-certification or documentary evidence; if both fail, report the account as an undocumented account.
Item (F) is the one that creates an undocumented account

Five of the six rule 240 indicia point somewhere — they name a country, and the account is treated as reportable to it. Item (F) does not: a hold mail instruction or an in-care-of address with no other address tells the institution the holder is somewhere else without saying where. That is why it alone triggers the fallback in sub-clause (iv), and why, if the paper search and the request for documentation both fail, the account is reported as undocumented rather than to any jurisdiction. Undocumented status is also the one condition under which the enhanced review must be re-applied annually.

Curing one of the rule 240 indicia

Sub-rule (3)(b)(v) lets an institution avoid treating a holder as foreign resident despite an indicium, on stated documentation:

IndiciumCure
U.S. place of birthA self-certification that the holder is neither a U.S. citizen nor a U.S. tax resident; a passport or other Government identification showing another nationality; and a certificate of loss of nationality or a reasonable explanation of why there is none despite relinquishment, or why U.S. citizenship was not acquired at birth
Foreign address, foreign-only telephone, or standing instructionsA self-certification of tax residences not including any foreign country, and documentary evidence establishing non-reportable status
Power of attorney abroad, or a foreign telephone alongside an Indian oneA self-certification of tax residences not including any foreign country, or documentary evidence of non-reportable status

Note the difference in the connectors. The U.S. place-of-birth cure needs three documents; the address and standing-instruction cure needs a self-certification and documentary evidence; the power-of-attorney cure needs either. Documentary evidence is defined in sub-rule (2)(a) as a Government certificate of residence, a Government identification for an individual, official documentation for an entity, or a financial statement, third-party credit report, bankruptcy filing or securities regulator report.

High value accounts — enhanced review beyond the rule 240 indicia

Sub-rule (3)(c) adds three layers on top of the electronic search:

  • a paper record search of the current customer master file and, where not contained in it, five categories of document obtained in the last five years — the most recent documentary evidence, the most recent account opening contract, the most recent PMLA documentation, current powers of attorney or signature authority forms, and current standing instructions to transfer funds;
  • an exemption from that paper search where the electronic data already includes six specified fields — tax residence status, residence and mailing address, telephone numbers, standing instructions for non-depository accounts, in-care-of or hold mail status, and any power of attorney or signatory authority; and
  • a relationship manager inquiry: an account assigned to a relationship manager, and any accounts aggregated with it, is reportable if the relationship manager has actual knowledge that the holder is a reportable person.
The six-field exemption is the whole business case for data quality

Sub-clause (iii) of sub-rule (3)(c) is worth reading as an instruction to the systems team rather than to the compliance team. If the institution's electronically searchable data carries all six listed fields, the paper record search is not required at all — no customer master file review, no trawl through five years of account opening documents. The cost of capturing those six fields once is far below the cost of a manual file review across a high value book, and it is the single highest-return investment in a rule 240 indicia programme.

Note also that the relationship manager inquiry survives everything. Sub-clause (vii) provides that once the enhanced review has been applied, it need not be re-applied in later years — except the relationship manager inquiry, and except where the account is undocumented, in which case the whole procedure is re-applied annually.

Sub-clause (vi) handles an account that becomes high value: the enhanced review must be completed within the calendar year following the year it crosses the threshold. Sub-clause (ix) requires procedures ensuring a relationship manager identifies any change in circumstances — and a new foreign mailing address notified to him is a change in circumstances.

Sub-rule (3)(e): once identified as reportable, a pre-existing individual account stays reportable in all subsequent years unless the holder ceases to be resident of the foreign country under its tax laws.

New individual accounts and the rule 240 indicia

Sub-rule (4) is much shorter, because the institution controls the moment of opening:

  • (a) Unless it elects otherwise, a depository account or a cash value insurance contract is not reviewed or reported as a U.S. reportable account unless the balance or cash value exceeds USD 50,000 equivalent at the end of any calendar year.
  • (b) Otherwise the institution shall obtain a self-certification — which may be part of the account opening documentation — allowing it to determine the holder's tax residences, and confirm its reasonableness against the information obtained on opening, including PMLA documentation. For a U.S. account this is due on opening or within ninety days of the year end in which the account leaves the clause (a) exemption; for a CRS account it is due on opening.
  • (c) Where the self-certification shows foreign tax residence, the account is reportable, and the self-certification must also carry the TIN, subject to rule 239(5), and the date of birth.
  • (d) On a change in circumstances making the institution know or have reason to know the self-certification is incorrect or unreliable, it may not rely on it and must obtain a valid one; failing that, the account is reportable for each country for which an indicium is identified.

Sub-rule (7)(a)(II) supplies the exception for the case where a self-certification simply cannot be obtained in time for a new CRS account: the institution applies the pre-existing account procedures to it until a valid self-certification is obtained and validated.

Worked example

FactsPosition under rule 240
Pre-existing U.S. account of USD 40,000 at 30 June 2014No review required
Pre-existing CRS account of USD 40,000Reviewable — no de minimis on the CRS side
Electronic search finds a Singapore address onlyTreat as Singapore tax resident unless cured
Only a hold mail instruction, no other addressPaper search or documentation; failing both, undocumented
U.S. place of birth; self-certification and foreign passport obtainedNot cured — the third document is also required
Power of attorney held by a person in DubaiCured by a self-certification or documentary evidence
High value account; all six fields electronically searchableNo paper record search
Relationship manager knows the holder is a German residentAccount is reportable regardless of the searches
Enhanced review done in 2026; account is documentedNot re-applied, except the relationship manager inquiry
Account crosses USD 1 million on 31 DecemberEnhanced review within the following calendar year
New CRS account opened with no self-certificationApply the pre-existing procedures until one is obtained
Holder later becomes non-resident of the reported countryThe account ceases to be reportable

Compliance checklist

  • Segment the book into the four populations, including the new 31 December 2025 cut-over for e-money and CBDC accounts.
  • Apply the USD 50,000 and USD 250,000 de minimis only to U.S. accounts.
  • Search for all six rule 240 indicia, and treat item (F) separately.
  • Capture the six electronic fields that remove the paper record search.
  • Match the cure documentation to the indicium — three documents for a U.S. place of birth.
  • Build a relationship manager knowledge and change-of-circumstance process; it never lapses.
  • Re-run the enhanced review annually only for undocumented accounts.
  • Obtain the self-certification at opening for every new account, with TIN and date of birth.

Common mistakes

  • Applying the U.S. de minimis to CRS accounts.
  • Reporting a hold mail account to a jurisdiction rather than as undocumented, when it is the one rule 240 indicia item that names no country.
  • Curing a U.S. place of birth on two documents.
  • Treating the enhanced review as one-off for an undocumented account.
  • Ignoring what the relationship manager actually knows.
  • Opening a CRS account without a self-certification and not applying the pre-existing procedures.

Which year this governs

The Income-tax Rules, 2026 are made under the Income-tax Act, 2025. The 1962 parallel to rule 240 is rule 114H, given for tracing only. The rule 240 indicia procedures carry the 2014 and 2016 implementation dates forward and add the 2025-26 CRS-amendment cut-over. Verify the current text before designing a review programme.

Key Facts About Rule 240 Indicia

  • Applies in: All states across India, under the relevant central law.
  • Mode: Mostly online via the official government portal.
  • Typical timeline: Ranges from a few days to a few weeks depending on the case.
  • Non-compliance: May attract penalties, interest or late fees.
  • Expert help: TaxClue completes the entire process end to end for you.

What is a high value account?

A pre-existing individual account with a balance or value exceeding the equivalent of USD 1 million as on 30 June 2014 or any subsequent 31 December for a U.S. reportable account, or as on 31 December 2015 or any subsequent 31 December for other reportable accounts.

What are the six indicia?

Identification as a resident of a foreign country for tax purposes or an unambiguous indication of a U.S. place of birth; a foreign mailing or residence address including a post office box; one or more foreign telephone numbers and none in India; standing instructions to transfer funds to a foreign account; a currently effective power of attorney or signatory authority granted to a person with a foreign address; and a hold mail instruction or in-care-of address abroad where no other address is on file.

Over 90% of compliance penalties in India arise from missed due dates — timely handling can save businesses thousands of rupees each year.

— TaxClue Compliance Desk

Rule 240 Indicia: a key compliance topic in Indian tax and corporate law that businesses and individuals must understand to remain compliant.

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Frequently Asked Questions
What is a high value account?
A pre-existing individual account with a balance or value exceeding the equivalent of USD 1 million as on 30 June 2014 or any subsequent 31 December for a U.S. reportable account, or as on 31 December 2015 or any subsequent 31 December for other reportable accounts.
What are the six indicia?
Identification as a resident of a foreign country for tax purposes or an unambiguous indication of a U.S. place of birth; a foreign mailing or residence address including a post office box; one or more foreign telephone numbers and none in India; standing instructions to transfer funds to a foreign account; a currently effective power of attorney or signatory authority granted to a person with a foreign address; and a hold mail instruction or in-care-of address abroad where no other address is on file.
What if no indicia are found?
No further action is required until there is a change in circumstances producing an indicium, or the account becomes a high value account.
What if only a hold mail or in-care-of address is found?
The institution applies the paper record search or seeks a self-certification or documentary evidence; if both fail, the account is reported as an undocumented account.
What extra review applies to high value accounts?
A paper record search of the customer master file and five years of specified documents where the electronic databases do not capture the listed fields, and a relationship manager inquiry — an account is reportable if the relationship manager has actual knowledge that the holder is a reportable person.
When is a new individual account exempt?
Unless the institution elects otherwise, a depository account or a cash value insurance contract is not reviewed or reported as a U.S. reportable account unless the balance or cash value exceeds the equivalent of USD 50,000 at the end of any calendar year.
What is required on opening a new individual account?
A self-certification, which may be part of the account opening documentation, allowing the institution to determine the holder's tax residences — and confirmation of its reasonableness against the information obtained at opening, including PMLA documentation.
What if a self-certification becomes unreliable?
The institution may not rely on it, must obtain a valid one, and if unable to do so must treat the account as reportable for each country for which an indicium is identified.
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Disclaimer: This article is for general informational purposes only and does not constitute professional tax, legal or financial advice. Laws, rates and due dates change and can vary by individual case — always verify with the relevant government source (e.g. mca.gov.in, incometax.gov.in) or consult a qualified professional before acting. TaxClue accepts no liability for decisions taken based on this content.

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