Rules 9A-11 explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
The last live rules deal with the machinery behind client due diligence. Rule 9A sets up the Central KYC Records Registry and lists its functions, rule 9B lets the Reserve Bank inspect it, rule 10 says how a reporting entity keeps the identity records, rule 10A fixes monthly reports on measures taken after a direction from the Director, rule 10B governs the expenses of an audit ordered by the Director, and rule 11 says that questions of interpretation go to the Central Government.
This article reads them as per the consolidated Rules consulted (amendments listed up to 19 July 2024), with the Act as consulted (amendments shown up to 1 August 2019). Later changes should be checked. A reporting entity unsure how its identity records and monthly reports fit these rules can take legal consultation on its own set-up.
The Central KYC Records Registry receives, stores, safeguards and retrieves electronic KYC records, causes an annual audit of its controls, and appoints a compliance officer; the Reserve Bank may call for information and inspect it (rules 9A and 9B). A reporting entity keeps identity records after filing the electronic copy with the Registry, in the manner its Regulator specifies (rule 10). Persons directed under section 13(2)(c) report by the 10th day of the succeeding month, relaxable to every three months (rule 10A). Audit expenses follow an hourly amount under the Income-tax Rules, 1962 (rule 10B).
Which sections of the Act these rules serve
| Rule | Act provision it works with |
|---|---|
| 9A, 9B, 10 | Section 12(1)(e), which requires records of documents evidencing identity of clients and beneficial owners, and section 12(4), which says those records are to be kept for five years after the business relationship has ended or the account has been closed, whichever is later |
| 10A | Section 13(2)(c), the Director's power to direct reports at such interval as may be prescribed on the measures being taken |
| 10B | Section 13(1A) and (1B), audit by an accountant from a panel, the expenses borne by the Central Government |
See our article on section 12 for the retention periods the Act itself prints, and our article on section 13 for the Director's inquiry, audit and penalty powers. The rules below print no number of years of their own for retention; the periods are in the Act.
Rule 2(1)(fa): who the "Regulator" is
The Registry rules lean on the definition of "Regulator": a person, authority or Government vested with the power to license, authorise, register, regulate or supervise the activity of reporting entities, or the Director as notified for a specific reporting entity, class or purpose; the Reserve Bank of India with respect to the Central KYC Records Registry; and the Central Board of Indirect Taxes and Customs for dealers in precious metals and precious stones and for real estate agents (sub-clauses (i) to (iv)). The Rules' terms are used as printed.
Rule 9A: functions and obligations of the Central KYC Records Registry
Sub-rule (1). The Central Government shall, within one hundred and eighty days from the date of coming into force of the Prevention of Money-laundering (Maintenance of Records) Amendment Rules, 2015, set up a Central KYC Records Registry with its own seal to receive, store, safeguard and retrieve electronic copies of KYC records obtained by reporting entities from their clients. (The period is shown as substituted by marker 13: G.S.R. 882(E) dated 18.11.2015.) The proviso says that in an International Financial Services Centre no such receiving, storing, safeguarding and retrieving is required for a client who is a foreign national.
Sub-rule (2). The Registry shall:
| Clause | Function as printed (summarised) |
|---|---|
| (a) | Follow operating instructions issued by the Regulator, consistent with the guidelines in clause (g), and issue them to implement the Rules |
| (b) | Store, safeguard and retrieve the KYC records and make them available online to reporting entities or the Director |
| (c) | Take all precautions so that electronic copies are not lost, destroyed or tampered with, with sufficient back-up at an alternative safe and secure place |
| (d) | Cause an annual audit of its controls, systems, procedures and safeguards and take corrective action |
| (e) | Provide information only to reporting entities registered with it on payment of fees specified by the Regulator |
| (f) | Appoint a compliance officer who monitors compliance with the Act, the rules, notifications, guidelines and instructions, handles clients' grievances, and reports any non-compliance immediately and independently to the Central Government |
| (g) | The Regulator, in consultation with the Central Government and the Registry, may issue guidelines on filing, retrieval and utilisation of the KYC records (marker 36: G.S.R. 419(E) dated 19.07.2024) |
| (h) | The Central Government, in consultation with the Regulator, may by notification direct that any provision of rule 9 or rule 9A shall not apply to a class of regulated entities, or shall apply with specified exceptions, modifications and adaptations |
Clause (h) is a notification-based exemption power. The text contains no such notification, and nothing here suggests that any exists. The filing duty on reporting entities (ten days, with updates in seven days) is in rule 9(1A) to (1H), covered in our article on rule 9(1) to (3).
Rule 9B: inspection by the Reserve Bank of India
- (1) The Reserve Bank may, with respect to the functions of the Central Registry referred to in rule 9A, call for any information, statement or other particulars from the Registry or cause an inspection by one or more of its officers as it deems fit.
- (2) The Reserve Bank shall supply to the Registry a copy of the inspection report.
- (3) It is the duty of every director, officer or employee of the Registry to produce before the inspecting officer all books, accounts and documents in his custody and furnish any statement and information relating to the Registry's affairs.
- (4) The expenses of the inspection are borne by the Registry.
(The rule is shown as inserted by marker 14: G.S.R. 347(E) dated 12.04.2017.) The sub-rules of rule 9B are printed as "sub-section" in one place; the sense is sub-rule, and it is quoted as read.
Rule 10: maintenance of the records of the identity of clients
- (1) Every reporting entity shall maintain the records of the identity of its clients obtained in accordance with rule 9, after filing the electronic copy of such records with the Central KYC Records Registry.
- (2) The records shall be maintained by the reporting entity in the manner as may be specified by its Regulator from time to time.
- (3) Where the reporting entity does not have records of the identity of its existing clients, it shall obtain them within the period specified by the regulator, failing which it shall close the account after giving due notice to the client.
- Explanation. "Records of the identity of clients" include updated records of the identification data, account files and business correspondence and the result of any analysis undertaken under rule 3 and rule 9 (the last words carry marker 34: G.S.R. 652(E) dated 04.09.2023).
Rule 10 does not name a number of years. The periods for which identity records must be kept are printed in section 12(4) of the Act, as above, and the transaction-record period in section 12(3). The Rules' transaction records are in our article on rules 1 and 3 to 8.
Rule 10A: furnishing of report to the Director
- (1) The persons referred to in clause (c) of sub-section (2) of section 13 of the Act shall furnish reports on the measures taken to the Director every month by the 10th day of the succeeding month.
- (2) The Director may relax the time interval in sub-rule (1) to every three months, on specific request made by the reporting entity based on reasonable cause.
Section 13(2)(c) as printed allows the Director, on finding a failure to comply, to direct the reporting entity, its designated director on the Board or any employee to send reports at such interval as may be prescribed on the measures it is taking. Rule 10A is the interval so prescribed. It applies only to a person who has been so directed.
Rule 10B: expenses for audit
- (1) The expenses of, and incidental to, an audit under section 13(1A) of the Act (including the remuneration of the accountant and the assistants engaged) are paid in accordance with the amount specified in sub-rule (2) of rule 14B of the Income-tax Rules, 1962 for every hour of the period specified by the Director. The Income-tax Rules, 1962 are quoted as printed; check the current law for the corresponding provision.
- (2) The period is specified in terms of the number of hours required for completing the report.
- (3) The accountant shall maintain a time sheet and submit it to the Director with the bill.
- (4) The Director shall ensure that the number of hours claimed is commensurate with the size and quality of the report.
Under section 13(1B), the expenses of such an audit are borne by the Central Government; the Rules do not alter that. The Rules print no figure for the hourly amount, because it is taken from the Income-tax Rules.
Rule 11: interpretation
If any question arises relating to the interpretation of the Rules, the matter shall be referred to the Central Government and its decision shall be final. The text sets no time limit or form for the reference.
A worked example
Metro Finance Ltd (invented) is a reporting entity. The Director, in an inquiry, finds a failure and directs it under section 13(2)(c) to report on its measures. Under rule 10A the reports are due by the 10th day of each succeeding month; the company shows reasonable cause and asks the Director to relax the interval to every three months, which the Director may do. Separately, the Director orders an audit of its records by an accountant from the panel under section 13(1A); the accountant keeps a time sheet and submits it with the bill under rule 10B. For its customer files, Metro Finance keeps the identity records after filing the electronic copy with the Registry (rule 10(1)), and where it finds that some existing clients have no records, it obtains them within the period its regulator specifies, or closes the accounts after notice (rule 10(3)).
Need help with identity records and reports to the Director?
If you hold client identity records, have been directed to report, or face an audit, the practical questions are which rule applies and by what date. Our team assists through legal consultation, starting from the direction or notice you have received.
Key takeaways
- The Central KYC Records Registry receives, stores, safeguards and retrieves KYC records, undergoes an annual audit and appoints a compliance officer.
- The Reserve Bank may call for information from and inspect the Registry; the Registry bears the expenses.
- Reporting entities keep identity records after filing the electronic copy with the Registry, in the manner their Regulator specifies.
- Existing clients without identity records must provide them within the regulator's period or the account is closed after notice.
- Persons directed under section 13(2)(c) report monthly by the 10th, relaxable to every three months by the Director.
- Audit expenses follow the hourly amount in the Income-tax Rules, 1962; the accountant submits a time sheet; interpretation questions go to the Central Government.
Read next
- Rule 9(1) to (3) PML Rules: client due diligence, Central KYC registry and beneficial owner
- Rule 9(4) to (19) PML Rules: KYC documents by client type
- Rules 1 and 3-8 PML Rules: transaction records and reports
- Section 13 PMLA: powers of the Director to impose fine
Disclaimer: Based on the consolidated text of the Prevention of Money-laundering Act, 2002 published by the Enforcement Directorate, showing amendments up to Act 23 of 2019 (1 August 2019), and on the Department of Revenue consolidated copy of the Prevention of Money-laundering (Maintenance of Records) Rules, 2005 listing amendments up to 19 July 2024, as consulted on 2 October 2026. Later amendments, notifications, other rules and regulator directions should be checked. This article is general information, not legal advice; check the official text before acting.