KYC issues — when the bank freezes first and answers later

The KYC cycle is the commonest cause of a frozen account in India — usually discovered at the moment you need money. The rules are actually on your side: the bank must maintain the record, tell you what is due, and act on your complaint in a fixed window. This page puts the three instruments in order: the Master Direction's clock, the complaint, and the RTI.

• Periodic updation is risk-based — high-risk customers: 2 years; medium: 8 years; low: 10 years
• The bank determines the risk category from its own assessment — your category decides your due date
• Notice precedes restriction: when re-KYC is due, the bank calls and writes for the documents; restricting operations is the last step after notice, not the first
• Acceptable documents are the standard set — the bank's own re-KYC page lists what it takes, including video/OTP-based re-KYC where it offers it

If your account was restricted without a notice, that sequence is itself the complaint — and the RTI asks for the notice's dispatch record.

1. **The branch, in writing** — the KYC desk logs the submission; take the acknowledgement
2. **The bank's complaint channel** — its ombudsman-integrated complaint system, with a complaint number; the bank has 30 days to resolve
3. **RBI CMS** — complaint on [[https://cms.rbi.org.in|cms.rbi.org.in]], the Reserve Bank's Complaint Management System; unresolved or wrongly-closed bank complaints go here, feeding the **Integrated Ombudsman** route
4. **RTI** — in parallel once you hold a dated submission or complaint: the file's own record

1. The risk category assigned to my account ____ and the date my periodic KYC updation fell due.
2. Copy of the notice(s) issued to me for periodic updation, with dates and mode of dispatch.
3. The date my KYC documents of ____ were received, and the present status of updation.
4. The date and reason operations on my account were restricted.
5. The present status of my complaint no. ____ dated ____.

Public-sector banks are public authorities — send it to the bank's CPIO with ₹10. The five points together reconstruct the entire dispute on the bank's own paper: category, due date, notice, receipt, restriction.

Banks answer KYC complaints with process phrases — “under process”, “system pending”. The file answers differently: either the notice record exists or it does not; either your documents were received on a date or they were not. A restriction that cannot show its notice does not survive the first appeal, and an updation that cannot show a pending deficiency is simply overdue.

Real example. Dr. Shrawan Kumar Pathak's father's pension account was restricted on a “re-KYC due” flag — no notice produced, and two branch visits ended in a queue token. The RTI (points 1, 2 and 4) returned: the account was low-risk, updation was not due for another four years, and the restriction had been applied against a different customer's KYC queue. The account was unblocked the week the reply reached the branch manager's desk — attached to a one-paragraph letter.

Under the RBI Master Direction, periodic updation is risk-based — high-risk 2 years, medium 8, low 10.

Restrictions after due notice are permitted; a restriction without a notice record is itself a deficiency to complain about — and to ask for on RTI.

First the bank's own channel, then the RBI Complaint Management System at cms.rbi.org.in, which carries the matter to the Ombudsman if the bank fails.

Public-sector banks are public authorities under §2(h); private banks are not, but every bank answers to the RBI's complaint machinery.

The standard identity and address set the bank itself lists for re-KYC — many banks now offer video or OTP-based updation for low-risk customers.

• Banking Ombudsman — the full guide
• IBPS exams — the bank-side RTI route
• File RTI online — the 12-step guide
• The RTI Playbook

• RBI — Master Direction on Know Your Customer (risk-based periodic updation: 2/8/10 years)
• cms.rbi.org.in — RBI Complaint Management System (verified live on this run)
• RTI Act 2005, §2(h) — banks substantially financed by government

Last reviewed: 26 August 2026. Periodicity per the Master Direction as amended; complaint routes verified live.