India: New e-KYC for Telecoms without Aadhaar

November 23, 2018

Humans being ‘social animals’ have developed and evolved themselves distinguishing them from the other living creatures with their advanced ability to communicate with one another. Physical form of communication was dominant for a number of years and those separated by distances managed to remain connected with the means of letters or messages via messengers. Updated version of technology has allowed the virtual platform to serve as the new means of the communication allowing individuals to interact although they may be miles apart from one another through the means of telecommunication services. Major sectors of the Indian telecommunication industry are telephone, internet and television broadcast Industry.

Regulating telecommunication

The Government through its telecom branch enforces polices and guidelines for the regulation of telecommunication in India which is monitored by the Telcom Regulatory of India (hereinafter referred to as “TRAI”) in accordance to the provisions of Telecom Regulatory Authority of India Act, 1997 (hereinafter referred to as “TRAI Act”).

Customer authentication

For the purpose of enrolling new customers to avail their services, the telecommunication service providers verify their authenticity by subjecting them to the ‘Know Your Customer’ (hereinafter referred to as “KYC”) norms as per the directions of the DoT. The said process requires submission of documents indicating the proof of identity and address of the new subscriber such as PAN Card, Voter ID, Driving License, Passport, etc would suffice. These identity proofs help in unique identification of a particular customer of the respective service provider. One of the commonly used documents for this procedure was Aadhaar card, the use of which has now been prevented for the private companies under the Supreme Court order dated on September 26, 2018.[1]

In furtherance to the same the DoT instructed the telecom operators to be ready with an alternate verification process for approval by November 5, 2018, as it prevented the operators to stop using Aadhaar e-KYC for the verification process.[2]

DoT introduced a new ‘alternate digital KYC’ on the recommendations of Telecoms for issuing new mobile connections whereby the customer acquisition form is to be embedded with live photograph of subscriber along with original proof of identification and proof of address document thus digitising the end-to-end process for on-boarding of new mobile subscribers by making it completely paperless.[3] The procedure to be followed in the said regards in stated below:

  • Entire process shall be used through authenticated applications hosted by telecoms.
  • Access of the applications should be controlled by the telecoms and the same should be protected from unauthorized use.
  • A new customer shall possess original proof of identification and proof of address document at the point of sale of the telecoms.
  • Live photograph of the subscriber is to embedded in the customer acquisition form to which the system shall put a watermark having customer acquisition form number, GPS coordinates, point of sale name, unique point of sale code, date and time stamp.
  • Likewise, the live photograph of the original proof of identification and proof of address document shall be captured in the aforesaid manner.
  • All customer acquisition form entries shall be made in consonance to the original proof of identification and proof of address document.
  • Validation shall be complete upon the provision of the One Time Password sent at the alternate number of the customer or his/ her relative.
  • Point of sale shall intimate the new subscriber regarding the transaction-ID/ reference number generated at the time of submission of the customer information by the telecoms to the activation officer.
  • Upon successful verification by the Telecom representatives that the information in the live pictures of the customer, his/her proof of identification and proof of address and other details in the customer acquisition form the new connection would be activated followed by a final tele-verification process before final activation.

DoT clarified that only 2 mobile connections will be provided per day per proof of identification and proof of address document to a customer by the operator using the alternate digital KYC process. Also, the said process of verification would be applicable for outstation and foreign customers.

The process of an effective and adequate mechanism for verification of new telecom customers without using Aadhaar ecosystem has been streamlined.

[1] Justice K.S. Puttaswamy (Retd.) and Another Vs. Union of India and Others [SC Writ Petition (Civil) No. 494 of 2012]



For more information please contact us at :