The 500 Million Mobiles Question: KYC Kaise Karein?

The past couple of days have been near-heartstoppers for nearly half of India’s mobile phone subscribers – two days ago, a news story in The Times of India (this one) did the rounds, telling us that:

“There could be a fresh KYC headache for over 50 crore mobile connections, or almost half of India’s phone population. They stare at the prospect of disconnection if SIM cards procured on the basis of Aadhaar verification are not backed up by a fresh identification.

“The issue has come to the fore following the Supreme Court’s judgment on Aadhaar where the court barred private companies from using an individual’s unique ID for authentication purposes.” – The Times of India, link visited on October 19, 2018

That news report also went on to state:

“On the way forward, sources said that customers may now have to submit a fresh identification document as part of the KYC process. This could be a copy of the passport, driving licence, voter’s card, electricity bill, gas bill, or PAN card.”

Bunkum. (With hogwash and horse feathers to follow).

 

DOT and UIDAI: Bunkum Bashers

The Department of Telecommunications (the “DOT”) and the Unique Identification Authority of India (the “UIDAI”) were quick to respond – the Press Information Bureau’s report on a joint statement issued by the DOT and UIDAI, states:

“…a few news reports in the media which state that 50 Crore mobile numbers, almost half of the total mobiles in circulation, are at the risk of disconnection, are completely untrue and imaginary. The news report tries to create unnecessary panic among mobile users by claiming that “they stare a prospect of disconnection if SIM cards procured on the basis of Aadhaar verification are not backed up by a fresh identification”.

“The joint statement clarifies that the Hon’ble Supreme Court in its judgement in Aadhaar case has nowhere directed that the mobile number which has been issued through Aadhaar eKYC has to be disconnected. Therefore, there is absolutely no reason for panic or fear at all. People should not believe in such rumours…

“…So in the light of the verdict if anybody wishes to get her/his Aadhaar eKYC replaced by the fresh KYC, s/he may request the service provider for delinking of her/his Aadhaar by submitting fresh OVDs as per earlier DOT Circulars on mobile KYC. But in any case his mobile number will not be disconnected.”

Phew. Bunkum bashed. Your mobile phone connection is (presumably!) safe. But what about the hogwash and horse feathers?

 

Hogwash and Horse Feathers: 6 Documents and Secret Sources

Let’s pick up that last quote from the news report above:

“On the way forward, sources said that customers may now have to submit a fresh identification document as part of the KYC process. This could be a copy of the passport, driving licence, voter’s card, electricity bill, gas bill, or PAN card.”

If the article is accurate, any of the six documents named in that last sentence can be submitted as part of the KYC process (“…submit a fresh identification document… gas bill, or PAN card.” [Emphasis added]).

But that’s not entirely true.

The DOT’s ‘Instructions on Verification of New Mobile Subscribers (Pre-paid & Postpaid)’ (the “DOT Instructions”) can easily be located on the DOT’s website here.

The DOT Instructions cite the CMTS/UAS License conditions which provide, inter alia, that “The LICENSEE shall ensure adequate verification of each and every customer before enrolling him as a subscriber; instructions issued by the licensor in this regard from time to time shall be scrupulously followed.”

In relation to the activation of new mobile connections, the DOT Instructions list the following requirements:

 

  • A passport size photograph of the subscriber should be pasted on the Customer Acquisition Form (“CAF“); and
  • The documents as proof of identity (“PoI“) and proof of address (“PoA“) of the subscriber shall be attached with the CAF, as per the instructions applicable from time to time.

 

The DOT Instructions also provide a detailed set of step-by-step instructions as to the manner in which the CAF, PoI, and PoA documents must be collected, signed, and stored, and various other measures that must be undertaken for a new mobile phone connection to be activated (such as tele-verification post CAF collection at the point of sale).

So that leaves us with two requirements as far as document submission for activation of new mobile phone connections is concerned: PoI and PoA. If the news article is accurate, the six documents mentioned therein should take care of both these requirements. But they don’t.

The ‘List of acceptable Documents as Proof of Identity and Proof of Address from General Public in the Country except in J&K, North East and Assam Service Areas’ (the “DOT List”) was published by the DOT here, and though the list is as of October 2016, we have not noticed any revisions to the list on the DOT website since then (all documents published on the DOT website after that date in relation to ‘subscriber verification’ or ‘KYC’ relate to various Aadhaar-based eKYC matters).

The DOT List includes twenty-two different documents that can be submitted as PoI, and twenty-five different documents that can be submitted as PoA. Of these, ten documents can be accepted as PoI and PoA, both. (Some of these appear with slight differences in the PoI and PoA lists, such as ‘Ration Card with Photo’ as PoI, and ‘Ration Card with address’ as PoA. But neither of these is applicable in the Mumbai and Maharashtra Service Areas; Driving Licenses are also not acceptable in the Mumbai and Maharashtra Services Areas). One of these ten documents is a ‘Sri Lankan Refugees Identity Card’, applicable only in the Chennai and Tamil Nadu Services Areas.

So here’s where that news report got it wrong or simply failed to mention (in addition to what the DOT and UIDAI have already clarified):

 

  • Both, PoI and PoA have to be produced. Only some documents apply in both cases.
  • ‘Gas Bill’ appears nowhere on either list.
  • Electricity Bills (not older than 3 months) are acceptable only as PoA and not as PoI
  • PAN cards are acceptable only as PoI and not as PoA
  • In the Mumbai and Maharashtra Services Areas, Driving License cannot be submitted as PoA .
  • There are twenty-two PoI documents and twenty-five PoA documents in the DOT list – and not just the six mentioned in the news article.

 

Trawling through Indian regulatory sources can be a time-consuming and frustrating process, with answers hard to find and complications around every corner. But that shouldn’t be an excuse for piecemeal research that relies only on ‘sources’ and results in stories that, in the words of the DOT and UIDAI, “…are completely untrue and imaginary…” and [try to] “…create unnecessary panic…”

 

Additional Resources:

 

Credits:

Photo by Hal Gatewood on Unsplash

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