SEBI VIPV (Video In-Person Verification): Complete Guide for Stock Brokers & Intermediaries

If you are a stock broker, depository participant, mutual fund distributor, or any securities market intermediary regulated by SEBI, Video In-Person Verification (VIPV) is no longer optional -- it is the standard mechanism for remotely verifying client identity. Under SEBI's KYC Master Circular (SEBI/HO/MIRSD/SECFATF/P/CIR/2023/169, dated October 12, 2023), VIPV is codified as the digital alternative to physical In-Person Verification (IPV), with detailed procedural requirements spelled out in Clauses 54 through 61. This guide breaks down every requirement, explains who must comply, and provides a practical checklist for implementation.

What is VIPV? Defining Video In-Person Verification Under SEBI

Video In-Person Verification (VIPV) is a process by which a SEBI-registered intermediary verifies the identity of a new client through a live, real-time video interaction -- instead of requiring the client to physically appear at a branch office. The concept builds on the traditional In-Person Verification (IPV) requirement that has been part of India's securities market KYC framework for over a decade, but adapts it for a digital-first environment where clients increasingly expect remote onboarding.

Under the SEBI KYC Master Circular 2023, VIPV is not a casual video call. It is a structured, compliance-driven process with specific technical and procedural safeguards mandated by the regulator. The verification must be conducted by a trained official, recorded in full, and stored in a tamper-proof format with date and time stamps. The client's identity must be confirmed against their Officially Valid Document (OVD), and the photograph on the Aadhaar must be matched against the person appearing on the video.

VIPV is distinct from Video KYC (V-CIP) as defined by the RBI for banking entities. While both involve live video verification, VIPV operates under SEBI's regulatory framework and is specifically tailored for securities market participants. The requirements, the list of authorized persons who can conduct verification, and the documentation standards differ from the RBI's V-CIP norms. Intermediaries must comply with the SEBI-specific requirements outlined in Clauses 54 through 61 of the Master Circular.

The practical effect of VIPV is transformative: a stock broker in Mumbai can verify the identity of a new client in Manipur within minutes, without either party traveling. A depository participant can open demat accounts for clients across all 28 states without maintaining a physical branch network. For the securities industry, VIPV has effectively eliminated geography as a constraint on client acquisition.

SEBI's IPV Mandate: Who Must Do It and Who Can Perform It (Clauses 54-59)

Before diving into the VIPV-specific requirements, it is essential to understand the broader IPV mandate that VIPV operates within. Clauses 54 through 59 of the SEBI KYC Master Circular establish the foundation for all In-Person Verification in the securities market.

Clause 54: The IPV Obligation

Clause 54 mandates that In-Person Verification shall be carried out for all new clients of SEBI-registered intermediaries. This is not a recommendation -- it is a regulatory requirement. Every new account opened with a stock broker, depository participant, mutual fund, portfolio manager, or any other SEBI-registered intermediary must include IPV as part of the KYC process.

"In-Person Verification (IPV) shall be carried out for all new clients." -- Clause 54, SEBI KYC Master Circular (SEBI/HO/MIRSD/SECFATF/P/CIR/2023/169)

Clauses 55-57: Who Can Perform IPV

The circular specifies a defined set of entities authorized to carry out IPV. This is a critical compliance point -- IPV performed by an unauthorized person or entity is invalid and exposes the intermediary to regulatory risk. The authorized entities include:

Clause 55: IPV can be carried out by any SEBI-registered intermediary -- including stock brokers, depository participants, mutual funds, portfolio managers, investment advisers, and research analysts -- or by a scheduled commercial bank with whom the intermediary has an arrangement.

Clause 56: For mutual fund distributors and their agents, the Asset Management Company (AMC) or the mutual fund trust may authorize specific individuals to perform IPV on their behalf. This provision recognizes the distributed nature of mutual fund distribution networks and allows AMCs to extend IPV capability to their channel partners.

Clause 57: KYC Registration Agencies (KRAs) are also authorized to perform IPV. Given that KRAs maintain centralized KYC records and already interact with investors during KYC data uploads, this provision creates an efficient channel for IPV completion during the KRA registration process.

Clauses 58-59: IPV Documentation

Clauses 58 and 59 address the documentation requirements for IPV. The person performing IPV must record the verification on the KYC form by signing, stamping, and dating it with the designation and organization name. For VIPV (video-based IPV), these documentation requirements are supplemented by the more detailed technical requirements in Clause 60, which we examine next.

VIPV Process Requirements: The 7 Sub-Clauses of Clause 60

Clause 60 is the heart of the VIPV framework. It contains seven sub-clauses (60a through 60g) that collectively define the technical, procedural, and security requirements for conducting In-Person Verification through video. Compliance with all seven sub-clauses is mandatory -- partial compliance is not an option. Let us examine each one in detail.

Clause 60(a): Trained Official, Informed Consent, and Activity Log

The first sub-clause establishes three foundational requirements. First, the VIPV must be conducted by an official who has been specifically trained in the video verification process. This is not a general customer service representative conducting a casual video call -- the official must understand the regulatory requirements, know what to look for during document verification, and be capable of identifying potential fraud indicators.

"VIPV shall be carried out by an official of the intermediary specifically trained for the purpose, with the informed consent of the client, and the activity log along with the video recording shall be maintained as records." -- Clause 60(a)

Second, the client must provide informed consent before the VIPV session begins. The client must be explicitly told that the session will be video-recorded, that their identity documents will be captured, and that the recording will be stored as part of the intermediary's compliance records. Consent must be captured in a verifiable manner -- typically through an on-screen acknowledgment or verbal confirmation recorded within the video itself.

Third, a comprehensive activity log must be maintained alongside the video recording. This log should capture the session timeline (start time, end time, key events), the identity of the official conducting the verification, the documents verified, the verification outcomes, and any anomalies or concerns noted during the session. The activity log serves as the intermediary's primary audit trail for regulatory examinations.

Clause 60(b): Live Environment Verification

Sub-clause 60(b) requires that the video interaction be conducted in a live, real-time environment. This means the session cannot use pre-recorded video clips, asynchronous document submissions, or any form of non-live interaction. The official and the client must interact simultaneously in real-time, with the ability for bidirectional communication -- the official must be able to ask questions and the client must be able to respond immediately.

"The VIPV process shall be carried out in a live environment." -- Clause 60(b)

The "live environment" requirement has important technical implications. The video platform must support real-time streaming with minimal latency. It must be capable of detecting and rejecting pre-recorded video feeds or looped video inputs. The platform should ideally incorporate liveness detection technology that can confirm the person on the video is physically present and not a digital reproduction.

Clause 60(c): Clear Video Quality and Face Visibility

The video quality must be sufficient for the official to clearly see the client's face throughout the session. This is not merely a technical specification -- it is a verification effectiveness requirement. If the video quality is poor, the official cannot reliably match the client's face against their photo ID, and the entire purpose of VIPV is defeated.

"The quality of the video should be clear enough to establish the identity of the client with reasonable certainty and the face of the client should be clearly visible." -- Clause 60(c)

In practice, this means the video platform must enforce minimum bandwidth and resolution thresholds. If the client's connection quality drops below acceptable levels, the session should be paused or rescheduled rather than continued with degraded video. The platform should also ensure adequate lighting detection -- if the client's face is in shadow or backlit to the point where features are indistinguishable, the official should be alerted.

Clause 60(d): Random Questions, OVD Display, and OTP Confirmation

This is one of the most operationally detailed sub-clauses. It requires three distinct verification actions within the video session. First, the official must ask the client randomized questions to confirm their identity -- these should not be predictable or scriptable, as the purpose is to detect impersonation. Second, the client must display their Officially Valid Document (OVD) -- typically Aadhaar or PAN -- on camera so the official can visually verify the document's authenticity and match the photo to the person on video. Third, an OTP (One-Time Password) must be sent to the client's registered mobile number or email, and the client must confirm receipt and read out or enter the OTP during the session.

"The official shall ask random questions to the client, the client shall display the OVD, and the OTP confirmation shall be obtained during the video interaction." -- Clause 60(d)

The combination of these three elements -- random questions, document display, and OTP confirmation -- creates a multi-factor verification within a single session. It is significantly harder to defeat than any single verification method alone. The random questions guard against rehearsed impersonation, the OVD display confirms document possession, and the OTP confirms control of the registered communication channel.

Clause 60(e): Aadhaar Photo Match

Sub-clause 60(e) mandates that the photograph on the client's Aadhaar card must be matched against the live video feed. This can be done manually by the official (visual comparison) or through automated facial recognition technology. The photograph on the Aadhaar serves as the reference image against which the client's live appearance is validated.

"The photograph of the client present in the Aadhaar shall be matched with the person present on the video call." -- Clause 60(e)

Modern VIPV platforms automate this step using AI-based facial recognition that compares the live video frame against the Aadhaar photo with a confidence score. However, the regulatory requirement does not mandate automation -- a trained official's visual confirmation also satisfies the clause. Best practice is to use both: automated face matching for consistency and speed, with the official's manual confirmation as a secondary check.

Clause 60(f): Tamper-Proof, Date/Time Stamped Storage

The complete video recording of the VIPV session must be stored in a tamper-proof format with embedded date and time stamps. This requirement addresses the integrity of the verification record -- if the recording can be altered after the fact, it loses its evidentiary value during regulatory audits or dispute resolution.

"The video recording shall be stored in a tamper-proof manner with date and time stamp." -- Clause 60(f)

Tamper-proofing can be achieved through cryptographic hashing (where the hash of the video file is recorded at the time of storage and any subsequent modification changes the hash), digital signatures, or blockchain-based immutability. The date and time stamps must reflect the actual time of the session, not the time of upload or storage. Intermediaries should ensure their video storage systems generate and retain hash verification records as part of the audit trail.

Clause 60(g): Additional Security Features

The final sub-clause provides flexibility for intermediaries to implement additional security measures beyond the minimum requirements specified in sub-clauses 60(a) through 60(f). These may include geo-tagging (capturing the client's GPS location during the session), IP address logging, device fingerprinting, AI-powered liveness detection, and deepfake detection. While these are not individually mandated, the clause encourages intermediaries to adopt a layered security approach. In practice, leading intermediaries implement most or all of these additional safeguards, both for genuine fraud prevention and to demonstrate regulatory good faith during SEBI inspections.

When IPV is NOT Required: Exemptions Under Clause 61

Clause 61 of the SEBI KYC Master Circular provides specific exemptions where In-Person Verification (including VIPV) is not required. Understanding these exemptions is critical for operational efficiency -- there is no point in conducting VIPV for clients who qualify for an exemption, and doing so wastes resources without adding compliance value.

Aadhaar-based Authentication: If the client's identity has been verified through Aadhaar authentication (biometric or OTP-based) using the UIDAI's authentication infrastructure, IPV is not required. This is because Aadhaar authentication provides a level of identity assurance that is considered equivalent to or stronger than in-person verification -- the client's biometric or OTP-confirmed identity is verified directly against the UIDAI database.

DigiLocker-based Verification: When the client's identity documents are fetched directly from DigiLocker (the Government of India's digital document storage platform), IPV is not required. Documents sourced from DigiLocker are considered authenticated at source -- they carry the same legal validity as original documents and have been verified by the issuing authority. Since the documents are fetched programmatically from a government platform, the risk of document forgery that IPV is designed to catch is effectively eliminated.

These exemptions are significant because they allow intermediaries to create tiered onboarding flows. Clients who are comfortable with Aadhaar OTP authentication or DigiLocker document sharing can be onboarded through a fully automated, instant process without any human intervention. Clients who prefer not to use these mechanisms, or whose documents are not available on DigiLocker, are routed through the VIPV process. This tiered approach maximizes conversion rates while maintaining full regulatory compliance. For a deeper look at the overall SEBI digital KYC framework, see our dedicated guide.

VIPV Compliance Checklist for Intermediaries

The following checklist translates the regulatory requirements of Clauses 54-61 into actionable items for compliance teams, operations heads, and technology teams at SEBI-registered intermediaries. Use this as a practical tool to assess your current VIPV readiness and identify gaps.

How BASEKYC Enables SEBI VIPV Compliance

BASEKYC is purpose-built for regulated entities that need to implement VIPV at scale without building and maintaining custom compliance infrastructure. Our platform maps directly to each sub-clause of Clause 60, so intermediaries can achieve full compliance out of the box.

Agent Training and Workflow Enforcement: BASEKYC's agent dashboard guides verification officials through a structured workflow that ensures every Clause 60 requirement is met in sequence. The system enforces mandatory steps -- consent capture, random question prompts, OVD display request, OTP trigger, and face match -- and will not allow the official to mark a session as complete until all steps are verified. This eliminates human error and ensures consistent compliance across hundreds or thousands of daily sessions.

AI-Powered Face Matching and Liveness Detection: Our platform integrates real-time facial recognition that compares the live video feed against the Aadhaar photograph (Clause 60(e)) with configurable confidence thresholds. AI-based liveness detection confirms the client is physically present, addressing Clause 60(b) and 60(g). The system detects presentation attacks including printed photos, screen replays, and sophisticated deepfakes.

Tamper-Proof Recording and Storage: Every VIPV session recorded through BASEKYC is encrypted at rest and in transit, with cryptographic hashes generated at the moment of recording (Clause 60(f)). Date and time stamps are embedded in the video metadata using NTP-synchronized server time. Recordings are stored on immutable storage with full audit trail access, ensuring they can withstand regulatory examination.

Comprehensive Audit Trail: BASEKYC automatically generates the activity logs required by Clause 60(a). Every action within a VIPV session -- from consent capture to OTP verification to face match result -- is timestamped and logged. The complete audit trail is available for download in formats suitable for SEBI inspection submissions.

Tiered Onboarding with Exemption Routing: For clients who qualify for the Clause 61 exemption (Aadhaar authentication or DigiLocker verification), BASEKYC routes them through an automated, no-VIPV onboarding flow. Clients who do not qualify are seamlessly routed to the VIPV queue. This tiered approach maximizes throughput without compromising compliance.

Whether you are a stock broker onboarding retail clients, a depository participant opening demat accounts, or an AMC processing mutual fund applications, BASEKYC provides the end-to-end infrastructure for SEBI-compliant VIPV. Our platform supports white-label deployment, API integration with existing back-office systems, and both cloud and on-premise deployment models.

Frequently Asked Questions About SEBI VIPV

What is the difference between IPV and VIPV under SEBI?

IPV (In-Person Verification) is the broader requirement under SEBI's KYC framework that mandates identity verification of all new clients. VIPV (Video In-Person Verification) is the specific method of conducting IPV remotely through a live video call. VIPV is governed by the additional technical requirements in Clause 60 of the SEBI KYC Master Circular (SEBI/HO/MIRSD/SECFATF/P/CIR/2023/169). Physical IPV and VIPV are both valid methods of fulfilling the IPV obligation -- the choice between them is at the intermediary's discretion, subject to client preference.

Can a mutual fund distributor conduct VIPV on behalf of the AMC?

Yes. Under Clause 56, AMCs can authorize their distributors and agents to perform IPV, including VIPV, on behalf of the mutual fund. The distributor's officials must be specifically trained for the VIPV process and must follow all Clause 60 requirements. The AMC retains regulatory responsibility for ensuring the VIPV is conducted properly and must maintain oversight of the distributor's verification practices.

Is VIPV mandatory, or can intermediaries still do physical IPV?

VIPV is not mandatory as the sole method -- intermediaries can still conduct physical in-person verification. However, VIPV is the only viable method for remote client onboarding where the client does not visit a physical office. In practice, the vast majority of intermediaries now offer VIPV as the primary verification channel, with physical IPV available as a fallback for clients who prefer it or face technical difficulties with video.

How long must VIPV video recordings be retained?

The SEBI KYC Master Circular requires that KYC records -- including VIPV video recordings, activity logs, and consent records -- be retained for a minimum of five years after the business relationship with the client has ended. In practice, most intermediaries retain records for eight years or longer, in line with PMLA record-keeping requirements and SEBI inspection cycles. BASEKYC's storage infrastructure supports configurable retention policies to meet these requirements.

Does VIPV apply to NRI clients opening accounts with Indian brokers?

Yes, the IPV requirement under Clause 54 applies to all new clients, including NRI and foreign national clients. VIPV is particularly valuable for NRI account opening since these clients are, by definition, not physically present in India. The Clause 60 requirements apply equally -- the video session must be live, the official must be trained, and the Aadhaar photo match (or equivalent OVD match for NRIs who may not have Aadhaar) must be performed. Some intermediaries implement additional safeguards for cross-border VIPV sessions, such as enhanced geo-location verification and multi-document cross-referencing.