FASTag KYC update: help at your counter

A customer walks in holding a phone. There’s an SMS or an email about “KYC pending” on their FASTag, and they want you to sort it out. Maybe they’ve already been told the tag could stop working. They’re worried, and they’re asking you what to do.

The first thing to know is that you can’t just pick a form and start. What the customer has to send depends on what the notice asks for, and the bank that issued the tag is the one who decides. Your job is smaller and more useful than it sounds: help the customer read the request, prepare the matching response, send it the right way, and write down what was sent and what came back.

Who is responsible for FASTag KYC?

As of 17 October 2026, the NETC Procedural Guidelines make the issuer responsible for the KYC of the account linked to the tag. These guidelines are NPCI’s framework, and they’re hosted on IHMCL’s website. The issuer does the checking under Reserve Bank of India (RBI) rules.

Those rules are not the same for every bank. RBI has separate KYC directions for Commercial Banks, Payments Banks and Small Finance Banks. RBI’s circular of 28 November 2025 applies the Commercial Banks directions, with adaptations, to prepaid payment instrument (PPI) issuers. So the first question to ask is simple: which category is this issuer, and what kind of account is the tag linked to?

Is a KYC request the same as a vehicle check?

No, and people mix them up all the time. KYC is about the customer: who they are and what the bank has on record. Know Your Vehicle (KYV) is about the vehicle. If the notice doesn’t say which one is outstanding, ask the issuer.

For context, the IHMCL circular of 30 December 2025 discontinues KYV for new Car/Jeep/Van FASTags from 1 February 2026. It keeps pre-activation vehicle validation. A customer holding an older tag may still see wording about the vehicle, so don’t assume.

Which response fits which notice?

Read the notice first, then match it to a row below. If you can’t tell which row applies, that’s your cue to ask the issuer, not to guess.

The customer’s details haven’t changed

RBI’s Commercial Banks directions, checked on 17 October 2026, provide for a self-declaration from an individual whose KYC information has not changed. The listed ways to send it include a registered email or mobile number, digital banking channels, ATMs and a letter.

What if the registered mobile number or email isn’t in use any more? Then the customer can’t use those channels. Ask the issuer which other listed channel it accepts, and note the answer.

Only the address has changed

The customer declares the new address through a permitted channel. The bank then checks it, for example with an address verification letter. Its own policy may also ask for a copy of an Officially Valid Document (OVD).

Sometimes the OVD still shows the old address. In that case the directions treat some documents as OVDs for address proof only, such as a utility bill that’s not more than two months old, or a property tax receipt. The customer then has to submit an OVD with the current address within three months. So before you say “that’s fine”, confirm the issuer accepts the temporary document, and write down the follow-up date. People forget this part.

The documents on record have expired

Here the directions require a process equivalent to new-customer KYC. The individual provisions allow Aadhaar, an OVD or an equivalent electronic document, or a KYC Identifier with the customer’s explicit consent. Aadhaar isn’t mandatory: the customer gives the number voluntarily, or to receive a benefit under a notified scheme. So if a customer is uneasy about giving Aadhaar, ask the issuer which other items it takes.

What if the customer has no PAN?

Don’t guess a form. This is the one spot where the sources stop short, and it’s better to say so than to bluff.

• What RBI says. The Commercial Banks directions list “PAN or the equivalent e-document thereof or Form No. 60 as defined in Income-tax Rules, 1962” among the things a bank obtains when it starts an account-based relationship (paragraph 23). For existing customers, paragraph 43 has the bank obtain the same items “by such date which the Central Government may notify”. If the customer doesn’t submit them, the bank can temporarily cease operations in the account, after giving notice and a reasonable chance to be heard. The Payments Banks (paragraph 43) and Small Finance Banks (paragraph 44) directions print the same wording.
• What the Income Tax Department says. Its FAQs on Interplay and Transition say at Q4.6 that a person without a PAN may enter a transaction listed in Rule 159(2) of the Income Tax Rules 2026 by filing a declaration in Form No. 97. That form replaces the earlier Form No. 60. The document calls itself general guidance, not a binding reading of the law.
• What nobody says. Neither the RBI texts nor the tax texts tell us whether an issuer accepts Form No. 97 in place of Form No. 60 when it updates an existing customer’s KYC. They also don’t say that PAN is compulsory for every such customer.

So you need the issuer’s answer in writing. Here’s how to get it.

1. Check that the customer really has no PAN. Some people have one and have simply forgotten the number.
2. Write to the issuer, and put the account or tag reference in the first line.
3. Ask what you need to know in one go: which account type is the tag linked to, and does the request need a PAN or a declaration in its place? What’s the name of any declaration form it accepts, and what evidence goes with it? Which channel receives it, and must the customer send it personally? By what date is it needed, and what happens to the account if that date passes?
4. Keep the reply, give the customer a copy, and prepare only what it names. The customer reads and signs any declaration personally. Don’t fill it in for them.

Until the issuer answers, don’t send an “unchanged details” declaration in place of the PAN item. And remember that one issuer’s answer settles only its own account category. Don’t pass it on to the next customer as a general FASTag rule.

Is a wallet upgrade a KYC update?

No. Converting to full KYC is a different request. RBI’s PPI Directions, checked on 17 October 2026, tell Small PPIs apart from Full-KYC PPIs. They allow a Video-based Customer Identification Process (V-CIP), which is a live audio-visual check by an authorised official, for full-KYC issuance or conversion. That doesn’t mean the customer’s app offers it. Use the issuer’s own conversion route.

The IHMCL FAQ page, retrieved on 17 October 2026 (page data: last modified 10 February 2024), says a non-KYC wallet customer who hasn’t upgraded after two years can’t recharge the wallet. It adds that the customer can keep using the balance until the tag shows low balance and gets blocked. That describes the IHMCL wallet, so ask the issuer whether the same applies to a bank-issued tag.

How do you submit through the issuer?

First, find the real contact. The NETC guidelines require the issuer to give the tag holder a toll-free user service number and show it on the tag, the usage guide and its website. The IHMCL FAQ page says an issuer tells a customer about incomplete KYC by email, SMS or its application interface.

For tags issued by NHAI, the customer logs in at fastag.ihmcl.com and chooses Update KYC Online. For bank-issued tags, the “Request for NETC FASTag” page on netc.org.in lets the customer pick the issuer and follow the link to its website. Treat all this as general guidance and check the issuer’s own notice.

Then work through it in this order:

1. Confirm the receiving channel. Use the contact on the tag, the usage guide or the issuer’s website. Don’t rely on a link or number printed inside the notice itself. If you can’t confirm where it goes, don’t send identity documents yet.
2. Review the response with the customer. They check names, address and document details. Fix any difference before submitting, because a mismatch is an easy reason for a rejection.
3. Let the customer authenticate. If the process needs an OTP, the customer types it in. Don’t read it aloud, forward it or put it in a screenshot. RBI’s fraud warning of 29 August 2024 advises against sharing these details or KYC copies with unidentified people or through unverified sites and apps.
4. Keep the reference. Note the issuer’s receipt date and reference. Give the customer a copy of exactly what was sent. For yourself, keep only the date, the reference and the issuer’s reply. Don’t keep photos of identity documents unless the customer agrees and you can store them safely.

When is the KYC update complete?

Two different messages matter here. The Commercial Banks directions require an acknowledgement showing when documents or a declaration were received. They also require a separate intimation stating when the KYC details were updated.

The acknowledgement proves receipt, nothing more. So don’t tell the customer the record is updated until the update confirmation arrives. If the issuer confirms receipt but not completion, follow up with the same reference and ask what’s still pending. And don’t promise that sending the documents will lift a restriction on the tag.

A completed declaration isn’t approved KYC either. The issuer decides whether the documents are enough.

What is your role at the counter?

Keep it modest. RBI’s rules allow a bank to use its authorised Business Correspondent to collect unchanged-information or address-only declarations. That route has its own authentication, forwarding and acknowledgement requirements, and the bank stays responsible for the update. Selling FASTags or doing recharges doesn’t make you that Business Correspondent. Unless the issuer confirms your role, keep the customer on the issuer’s own route and help them with the reading and the record-keeping.

If the issuer’s route fails, or its instructions contradict each other, contact it and quote the exact message you saw. For a PPI account, RBI’s PPI Directions require a published grievance framework with nodal-officer details, so there’s a place to escalate an unanswered submission.

Questions agents ask

What if the customer has received no KYC reminder?

The IHMCL FAQ page says a holder who has received no notification or reminder from the bank has complete KYC and needs no action. It speaks in general terms, so a customer who’s still unsure should ask the issuer.

Where can a customer check the KYC status of an NHAI-issued tag?

The IHMCL FAQ says the customer logs in at fastag.ihmcl.com and opens My Profile. That describes the IHMCL portal. For a bank-issued tag, ask the issuer where its status shows up.

Should I take a photo of the customer’s documents for my records?

Only the date, the reference and the issuer’s reply need to stay with you. Identity document images are the customer’s, so keep them only if the customer agrees and you can store them safely.

Help for a SiOnline account

For a problem with your SiOnline agent account, contact SiOnline support with your agent ID and the exact message, and never send a password or OTP. For agent-access problems, see the FASTag agent login guide. If you’re thinking about adding FASTag work at your counter, the FASTag agent page has the starting point.

Sources

All sources were retrieved on 17 October 2026: NPCI NETC Procedural Guidelines v2.1 (linked above); RBI KYC Directions for Commercial Banks, Payments Banks and Small Finance Banks; RBI circular of 28 November 2025; RBI PPI Directions; Income Tax Department FAQs on Interplay and Transition; IHMCL FAQ page and vehicle-validation circular of 30 December 2025; RBI fraud warning of 29 August 2024.