Revised nomination opt-out workflows

Collection of Video based consent or OTP based consent with signed declaration forms for nomination opt-out cases

As per SEBI Circular NO. SEBI/HO/OIAE/OIAE_IAD-3/P/ON/2025/01650 dated 10th January, 2025,

  • The 1st and 2nd phase of these changes went live on 1st June, 2025 and it majorly covered the implementation of cases where the investor opted in for nominations.
  • The 3rd phase of this circular is going live on 15th December, 2025 which will cover the implementation of cases where the investor opted out of nominations.

Here are the highlights of the changes as mentioned in the circular -

  • Going ahead, you need to extend the support upto 10 nominees
  • If the investor is opting out of the nomination for a particular folio creation request, there has to be an explicit consent taken from them either in form of a video recording or in the form of OTP + signed opt-out declaration

Changes that needs to be accommodated at your end to facilitate these changes -

  • In case of nomination opt-in workflows, FP/Cybrilla is going to continue the support to only upto 3 nominees. In case any investor wants to add more nominees, an external NCT can be initiated at the respective AMC portals
  • In case of nomination opt-out workflows, FP/Cybrilla is going to support Video based consent to start with
    • Since there is no enough clarity on the implementation of OTP based consent + signed declaration form option at an industry level, we are starting to accept Video based consent inorder to ensure business continuity
    • We will work in parallel regarding OTP based consent + signed declaration form option and share more details on this in the coming days
  • WRT Video based opt-out consent flow, below are the changes that you need to take care of -
    1. Whenever an investor chooses to opt-out of the nominations for a particular folio creation request, record a video of the investor conveying the below points -
      • Investor's name and PAN number
      • Choice of opting out of nominations
    2. Once the video is recorded, upload the same to FP/Cybrilla and proceed with the order workflow
  • In case of nomination opt-out, only after investor completes the above mentioned workflow, can the order workflow be continued further to collect payment or activate a plan.
  • The above points are applicable for every folio creation request. This also means that - if you are supporting batch orders (basket orders) and the investor is opting out of nominations, all the above mentioned points should be taken care of for each of those orders.
    • Even in cases of batch orders where multiple orders belong to the same AMC, the above points should be taken care for each of those folio creation requests as well

Assumption: The investor has opted out of nominations and the same has been updated on the respective mf_investment_account.folio_defaults object.

  1. Once you have collected the video recording from the investor, pass it in Create a File API

  2. Once you have the File ID, create a mf_folio_creation_request using the below API -

    POST {{base_url}}/v2/mf_folio_creation_requests
{
"mf_investment_account":"mfia_3c1f0c0b0f15474e90baf9f32692c6eb",

"nomination_opt_out": true,        
"nomination_opt_out_declaration":"file_96a0ccde4bb74ce6b79bab6b720d479c"
}

  3. mf_folio_creation_request object will look like below

    {
"object": "mf_folio_creation_request",
"id": "mfcr_3c1f0c0b0f15474e90baf9f32692c6eb",

"mf_investment_account": "mfia_3c1f0c0b0f15474e90baf9f32692c6eb",

"nomination_opt_out": true,
"nomination_opt_out_declaration": "file_96a0ccde4bb74ce6b79bab6b720d479c",

"created_at": "<timestamp>"
}

  4. Only after ensuring the above points are completed, you can go ahead and create a MF Puchase or a MF Purchase Plan

  5. While creating mf_purchase or mf_purchase_plan, ensure to provide the mf_folio_creation_request.id in the request body. Refer to the below examples -

    POST {{base_url}}/v2/mf_purchases
{
"mf_investment_account": "mfia_367a75826694614a539c0f82b196027",

"mf_folio_creation_request": "mfcr_3c1f0c0b0f15474e90baf9f32692c6eb",

"scheme": "INF173K01FE6",
"amount": 10000

// Object trimmed for brevity
}

    POST {{base_url}}/v2/mf_purchase_plans
{
"mf_investment_account": "mfia_d8c1b501c10d4835947a5c77fc031789",

"mf_folio_creation_request": "mfcr_3c1f0c0b0f15474e90baf9f32692c6eb",

"scheme": "INF109K01TP7",
"frequency": "daily",
"amount": 21,
"number_of_installments": 6,
"systematic": true

// Object trimmed for brevity
}

  6. Once mf_folio_creation_request is associated with MF Purchase or MF Purchase Plan, the subsequent order workflow would continue as currently implemented.