AIF Compliance Calendar FY 2026-27: SEBI Filing Obligations

The compliance calendar most AIF fund managers discover too late

You registered your AIF. Your scheme is live. Your first capital call is done.

Now SEBI’s quarterly deadline is in three weeks and your compliance calendar is a blank spreadsheet.

This is the most common scenario the compliance team at Treelife encounter with newly registered fund managers. The regulatory clock starts running from the date of SEBI registration, not from the date of First Close. If your scheme PPM was filed in October 2024 and you hit First Close in January 2025, your Q3 FY 2024-25 quarterly report was already due in January 2025.

This article gives you the complete FY 2026-27 compliance calendar – periodic, event-based, and category-specific – that a fund manager operating a trust-form AIF under the SEBI (Alternative Investment Funds) Regulations, 2012 (AIFR 2012) needs to run a clean compliance cycle.

What governs AIF compliance obligations?

The primary legal source for all ongoing compliance obligations is SEBI’s Master Circular No. SEBI/HO/AFD-1/AFD-1-PoD/P/CIR/2024/39 dated 7 May 2024 (the 2024 Master Circular). This circular superseded the July 2023 Master Circular and consolidated all SEBI instructions for AIFs issued up to 31 March 2024. It is the operative document for every filing, disclosure, and certification obligation covered in this calendar.

The AIFR 2012 itself sets the structural framework: registration, investment conditions, leverage limits, and investor rights. The Master Circular operationalises that framework into specific timelines, formats, and portals. Fund managers who track only the Regulations without tracking the Master Circular and subsequent circulars issued after March 2024 will miss procedural updates, new certification requirements, and revised filing formats.

Three regulatory layers every fund manager must track:

1. SEBI (Alternative Investment Funds) Regulations, 2012 – the primary source of law.
2. SEBI Master Circular (currently the May 2024 version, updated by subsequent standalone circulars) – operational compliance instructions with specific deadlines.
3. Post-Master Circular standalone circulars – including the December 2025 Compliance Officer NISM certification mandate and the 2024 ADR filing requirement. These are not yet consolidated into the Master Circular and must be tracked independently.

Quarterly obligations: what every AIF must file

Every AIF – Category I, II, and III – must submit a quarterly activity report to SEBI within 15 calendar days from the end of each quarter. The report covers investment-level data, portfolio composition, fundraising activity, and investor details. It is filed online through the SEBI Intermediary Portal (SI Portal at siportal.sebi.gov.in) in the format prescribed and maintained by the AIF industry associations IVCA and Equalifi, per para 15.1.1 of the 2024 Master Circular.

AIF Quarterly deadlines (FY 2026-27):

Quarter	Period	Filing Deadline
Q1 FY 2026-27	April – June 2026	15 July 2026
Q2 FY 2026-27	July – September 2026	15 October 2026
Q3 FY 2026-27	October – December 2026	15 January 2027
Q4 FY 2026-27	January – March 2027	15 April 2027

Note: Quarters above are calendar quarters aligned to SEBI’s reporting cycle, not Indian FY quarters.

Category III additional quarterly obligations:

Category III AIFs carry two additional quarterly filings that do not apply to Category I and II funds:

• Leverage report: A quarterly report on leverage undertaken by the fund, in the revised SEBI format, filed through the SI Portal. This is separate from the standard activity report and has the same 15-calendar-day deadline.
• AIF Data Repository (ADR) filing: Introduced in 2024, this is a mandatory quarterly data submission to the ADR platform within 7 days from quarter-end. The ADR obligation applies to Category III funds and must be included in compliance calendars; many older AIF compliance checklists do not capture it.

Investor complaint data: All AIFs must compile investor complaint data within 7 days from the end of each quarter, per SEBI’s Investor Charter requirements. This is distinct from the SCORES grievance registration but runs on the same quarterly cadence.

Annual obligations: the full-year compliance cycle

What is the Compliance Test Report (CTR) and when is it due?

The CTR is an annual self-assessment that the Manager of the AIF must prepare confirming compliance with the AIFR 2012 and all SEBI circulars. Under para 15.2 of the 2024 Master Circular, the CTR must be prepared in the specified format and submitted within 30 days from the end of the financial year – that is, by 30 April each year – to the Trustee and Sponsor (for a trust-form AIF) or to the Sponsor (for other forms).

The Trustee or Sponsor then has 30 days to raise observations. If observations are raised, the Manager must submit a reply within 15 days.

The December 2025 Compliance Officer NISM certification circular (Circular No. HO/19/(8)2025-AFD-POD1/I/1266/2025) added one new requirement to the CTR: it must now expressly include confirmation that the Compliance Officer of the Manager satisfies, or is on track to satisfy, the NISM Series-III-C certification requirement effective 1 January 2027.

Private Placement Memorandum (PPM) annual compliance audit:

Every AIF must conduct a PPM compliance audit within six months of financial year-end – that is, by 30 September each year – verifying that the fund’s actual operations are consistent with the terms of the PPM filed with SEBI. This audit can be conducted by an internal or external auditor or legal professional. The audit report is shared with investors and kept on record for SEBI inspection.

Annual obligations summary (FY 2026-27):

Obligation	Deadline	Notes
Compliance Test Report	30 April 2026	CTR format per para 15.2; now includes NISM confirmation
PPM compliance audit	30 September 2026	Internal or external auditor acceptable
Annual financial statements	30 September 2026	Per AIFR 2012 Reg. 20(14)
Performance benchmarking data	28 September 2026	Submitted to SEBI-empanelled benchmarking agencies
NISM certification (Compliance Officer)	Before 1 January 2027	NISM Series-III-C: Securities Intermediaries Compliance (Fund)

Half-yearly obligations: portfolio reporting and investor disclosures

Under the 2024 Master Circular, all AIFs must submit half-yearly portfolio reports to SEBI through the SI Portal. The half-yearly periods end on 30 September and 31 March. Portfolio-level data including investment valuations, exits, and sector exposures is covered in this report.

Category II AIFs must additionally provide half-yearly reports to each investor disclosing the fund’s portfolio, financial position, material risks, and performance relative to benchmarks. This obligation runs parallel to the SEBI-facing half-yearly portfolio report and is investor-facing.

The Manager must also communicate any material deviation from the PPM investment strategy to investors on a half-yearly basis, even if no SEBI filing is required for that specific deviation.

Half-yearly deadlines (FY 2026-27):

Period	End Date	Report Due
H1 FY 2026-27	30 September 2026	By 29 November 2026
H2 FY 2026-27	31 March 2027	By 30 May 2027

What triggers event-based filings?

Not all SEBI compliance obligations run on a calendar. Several filings are triggered by specific events in the life of the fund. Missing these is the compliance failure mode most fund managers encounter, because there is no deadline printed in the calendar until the event occurs.

Event-based filing obligations:

1. Change in key management personnel (KMP): Any change in KMP of the Manager (CEO, CIO, Compliance Officer, or others named in the PPM) must be intimated to investors as specified in the PPM and to SEBI through the SI Portal within the timelines prescribed in Reg. 20 of the AIFR 2012. The specific intimation format and timeline depend on whether SEBI prior approval is required (for change in control of Manager or Sponsor) or whether intimation is sufficient.
2. PPM amendments: Material changes to the PPM require SEBI intimation through a Merchant Banker. Non-material changes can be notified to SEBI directly. The 2024 Master Circular relaxed the earlier requirement for all PPM changes to be routed through a Merchant Banker; only material changes now require it. Fund managers running on the pre-2024 process may be over-complying on minor amendments.
3. New scheme launch: Each subsequent scheme after the first requires a scheme PPM to be filed with SEBI at least 30 days before launch. The 30-day window is a hard regulatory requirement, not a soft guidance period. Build this into your fundraising timeline before you begin LP conversations for the new scheme.
4. Breach of investment conditions or placement memorandum terms: Any breach of the investment conditions under Regulation 15 of the AIFR 2012, or of any provision of the PPM, must be reported to SEBI. The 2024 Master Circular requires that such breaches be reported in the quarterly activity report and separately communicated to investors.
5. Change in control of Manager or Sponsor: Requires SEBI prior approval before any NCLT filing or execution, per the 2024 Master Circular’s streamlined process. SEBI’s in-principle approval carries a three-month validity, and the process requires a specific application format.
6. Liquidation scheme trigger: If the fund is transitioning to a Liquidation Scheme (available where 75% of investors by value consent), the Manager must file with SEBI and provide exit options to dissenting investors as prescribed in the Master Circular.

The NISM certification requirement: what fund managers must do now

What is the NISM certification obligation for AIF key personnel?

SEBI has introduced two distinct NISM certification obligations that affect fund managers.

The first applies to the key investment team. Under SEBI’s amendment notified in May 2024, at least one key personnel in the investment team of the Manager of a Category I or Category II AIF must hold valid certification from NISM by passing NISM Series-XIX-C: Alternative Investment Fund (AIF) Distributors Certification Examination. Existing AIFs were required to comply by July 2025.

The second applies to the Compliance Officer. SEBI’s circular dated 30 December 2025 (Circular No. HO/19/(8)2025-AFD-POD1/I/1266/2025) mandates that the Compliance Officer of the Manager must obtain certification by passing NISM Series-III-C: Securities Intermediaries Compliance (Fund) Certification Examination. From 1 January 2027, only persons who have obtained this certification can act as, or be appointed as, Compliance Officers for AIF Managers.

Action required in FY 2026-27:

• If your Compliance Officer does not hold NISM Series-III-C certification, they must register and pass the examination before 1 January 2027.
• The CTR for FY 2025-26 (due 30 April 2026) must expressly confirm compliance status against this requirement.
• NISM Series-III-C became available from 24 November 2025 per NISM’s communique dated 20 November 2025.

Dematerialisation and valuation obligations: two obligations new funds often miss

Dematerialisation of AIF units:

All units issued by an AIF from November 2023 onwards must be in dematerialised form only. AIFs must hold their portfolio investments in dematerialised form from October 2024 onwards, subject to specific exemptions for investments made prior to that date.

If your fund issued physical units before November 2023 and has not migrated those investors to demat, the outstanding physical units create an ongoing compliance gap. SEBI’s 2024 Master Circular specifies an “Aggregate Escrow Demat Account” mechanism for investors who have not provided demat account details; parking units in escrow is a transitional measure, not a permanent solution.

Independent valuation:

All AIF investments must be valued in accordance with SEBI’s prescribed norms, with the valuation methodology disclosed in the PPM. The Manager is responsible for ensuring fair valuation. Independent valuers must meet SEBI’s eligibility criteria – a category that Treelife’s compliance team routinely verifies at fund setup to avoid mid-fund corrections.

Any deviation from the PPM-stated valuation methodology must be reported in the performance benchmarking submission. This is a disclosure obligation that many fund managers miss until their first PPM audit flags it.

Does the AIF compliance calendar vary by category?

Yes. While the core SEBI obligations – quarterly activity report, CTR, PPM audit, and half-yearly disclosures – apply to all AIFs, Category III carries materially heavier periodic obligations.

Comparison of periodic obligations by AIF category:

Obligation	Category I	Category II	Category III
Quarterly activity report (SI Portal)	Yes – 15 days	Yes – 15 days	Yes – 15 days
Quarterly leverage report	No	No	Yes – 15 days
ADR quarterly filing	No	No	Yes – 7 days
Half-yearly portfolio report to SEBI	Yes	Yes	Yes
Half-yearly investor disclosures	Optional per PPM	Yes – mandatory	Yes – mandatory
Daily NAV disclosure	No	No	Yes
Strategy-level exposure reports	No	No	Yes – 7 days from trigger event
Dedicated compliance officer requirement	Yes	Yes	Yes – with derivative accounting capability
Annual CTR	Yes	Yes	Yes
PPM compliance audit	Yes	Yes	Yes
Performance benchmarking submission	Yes	Yes	Yes

What Treelife handles for fund managers running AIF compliance

The Treelife compliance team, runs AIF compliance calendaring and execution for Category I, II, and III funds from scheme launch through annual audit.

Engagements typically cover:

• Building and maintaining a fund-specific compliance calendar anchored to SEBI, income tax, and FEMA deadlines, with clear ownership and escalation protocols.
• Preparing and filing all quarterly SEBI activity reports through the SI Portal, including the leverage overlay for Category III.
• Drafting the annual CTR in the SEBI-prescribed format, incorporating the NISM certification confirmation requirement, and coordinating Trustee review.
• Coordinating the PPM compliance audit with empanelled auditors and flagging deviations that need investor notification or SEBI intimation.
• Managing event-based filings including KMP change intimations, PPM amendments, scheme launches, and breach reporting so that nothing falls through the gap between scheduled cycles.
• Tracking post-Master Circular standalone circulars and updating the compliance calendar before their deadlines become active.

Our AIF compliance engagements are built for fund managers who want to operate the fund and make investment decisions, not administrate a regulatory calendar. If you are in the first 18 months of running your scheme, the earliest engagement point – before the first CTR cycle – is where Treelife adds the most leverage.

To discuss your fund’s FY 2026-27 compliance calendar, contact Treelife for a 45-minute scoping call via our AIF Setup and Compliance page.

Common mistakes AIF fund managers make in the first compliance cycle

Mistake 1: Treating registration date as the compliance start date

Fund managers sometimes assume compliance reporting begins at First Close or at the start of the next financial year. Under AIFR 2012, compliance obligations commence from the date of SEBI registration. A fund registered in November and hitting First Close in February already missed a quarterly report.

Correct approach: Build the compliance calendar before First Close, anchored to the SEBI registration date. The first quarterly report is due 15 days after the end of the calendar quarter in which registration occurred.

Mistake 2: Missing the ADR filing for Category III funds

The AIF Data Repository (ADR) filing requirement was introduced in 2024. Fund managers operating pre-2024 compliance checklists, or using compliance templates that predate the 2024 Master Circular, will not have this obligation on their calendar. The 7-day ADR deadline is tighter than the 15-day quarterly report deadline.

Correct approach: Update your compliance calendar to the 2024 Master Circular version. The ADR platform and filing format are managed through SEBI’s intermediary portal infrastructure.

Mistake 3: Filing the CTR without the NISM certification confirmation

Since the December 2025 circular, the CTR format must expressly confirm compliance with the Compliance Officer NISM certification requirement. Many compliance officers preparing the FY 2025-26 CTR will use the prior-year format and miss this new confirmation block.

Correct approach: Before filing the FY 2025-26 CTR (due 30 April 2026), verify that your Compliance Officer holds or is actively pursuing NISM Series-III-C certification, and that the CTR format has been updated to include the confirmation.

Mistake 4: Conflating the half-yearly SEBI portfolio report with the investor disclosure

These are two separate obligations. The SEBI-facing half-yearly portfolio report goes through the SI Portal. The investor-facing half-yearly disclosure goes to each LP directly, per the format and content requirements of the PPM and the Master Circular. Running one without the other leaves either SEBI or your investors under-informed – both are compliance failures.

Correct approach: Maintain separate calendars for SEBI-facing filings and investor-facing disclosures, with different ownership within the Manager’s team.

Mistake 5: Not updating the compliance calendar after standalone SEBI circulars

The 2024 Master Circular is the baseline, but SEBI issues standalone circulars throughout the year – and each one potentially adds, modifies, or defers an obligation. Fund managers who track compliance only against the consolidated Master Circular will be operating on a stale calendar within six months of the Master Circular’s publication date.

Correct approach: Assign someone in the Manager’s team to monitor SEBI AFD (Alternative Funds Division) circulars monthly, and review the compliance calendar after each new issuance.

In the AIF compliance engagements we have run at Treelife, the most consistent pattern we see is not a single missed deadline; it is a compliance architecture that was designed for registration and never rebuilt for the ongoing cycle. The SEBI registration process for an AIF is documentation-intensive and lawyers are deeply engaged. But the moment the certificate issues, the compliance obligation shifts from document preparation to process ownership, and many fund managers find that their legal counsel has stepped back and their internal team was never set up to own the calendar.