Alternative Investment Funds (AIF) Compliance Calendar – SEBI Filing & Regulatory

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 This circular superseded the July 2023 Master Circular and consolidated all SEBI instructions for AIFs issued up to 31 March 2024.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.

Master AIF compliance checklist for FY 2026-27

Every AIF operating under the SEBI (Alternative Investment Funds) Regulations, 2012 must track compliance obligations across six frequencies: annual, half-yearly, quarterly, monthly, daily (Category III only), and event-based. The table below gives a complete bird’s-eye view of all filing obligations with the submitting party, recipient, and applicable category. Detailed deadlines and regulatory citations follow in each section below.

Table: Complete AIF compliance obligation summary

#	Compliance obligation	Submitted by	Submitted to	Frequency	Category applicability
1	Quarterly activity report	Manager	SEBI	Quarterly	I, II, III
2	Compliance Test Report (CTR)	Manager	Trustee and Sponsor	Annual	I, II, III
3	PPM compliance audit findings	Manager	Trustee, Board/DP of Manager, SEBI	Annual	I, II, III
4	CA certificate (no funds raised)	Manager	Trustee, Board/DP, SEBI	Annual	I, II, III
5	PPM changes (consolidated)	Manager	SEBI and Investors	Annual	I, II, III
6	Annual investor report	Manager	Investors	Annual	I, II
7	Quarterly investor report	Manager	Investors	Quarterly	III
8	Valuation methodology disclosure	Manager	SEBI and Investors	Annual	I, II, III
9	Half-yearly valuation and portfolio report	Manager	Performance Benchmarking Agency	Half-yearly	I, II, III
10	Half-yearly investor disclosure (valuation)	Manager	Investors	Half-yearly	I, II
11	NAV disclosure (close-ended)	Manager	Investors	Quarterly	III
12	NAV disclosure (open-ended)	Manager	Investors	Monthly	III
13	Quarterly leverage report	Manager	SEBI	Quarterly	III only
14	Daily leverage amount report	Manager	Custodian	Daily	III only
15	ADR quarterly filing	Manager	ADR platform	Quarterly (7 days)	III only
16	Investor complaint data compilation	Manager	Investors	Quarterly	I, II, III
17	KYC data for Aggregate Escrow Demat Account	Manager	Depositories and Custodian	Monthly	I, II, III
18	Form InVI (units issued to foreign residents)	Manager	RBI	Monthly (within 30 days of issuance)	I, II, III
19	DPIIT intimation (downstream investment)	Manager	Secretariat for Industrial Assistance, DPIIT	Monthly (within 30 days)	I, II, III
20	Form DI (indirect foreign investment)	Manager	RBI	Monthly (within 30 days of allotment)	I, II, III
21	FLA return	Manager	RBI	Annual (by 15 July)	I, II, III
22	Cash Transaction Report (PMLA)	Principal Officer	FIU-IND	Monthly (within 15 days)	I, II, III
23	Suspicious Transaction Report	Principal Officer	FIU-IND	Immediate	I, II, III
24	Immovable property transaction report	Principal Officer	FIU-IND Director	Quarterly (within 15 days)	I, II, III
25	CKYCRR client KYC filing	Manager	Central KYC Records Registry	Event (within 10 days)	I, II, III
26	FIU-IND appointment intimation	Manager	FIU-IND Director	One-time / Event	I, II, III
27	Annual cyber audit report	Manager	SEBI	Annual (within 1 month of completion)	I, II, III
28	VAPT report	Manager	SEBI	Annual	I, II, III
29	Cyber resilience self-assessment (CCI)	Manager	SEBI	Annual	I, II, III
30	CSCRF half-yearly standards compliance	Manager	SEBI	Half-yearly	I, II, III (AUM-dependent)
31	CSCRF quarterly standards compliance	Manager	SEBI	Quarterly	I, II, III (AUM-dependent)
32	Digital accessibility audit compliance	Manager	SEBI	Annual (within 30 days of FY end)	I, II, III
33	Income tax return	Manager	Income Tax Department	Annual (31 October)	I, II, III
34	Advance tax payments	Manager	Income Tax Department	Quarterly (15 Jun, Sep, Dec, Mar)	I, II, III
35	TDS payment	Manager	Income Tax Department	Monthly (7th of following month)	I, II, III
36	TDS returns	Manager	Income Tax Department	Quarterly	I, II, III
37	Form 64D (income distributed to IT authorities)	Manager	Income Tax Department	Annual (15 June)	I, II only
38	Form 64C (income distributed to unit holders)	Manager	Unit holders	Annual (30 June)	I, II only
39	Form 15CA/15CB (foreign remittance)	Manager	Income Tax Department	Per remittance	I, II, III
40	Overseas investment utilisation report	Manager	SEBI	Event (within 5 working days)	I, II, III
41	Un-utilised overseas limit report	Manager	SEBI	Event (within 2 working days of expiry)	I, II, III
42	Overseas limit surrender report	Manager	SEBI	Event (within 2 working days)	I, II, III
43	Overseas investment divestment details	Manager	SEBI	Event (within 3 working days)	I, II, III
44	KMP change disclosure	Manager	SEBI and Investors	Event	I, II, III
45	Material non-compliance report	Compliance Officer	SEBI	Event (within 7 working days)	I, II, III
46	Conflict of interest disclosure	Manager and Sponsor	Investors	Event (as and when)	I, II, III
47	Change in control (prior approval)	Manager	SEBI	Event (prior approval required)	I, II, III
48	Breach of investment conditions	Manager	SEBI and Investors	Event	I, II, III
49	Liquidation scheme reporting	Manager	SEBI	Quarterly	I, II, III
50	Performance of liquidation scheme	Manager	Performance Benchmarking Agency	Half-yearly	I, II, III
51	CDS transaction reporting	Manager	Custodian	Daily (next working day)	II, III
52	Investor grievance redressal	Manager	Investors	Event (within 21 calendar days)	I, II, III

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)

Liquidation Scheme compliance obligations

Where an AIF has not been able to fully liquidate its portfolio by the end of the fund tenure and its extended tenure, the 2024 Master Circular provides a Liquidation Scheme pathway under Chapter 23. Entry into a Liquidation Scheme requires consent of at least 75% of investors by value and creates a distinct set of ongoing compliance obligations that run parallel to the wind-down.

The Liquidation Scheme compliance obligations include:

• Quarterly reporting to SEBI on compliance with the provisions of Chapter 23 of the 2024 Master Circular upon exercising any of the options to distribute unliquidated investments (Para 23.4.2 of the Master Circular).
• Half-yearly performance reporting of the Liquidation Scheme to the Performance Benchmarking Agency, within 45 days from the end of the half-year ending 30 September and within 6 months from the end of the half-year ending 31 March (Para 23.1.14 of the Master Circular).
• Timely reporting of the value of unliquidated investments sold to the Liquidation Scheme or distributed in-specie to the Performance Benchmarking Agencies (Para 23.4.3 of the Master Circular).

Suitable disclosure in respect of the Liquidation Scheme must also be made in the PPMs of any subsequent schemes launched by the Manager.

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.

Table: Half-yearly AIF obligations and deadlines (FY 2026-27)

Obligation	Period end date	Submission due	Submitted to	Applicable to
Half-yearly portfolio report to SEBI (SI Portal)	30 September 2026	14 November 2026 (45 days)	SEBI	I, II, III
Half-yearly portfolio report to SEBI (SI Portal)	31 March 2027	30 September 2027 (6 months)	SEBI	I, II, III
Scheme-wise valuation and cash flow data	30 September 2026	14 November 2026 (45 days)	Performance Benchmarking Agency	I, II, III (schemes with at least 1 year from First Close)
Scheme-wise valuation and cash flow data	31 March 2027	30 September 2027 (6 months)	Performance Benchmarking Agency	I, II, III (schemes with at least 1 year from First Close)
Investor-facing valuation disclosure	30 September 2026	By 29 November 2026	Investors	I (unless extended to annual by 75% investors); II, III (mandatory)
Investor-facing valuation disclosure	31 March 2027	By 30 May 2027	Investors	I (unless extended to annual by 75% investors); II, III (mandatory)
CSCRF half-yearly standards compliance	30 September 2026	14 November 2026	SEBI	AIFs with AUM below Rs. 1,000 crore
CSCRF half-yearly standards compliance	31 March 2027	30 September 2027	SEBI	AIFs with AUM below Rs. 1,000 crore
Liquidation Scheme performance reporting	30 September 2026	14 November 2026 (45 days)	Performance Benchmarking Agency	Funds under Liquidation Scheme
Liquidation Scheme performance reporting	31 March 2027	30 September 2027 (6 months)	Performance Benchmarking Agency	Funds under Liquidation Scheme

The bifurcated performance benchmarking deadline (45 days for the September half-year, 6 months for the March half-year) is a design feature of the Master Circular: the September deadline is tight because the fund must submit preliminary unaudited data, while the March deadline aligns with the annual audit cycle. Fund managers who apply a single 45-day rule to both half-years will create a compliance gap for the March submission.

The half-yearly valuation disclosure to investors under Regulation 23(1) and 23(2) of the AIFR 2012 for Category I AIFs can be extended to annual frequency with the approval of at least 75% of investors by value of their investment. Category II and Category III funds do not have this extension option.

Monthly compliance obligations for AIFs

Monthly obligations are the most overlooked frequency in AIF compliance. Unlike quarterly reports that have a visible SEBI portal deadline, monthly filings are process-level obligations triggered by fund activity rather than a calendar date. Missing them creates a running compliance deficit that compounds into larger violations.

KYC data reporting for Aggregate Escrow Demat Account

Under para 20.12 of the 2024 Master Circular, the Manager must report investor-wise KYC data for units held in the Aggregate Escrow Demat Account, including name, PAN, and bank account details along with audit trail of transactions, to Depositories and the Custodian every month. This applies to existing investors who have not provided demat account details. For Category I funds, the deadline is within 15 days from the beginning of the next month. For Category II and III funds, the deadline is simply monthly with no specified day, making it advisable to align this to the same 15-day window.

NAV disclosure for Category III open-ended funds

Category III AIFs operating open-ended schemes must disclose NAV to investors at intervals not longer than one month. This is a direct obligation under Regulation 23(3) of the AIFR 2012. The frequency cannot be reduced by investor consent; it is a hard regulatory floor. Category III close-ended funds have a quarterly NAV disclosure obligation instead.

Table: Monthly AIF compliance deadlines

Obligation	Submitted by	Submitted to	Deadline	Regulation
KYC data for Escrow Demat Account	Manager	Depositories and Custodian	Within 15 days of month start (Cat I); monthly (Cat II, III)	Para 20.12, 2024 Master Circular
NAV disclosure (open-ended Cat III)	Manager	Investors	Monthly (at intervals not exceeding 1 month)	Reg. 23(3), AIFR 2012
Form InVI filing (foreign unit issuance)	Manager	RBI	Within 30 days of unit issuance	Rule 4(10), FEMA Regulations 2019
DPIIT downstream investment intimation	Manager	Secretariat, DPIIT	Within 30 days of downstream investment	Rule 4(11)(a), FEMA Regulations 2019
Form DI filing (indirect foreign investment)	Manager	RBI	Within 30 days of equity allotment	Rule 4(11)(b), FEMA Regulations 2019
Cash Transaction Report (PMLA)	Principal Officer	FIU-IND Director	Within 15 days of succeeding month	Rule 3(1)(E) r/w Rule 8(1), PMLA Rules 2005

The FEMA and PMLA monthly obligations are covered in detail in the sections immediately below. The key point for operational compliance planning is that Form InVI, Form DI, and the DPIIT intimation are event-triggered within a monthly window rather than date-triggered: the 30-day clock starts from the triggering event (unit issuance or downstream investment), not from month-end.

FEMA compliance obligations for AIFs with foreign investors

Any AIF that has issued units to a person resident outside India, or that makes downstream investments where the Manager or Sponsor is not Indian owned and controlled, carries a parallel set of obligations under the Foreign Exchange Management Act, 1999 and the Foreign Exchange Management (Mode of Payment and Reporting of Non-Debt Instruments) Regulations, 2019 (FEMA Regulations 2019). These obligations run alongside SEBI filings and are reported to the Reserve Bank of India and DPIIT rather than SEBI. Many fund managers with predominantly domestic LPs are unaware of these obligations until a foreign co-investor participates in a close, at which point the 30-day filing clock has already started.

Form InVI: reporting foreign unit issuances to RBI

Under Rule 4(10) of the FEMA Regulations 2019, the Manager must file Form InVI with the RBI within 30 days from the date of issuance of units to a person resident outside India. This applies each time foreign investors receive units, including at each drawdown for a close-ended fund. The Form InVI is filed through the RBI’s FIRMS portal (Foreign Investment Reporting and Management System). Failure to file within 30 days constitutes a FEMA violation and attracts compounding proceedings under Section 15 of FEMA.

Downstream investment reporting

An AIF making a downstream investment in another Indian entity is required to comply with two separate reporting obligations depending on the nature of the investment:

• Under Rule 4(11)(a) of the FEMA Regulations 2019, the Manager must intimate the Secretariat for Industrial Assistance, DPIIT within 30 days of the downstream investment, even if equity instruments have not yet been allotted. This intimation covers the modality of investment in new or existing ventures.
• Under Rule 4(11)(b), if the downstream investment is regarded as indirect foreign investment because the Manager or Sponsor is not Indian owned and controlled, the Manager must file Form DI with the RBI within 30 days from the date of allotment of equity instruments.

The distinction between Rule 4(11)(a) and (b) obligations is important: (a) is triggered by the investment act itself regardless of allotment, while (b) is triggered by allotment. Both can apply to the same transaction if the fund has foreign ownership at the Manager level.

Foreign Liabilities and Assets (FLA) return

The FLA return is an annual obligation under Rule 4(2) of the FEMA Regulations 2019. Every AIF that has received foreign investment or made foreign investments in the previous financial year must file the FLA return with the RBI by 15 July of the following financial year. For FY 2025-26, the FLA return is due by 15 July 2026. The return is filed through the RBI’s FLAIR portal (Foreign Liabilities and Assets Information Reporting system). Non-filing attracts penalty under FEMA.

Table: FEMA compliance obligations for AIFs

Obligation	Form / Portal	Submitted to	Deadline	Regulation
Report foreign unit issuance	Form InVI / FIRMS	RBI	Within 30 days of unit issuance	Rule 4(10), FEMA Regulations 2019
Downstream investment intimation	Letter / DPIIT portal	Secretariat, DPIIT	Within 30 days of investment	Rule 4(11)(a), FEMA Regulations 2019
Downstream indirect foreign investment	Form DI / FIRMS	RBI	Within 30 days of equity allotment	Rule 4(11)(b), FEMA Regulations 2019
FLA return (annual)	FLAIR portal	RBI	15 July of following FY	Rule 4(2), FEMA Regulations 2019

When FEMA obligations are triggered for a typical close-ended AIF:

A Category II AIF with one foreign institutional LP will trigger Form InVI at every drawdown close where that LP’s units are issued, and will require FLA return filing annually as long as that LP holds units. If the same fund invests in a company where the Manager holds equity, and the Manager has foreign shareholders above the applicable threshold, each portfolio investment potentially triggers both the DPIIT intimation and the Form DI filing. In practice, the compliance team must map each investment against the Manager’s ownership structure before each deployment to determine which FEMA obligations attach.

PMLA and AML compliance obligations every AIF must maintain

AIF Managers are “reporting entities” under the Prevention of Money Laundering Act, 2002 (PMLA) and the Prevention of Money-Laundering (Maintenance of Records) Rules, 2005 (PMLA Rules). This means they carry a set of ongoing AML compliance obligations that exist entirely outside the SEBI filing framework. These obligations are enforced by the Financial Intelligence Unit, India (FIU-IND) under the Ministry of Finance, not by SEBI. SEBI inspections of AIFs now routinely check for PMLA compliance gaps.

Appointment of Principal Officer and Designated Director

Under Rule 7(1) of the PMLA Rules 2005, the Manager must designate a Principal Officer and a Designated Director. On appointment, the Manager must submit a letter to the Office of the Director, FIU-IND communicating the appointment and contact details of both persons. This is a one-time obligation that must be completed before the AIF begins fundraising. Any change in these designations must be immediately re-reported to FIU-IND.

Cash Transaction Reports (CTR under PMLA)

The Principal Officer must file Cash Transaction Reports for all cash transactions, including all cross-border wire transfers above Rs. 5 lakhs or its equivalent in foreign currency where the origin or destination of funds is in India. Filing deadline under Rule 3(1)(E) read with Rule 8(1) of the PMLA Rules 2005 is within 15 days of the succeeding month. Note: “CTR” in the PMLA context refers to Cash Transaction Reports filed with FIU-IND. This is entirely separate from the Compliance Test Report (CTR) filed with the Trustee and Sponsor under SEBI regulations. The acronym overlap creates confusion in multi-document compliance frameworks.

Suspicious Transaction Reports (STR)

Under Rule 3(1)(D) read with Rule 8(2) of the PMLA Rules 2005, the Principal Officer must report all suspicious transactions to the FIU-IND Director immediately, with no prescribed lag. Suspicious transactions include any transaction that raises reasonable grounds to suspect money laundering, regardless of transaction size.

Quarterly immovable property transaction reporting

Under Rule 3(1)(F) read with Rule 8(3) of the PMLA Rules 2005, the Principal Officer must furnish information on all purchase and sale by any person of immovable property valued at Rs. 50 lakhs or more that is registered by the AIF. This report is due within 15 days from the end of each quarter.

Central KYC Records Registry (CKYCRR) filing

Under Rule 9(1-A) of the PMLA Rules 2005, the Manager must file an electronic copy of each investor’s KYC records with the Central KYC Records Registry within 10 days of commencement of an account-based relationship with the investor. In practice, this obligation is triggered at investor onboarding (contributor agreement execution) and must be built into the subscription and onboarding workflow.

Table: PMLA compliance obligations for AIF Managers

Obligation	Filed by	Filed to	Deadline	Regulation
FIU-IND appointment intimation	Manager	FIU-IND Director	Immediate on appointment	Rule 7(1), PMLA Rules 2005
Cash Transaction Report (CTR-PMLA)	Principal Officer	FIU-IND Director	Within 15 days of succeeding month	Rule 3(1)(E) r/w Rule 8(1), PMLA Rules 2005
Suspicious Transaction Report (STR)	Principal Officer	FIU-IND Director	Immediate	Rule 3(1)(D) r/w Rule 8(2), PMLA Rules 2005
Immovable property transaction report	Principal Officer	FIU-IND Director	Within 15 days of quarter-end	Rule 3(1)(F) r/w Rule 8(3), PMLA Rules 2005
Investor KYC filing with CKYCRR	Manager	Central KYC Records Registry	Within 10 days of account-based relationship commencement	Rule 9(1-A), PMLA Rules 2005

AML policy requirement

Every AIF Manager must maintain a documented AML/KYC policy under the PMLA framework. SEBI’s inspection checklist for AIFs includes verification that this policy is current, approved by the Board or Designated Partners of the Manager, and includes customer due diligence procedures, enhanced due diligence thresholds for high-risk investors, record-keeping procedures, and the escalation protocol for flagging suspicious activity to the Principal Officer.

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. Ongoing obligations post-transition are described in the annual obligations section above.
7. Overseas investment limit utilisation: AIFs approved by SEBI to make overseas investments must report utilisation of the approved limit to SEBI through the SI Portal within 5 working days of such utilisation (Para 7.3.1 of the 2024 Master Circular). If the limit is not fully utilised or partially utilised within 4 months from the date of SEBI approval (validity period), the un-utilised portion must be reported within 2 working days after expiry of the validity period (Para 7.3.2(i) and (ii)).
8. Overseas limit voluntary surrender: If the AIF decides to surrender the overseas investment limit at any point within the validity period, the surrender must be reported to SEBI through the SI Portal within 2 working days from the date of the decision to surrender (Para 7.3.2(iii) of the 2024 Master Circular).
9. Sale or divestment of overseas investment: Details of any sale or divestment of an overseas investment must be furnished to SEBI within 3 working days of the divestment (Para 7.3.3 of the 2024 Master Circular). This is a standalone post-divestment obligation and applies regardless of whether the original utilisation report was filed on time.

Cybersecurity and Cyber Resilience Framework (CSCRF) obligations

SEBI’s Circular on Cybersecurity and Cyber Resilience Framework for SEBI Regulated Entities dated 20 August 2024 (SEBI/HO/ITD-1/ITD_CSC_EXT/P/CIR/2024/113) (the CSCRF Circular) introduced a tiered set of cybersecurity compliance obligations applicable to all AIFs. The obligations are calibrated by AUM size, with heavier requirements for funds above certain thresholds. This is a relatively new compliance layer that most AIF compliance checklists predating August 2024 do not capture. SEBI has since conducted thematic inspections of intermediaries specifically against the CSCRF standards.

AUM-based CSCRF applicability

The CSCRF Circular organises AIFs into tiers based on AUM. The table below maps which obligations apply at each tier:

Table: CSCRF obligations by AIF AUM size

CSCRF Obligation	AUM below Rs. 100 crore	AUM Rs. 100 crore to Rs. 500 crore	AUM Rs. 500 crore to Rs. 1,000 crore	AUM above Rs. 1,000 crore	Frequency
Cyber resilience self-assessment (CCI) and evidence submission	No	Yes	Yes	Yes	Annual
Cybersecurity and cyber resilience policy review	Yes	Yes	Yes	Yes	Annual
Cybersecurity risk management policy	Yes	Yes	Yes	Yes	Annual
Threat-based risk assessment	No	No	Yes	Yes	Annual
Cybersecurity training programme	Yes	Yes	Yes	Yes	Annual
Review of third-party systems	Yes	Yes	No	No	Annual
Functional efficacy of SOC	Yes	Yes	No	No	Annual / Half-yearly
Drill exercises for recovery plan testing	Yes	Yes	No	No	Annual / Half-yearly
Contingency and continuity plan review	Yes (AUM between Rs. 10-50 crore)	Yes	No	No	Annual / Half-yearly
Evaluation of cyber resilience posture	Yes (AUM between Rs. 10-50 crore)	Yes	No	No	Annual
User access rights and unused tokens review	No	No	Yes	Yes	Quarterly / Half-yearly
Privileged user activity review	No	No	Yes	Yes	Quarterly / Half-yearly
IT committee meetings	No	No	Yes	Yes	Quarterly
Threat hunting	No	No	Yes	Yes	Quarterly
Red teaming exercises	No	No	Yes	Yes	Half-yearly

Note: AUM thresholds above use the CSCRF Circular’s terminology of INR 1 billion (approximately Rs. 100 crore), INR 5 billion (approximately Rs. 500 crore), and INR 10 billion (approximately Rs. 1,000 crore). Verify the applicable tier against the Circular directly, as SEBI may revise thresholds through standalone notifications.

Annual CSCRF obligations

The following annual obligations apply to all AIFs above the minimum threshold:

• Cyber audit: A formal cyber audit must be conducted and the cyber audit report submitted to SEBI within 1 month of completion of audit activity. For AIFs with AUM above Rs. 1,000 crore, this requirement applies twice in a year. The report must be submitted in the format prescribed as Annexure-B of the CSCRF Circular along with a declaration from the Manager.
• VAPT report: A Vulnerability Assessment and Penetration Testing (VAPT) report must be submitted to SEBI annually under Para 4.3 of Part I of the CSCRF Circular.
• Cyber resilience self-assessment: AIFs with AUM above Rs. 100 crore must submit a self-assessment using the Cyber Capability Index (CCI) prescribed in Annexure-K of the CSCRF Circular, along with supporting evidence.

What does a cyber audit cover for an AIF Manager?

A cyber audit for an AIF Manager typically covers: security of the fund management system and investor portal, access controls for portfolio data, data localisation compliance, endpoint security across team devices, and review of third-party service providers including fund administrators and custodians who have system-level access to AIF data. The auditor must be an empanelled CERT-In certified auditor. The scope is determined by the CSCRF Circular’s prescribed framework, not by the Manager’s preference.

Digital Accessibility compliance

Under SEBI’s Digital Accessibility Circular (SEBI/HO/ITD1/ITD_VIAP/P/CIR/2025/111), all AIFs must conduct annual accessibility audits of their digital platforms with respect to the Rights of Persons with Disabilities Act, 2016 and the rules made thereunder. A compliance report of the accessibility audit must be submitted to SEBI within 30 days from the end of each financial year, that is by 30 April annually. This obligation applies to any digital platform operated by or on behalf of the AIF, including investor portals, fund reporting dashboards, and the Manager’s website if it is used for investor communication.

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.

Direct tax compliance obligations for AIFs

AIF Managers must maintain a parallel direct tax compliance calendar alongside the SEBI filing calendar. Tax obligations for Category I and Category II AIFs are governed by the pass-through tax regime under Section 115UB of the Income Tax Act, 1961, which treats the AIF as a pass-through vehicle for the purpose of income tax. Category III AIFs are taxed at the fund level at applicable rates. The direct tax calendar applies to the AIF entity itself and to the Manager entity separately; the obligations below cover the AIF entity’s tax compliance.

Income tax return

The AIF must file its income tax return by 31 October of the relevant assessment year. For FY 2025-26 (Assessment Year 2026-27), the due date is 31 October 2026. Late filing attracts interest under Section 234A and a late filing fee under Section 234F of the Income Tax Act, 1961.

Advance tax

If the AIF has taxable income (applicable to Category III AIFs and to the extent any income at the AIF level is not eligible for pass-through treatment), advance tax must be paid in four instalments:

• 15 June: 15% of estimated tax liability
• 15 September: 45% of estimated tax liability (cumulative)
• 15 December: 75% of estimated tax liability (cumulative)
• 15 March: 100% of estimated tax liability

Shortfall in advance tax payment attracts interest under Sections 234B and 234C of the Income Tax Act, 1961.

TDS obligations

The Manager or AIF, as applicable, must deduct TDS on payments made to service providers, advisors, employees, and on income distributed to investors where required. TDS obligations include:

• Monthly TDS payment to the government by the 7th of the following month. March TDS is due by 30 April.
• Quarterly TDS returns: 31 July (Q1), 31 October (Q2), 31 January (Q3), 31 May (Q4).
• Form 15CA and Form 15CB for each foreign remittance made by the AIF, filed at the time of remittance.

Pass-through reporting: Form 64D and Form 64C

These two forms apply specifically to Category I and Category II AIFs operating under the Section 115UB pass-through regime:

• Form 64D: Statement of income distributed during the previous year, to be furnished to the Income Tax Department by 15 June of the following year. For FY 2025-26, the due date is 15 June 2026.
• Form 64C: Statement of income distributed during the previous year, to be furnished to each unit holder by 30 June of the following year. For FY 2025-26, the due date is 30 June 2026.

The distinction between these two forms is the recipient: Form 64D goes to the tax department, Form 64C goes to the investor. Both cover the same distribution data but serve different purposes. Form 64C is what investors need to correctly report their pass-through AIF income in their personal income tax returns.

Table: Direct tax compliance deadlines for AIFs (FY 2026-27)

Obligation	Due date	Notes	Applicable to
Advance tax instalment 1 (15%)	15 June 2026	Section 207, Income Tax Act 1961	Category III; Cat I/II where AIF-level income exists
Form 64D (to IT Department)	15 June 2026	Income distributed in FY 2025-26	Category I and II only
Form 64C (to unit holders)	30 June 2026	Income distributed in FY 2025-26	Category I and II only
Advance tax instalment 2 (45% cumulative)	15 September 2026	Section 207	Category III; Cat I/II where applicable
Advance tax instalment 3 (75% cumulative)	15 December 2026	Section 207	Category III; Cat I/II where applicable
Advance tax instalment 4 (100%)	15 March 2027	Section 207	Category III; Cat I/II where applicable
Income tax return (AIF entity)	31 October 2026	Assessment Year 2026-27	I, II, III
TDS returns (quarterly)	31 Jul / 31 Oct 2026 / 31 Jan 2027 / 31 May 2027	Per TDS schedule	I, II, III
TDS payment	7th of following month (March: 30 April)	Monthly	I, II, III
Form 15CA/15CB	At time of each foreign remittance	Section 195, Income Tax Act 1961	I, II, III where applicable

How the pass-through regime affects investor tax obligations

Under Section 115UB, income of a Category I or Category II AIF that is not taxable at the fund level passes through to investors in the same character in which it arose at the fund level. Business income of the AIF that cannot be passed through is taxed at the maximum marginal rate (MMR) at the fund level. The AIF Manager must therefore correctly characterise all income at the fund level before year-end to determine what passes through to investors and what is taxed at the fund.

Category III AIFs are taxed at the fund level. Short-term capital gains from equity-oriented investments are taxed at 20% (post-Finance Act 2024). Long-term capital gains are taxed at 12.5% without the benefit of indexation (post-Finance Act 2024). Other income is taxed at MMR (42.744% including surcharge and cess for income above Rs. 5 crore). The Manager must compute and pay advance tax on this estimated liability each quarter.

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

Mandatory policies every AIF must maintain

Beyond filing obligations, SEBI requires every AIF to maintain a set of governance documents and internal policies. These policies are not filed with SEBI as part of a periodic submission but are reviewed during SEBI inspections, referenced in PPM compliance audits, and required to be disclosed to investors where applicable. A fund operating without documented policies in these areas has a structural compliance gap regardless of whether all periodic filings are current.

Table: Mandatory AIF governance policies

Policy	Applicable to	Key content requirements	SEBI reference
Stewardship Policy	Category I and II	How the fund monitors investee companies; engagement on performance, strategy, corporate governance, ESG risks; voting mechanism; training for investment team personnel	SEBI Circular dated 24 December 2019
Conflict of Interest Policy	All AIFs	Identification and management of conflicts; interest of client/beneficiary over entity interest; handling divergent client interests; escalation mechanism	SEBI (AIF) Regulations 2012 Reg. 21
Voting and Disclosure of Voting Rights Policy	All AIFs	Voting mechanisms; internal voting guidelines; list of specific matters/circumstances; oversight committee; proxy advisor usage; disclosure of voting records	SEBI Circular dated 24 December 2019
Continuous Monitoring Policy for Investee Companies	All AIFs	Monitoring levels per investee; areas and mechanisms for monitoring; situations of non-engagement (e.g. small investments); insider trading considerations	SEBI Circular dated 24 December 2019
Valuation Policy	All AIFs	Valuation guidelines per asset class; frequency; whether IPEV guidelines are followed; disclosure of any deviation	Reg. 23, AIFR 2012; Para 22, 2024 Master Circular
Grievance Redressal Policy	All AIFs	Mechanism for handling investor complaints; timeframes for resolution; escalation to Trustee/Sponsor	Reg. 24A, AIFR 2012
Risk Management Policy	All AIFs	Identification of material risks (concentration, FX, leverage, realisation, strategy, reputation, ESG); mitigation mechanisms per risk type	Reg. 22(g), AIFR 2012
AML/KYC Policy (PMLA)	All AIFs	Customer due diligence; enhanced due diligence for high-risk investors; record-keeping procedures; suspicious transaction escalation; Principal Officer and Designated Director roles	PMLA 2002; PMLA Rules 2005
Client Acceptance Policy	All AIFs	Norms before accepting investors; KYC procedures; contributor agreement requirements; PPM circulation and sign-off; payment receipt procedures	SEBI (AIF) Regulations 2012
Cybersecurity Policy	All AIFs (AUM-dependent depth)	Asset inventory; access controls; incident response; third-party vendor risk; CERT-In empanelled auditor engagement	CSCRF Circular, 20 August 2024

A note on the Stewardship Policy requirement

The Stewardship Policy obligation under SEBI’s December 2019 Circular applies specifically to Category I and Category II AIFs. The policy must spell out how the fund intends to discharge stewardship responsibilities including active engagement with investee companies on performance, strategy, corporate governance, and ESG matters. SEBI expects the policy to include a training component for investment team personnel involved in implementing stewardship principles. Many Category I and II funds set up after 2020 include a boilerplate stewardship policy in their PPM annexures without maintaining it as a living document, which creates an inspection risk.

Category-specific compliance calendars: Category I, II, and III differences

The core SEBI framework applies to all three AIF categories, but the reporting frequency, investor disclosure obligations, and additional SEBI requirements differ materially between categories. Running a Category III fund on a Category I compliance calendar is one of the most common structural mistakes Treelife’s compliance team encounters during onboarding. The section below breaks out each category’s full periodic compliance calendar independently.

Category I AIF compliance calendar

Category I AIFs include Venture Capital Funds, SME Funds, Social Venture Funds, and Infrastructure Funds. They operate with the lightest periodic reporting burden among the three categories.

Table: Category I AIF periodic compliance calendar (FY 2026-27)

Obligation	Deadline	Submitted to	Regulation
Quarterly activity report to SEBI	15 Jul / 15 Oct 2026 / 15 Jan / 15 Apr 2027	SEBI (SI Portal)	Para 15.1.1, 2024 Master Circular
Annual investor report (financial info, material risks)	Within 180 days of FY end (by 30 Sep 2026)	Investors	Reg. 22(g), AIFR 2012
Compliance Test Report (CTR)	By 30 April 2026 (FY25-26)	Trustee and Sponsor	Para 15.2.2, 2024 Master Circular
Trustee/Sponsor observations on CTR	Within 30 days of CTR receipt	Manager	Para 15.2.3
Revised CTR (if observations raised)	Within 15 days of receiving observations	Trustee and Sponsor	Para 15.2.3
PPM compliance audit findings	By 30 September 2026	Trustee, Board/DP of Manager, SEBI	Para 2.4.2, 2024 Master Circular
PPM changes (consolidated)	Within 1 month of FY end (by 30 April annually)	SEBI and Investors	Para 2.5.2, 2024 Master Circular
Valuation methodology change disclosure	Within 1 month of FY end	SEBI and Investors	Reg. 23(1) r/w Para 22.2.3, 2024 Master Circular
Half-yearly valuation disclosure to investors	29 Nov 2026 and 30 May 2027	Investors	Reg. 23(1) and 23(2) (extendable to annual with 75% investor approval)
Performance benchmarking data submission	14 Nov 2026 (H1) and 30 Sep 2027 (H2)	Performance Benchmarking Agency	Para 16.3.3 and 16.4, 2024 Master Circular
Investor complaint data	Within 7 days of quarter-end	Investors	Para 17.4, 2024 Master Circular
KYC data for Aggregate Escrow Demat Account	Within 15 days of month start	Depositories and Custodian	Para 20.12, 2024 Master Circular
Annual cyber audit report	Within 1 month of completion	SEBI	Para 4.4, CSCRF Circular
VAPT report	Annually	SEBI	Para 4.3, CSCRF Circular
Digital accessibility audit compliance	By 30 April annually	SEBI	Digital Accessibility Circular
FLA return	By 15 July 2026	RBI	Rule 4(2), FEMA Regulations 2019
Advance tax (4 instalments)	15 Jun / 15 Sep / 15 Dec 2026 / 15 Mar 2027	Income Tax Department	Section 207, Income Tax Act 1961
Form 64D	15 June 2026	Income Tax Department	Section 115UB, Income Tax Act 1961
Form 64C	30 June 2026	Unit holders	Section 115UB, Income Tax Act 1961
TDS payment	7th of following month (March: 30 April)	Income Tax Department	Income Tax Act 1961
TDS returns	31 Jul / 31 Oct 2026 / 31 Jan 2027 / 31 May 2027	Income Tax Department	Income Tax Act 1961
Income tax return	31 October 2026	Income Tax Department	Section 139, Income Tax Act 1961

Category I funds do not have any obligation to separately report leverage, do not file the ADR quarterly data submission, and do not have a daily reporting obligation to the custodian.

Category I specific note on Angel Funds: Angel Funds registered as a sub-category of Venture Capital Fund under Category I are exempt from the PPM compliance audit requirement (Para 2.4.2 of the 2024 Master Circular). The performance benchmarking data submission requirement under Para 16.3.3 also does not apply to Angel Funds. All other periodic obligations listed above apply.

Category II AIF compliance calendar

Category II AIFs include Private Equity Funds, Debt Funds, Fund of Funds, and Real Estate Funds. The key difference from Category I is that half-yearly investor-facing valuation disclosures are mandatory and cannot be extended to annual frequency.

Table: Category II AIF periodic compliance calendar (FY 2026-27)

Obligation	Deadline	Submitted to	Regulation
Quarterly activity report to SEBI	15 Jul / 15 Oct 2026 / 15 Jan / 15 Apr 2027	SEBI (SI Portal)	Para 15.1.1, 2024 Master Circular
Annual investor report (financial info, material risks)	Within 180 days of FY end (by 30 Sep 2026)	Investors	Reg. 22(g), AIFR 2012
Compliance Test Report (CTR)	By 30 April 2026 (FY25-26)	Trustee and Sponsor	Para 15.2.2, 2024 Master Circular
Trustee/Sponsor observations on CTR	Within 30 days of CTR receipt	Manager	Para 15.2.3
Revised CTR (if observations raised)	Within 15 days of receiving observations	Trustee and Sponsor	Para 15.2.3
PPM compliance audit findings	By 30 September 2026	Trustee, Board/DP of Manager, SEBI	Para 2.4.2, 2024 Master Circular
PPM changes (consolidated)	Within 1 month of FY end (by 30 April annually)	SEBI and Investors	Para 2.5.2, 2024 Master Circular
Valuation methodology change disclosure	Within 1 month of FY end	SEBI and Investors	Reg. 23(1) r/w Para 22.2.3, 2024 Master Circular
Half-yearly valuation disclosure to investors	29 Nov 2026 and 30 May 2027	Investors	Reg. 23(1) and 23(2) (mandatory; cannot be extended to annual)
Performance benchmarking data submission	14 Nov 2026 (H1) and 30 Sep 2027 (H2)	Performance Benchmarking Agency	Para 16.3.3 and 16.4, 2024 Master Circular
Investor complaint data	Within 7 days of quarter-end	Investors	Para 17.4, 2024 Master Circular
KYC data for Aggregate Escrow Demat Account	Monthly	Depositories and Custodian	Para 20.12, 2024 Master Circular
Annual cyber audit report	Within 1 month of completion	SEBI	Para 4.4, CSCRF Circular
VAPT report	Annually	SEBI	Para 4.3, CSCRF Circular
Digital accessibility audit compliance	By 30 April annually	SEBI	Digital Accessibility Circular
Liquidation Scheme compliance (if applicable)	Quarterly	SEBI	Para 23.4.2, 2024 Master Circular
Borrowing disclosure to investors	Periodic (per investor agreement terms)	Investors	Para 4.6, August 19, 2024 Circular
FLA return	By 15 July 2026	RBI	Rule 4(2), FEMA Regulations 2019
Advance tax (4 instalments)	15 Jun / 15 Sep / 15 Dec 2026 / 15 Mar 2027	Income Tax Department	Section 207, Income Tax Act 1961
Form 64D	15 June 2026	Income Tax Department	Section 115UB, Income Tax Act 1961
Form 64C	30 June 2026	Unit holders	Section 115UB, Income Tax Act 1961
TDS payment	7th of following month (March: 30 April)	Income Tax Department	Income Tax Act 1961
TDS returns	31 Jul / 31 Oct 2026 / 31 Jan 2027 / 31 May 2027	Income Tax Department	Income Tax Act 1961
Income tax return	31 October 2026	Income Tax Department	Section 139, Income Tax Act 1961

Category II specific note on borrowing disclosure: The August 19, 2024 Circular on guidelines for borrowing by Category I and II AIFs requires the Manager to disclose details of amount borrowed, terms of borrowing, and repayment to investors on a periodic basis as per the terms of the investor agreement. This is a Category I and II specific obligation triggered when the AIF has borrowed funds as permitted under the Regulations.

Category III AIF compliance calendar

Category III AIFs include Hedge Funds and funds that use complex trading strategies, derivatives, leverage, and listed or unlisted instruments. They carry the heaviest compliance burden of all three categories, with daily, monthly, quarterly, and half-yearly obligations layered on top of the annual cycle.

Table: Category III AIF periodic compliance calendar (FY 2026-27)

Obligation	Deadline	Submitted to	Regulation
Quarterly activity report to SEBI	15 Jul / 15 Oct 2026 / 15 Jan / 15 Apr 2027	SEBI (SI Portal)	Para 15.1.1, 2024 Master Circular
Quarterly leverage report	15 Jul / 15 Oct 2026 / 15 Jan / 15 Apr 2027	SEBI (SI Portal)	Para 15.1.1, 2024 Master Circular
ADR quarterly data filing	7 Jul / 7 Oct 2026 / 7 Jan / 7 Apr 2027	ADR platform	2024 ADR requirement
Quarterly investor report (financial info, material risks)	Within 60 days of quarter-end	Investors	Reg. 22(g) and 22(h), AIFR 2012
Quarterly NAV disclosure (close-ended fund)	Quarterly	Investors	Reg. 23(3), AIFR 2012
Monthly NAV disclosure (open-ended fund)	Monthly (at intervals not exceeding 1 month)	Investors	Reg. 23(3), AIFR 2012
Daily leverage amount report	By end of next working day	Custodian	Para 5.2.13, 2024 Master Circular
CDS transaction reporting	By next working day	Custodian	Para 9.3.1, 2024 Master Circular
Leverage breach report (to custodian, end of day)	End of day on breach day	Custodian	Para 5.2.14, 2024 Master Circular
Leverage breach report (to investors)	Before 10 a.m. next working day	Investors	Para 5.2.14(a), 2024 Master Circular
Confirmation of squaring off excess leverage	End of day	Investors and Custodian	Para 5.2.14, 2024 Master Circular
Passive breach of concentration norm rectification	Within 30 days of breach	Internal action	Para 5.1.3, 2024 Master Circular
Open-ended scheme corpus breach notification (below Rs. 20 crore)	Within 2 working days of redemption request	SEBI	Para 5.5.1, 2024 Master Circular
Suspension of redemptions communication	Within a reasonable period	SEBI and Investors	Paras 5.4.7 and 5.4.9, 2024 Master Circular
Compliance Test Report (CTR)	By 30 April 2026 (FY25-26)	Trustee and Sponsor	Para 15.2.2, 2024 Master Circular
PPM compliance audit findings	By 30 September 2026	Trustee, Board/DP of Manager, SEBI	Para 2.4.2, 2024 Master Circular
PPM changes (consolidated)	Within 1 month of FY end	SEBI and Investors	Para 2.5.2, 2024 Master Circular
Valuation methodology change disclosure	Within 1 month of FY end	SEBI and Investors	Reg. 23(1) r/w Para 22.2.3, 2024 Master Circular
Half-yearly portfolio report to SEBI	14 Nov 2026 (H1); 30 Sep 2027 (H2)	SEBI (SI Portal)	2024 Master Circular
Performance benchmarking data submission	14 Nov 2026 (H1); 30 Sep 2027 (H2)	Performance Benchmarking Agency	Para 16.3.3 and 16.4, 2024 Master Circular
CSCRF half-yearly standards compliance	14 Nov 2026 and 30 Sep 2027	SEBI	CSCRF Circular, 20 August 2024
KYC data for Aggregate Escrow Demat Account	Monthly	Depositories and Custodian	Para 20.12, 2024 Master Circular
Investor complaint data	Within 7 days of quarter-end	Investors	Para 17.4, 2024 Master Circular
Annual cyber audit report	Within 1 month of completion	SEBI	Para 4.4, CSCRF Circular
VAPT report	Annually	SEBI	Para 4.3, CSCRF Circular
Digital accessibility audit compliance	By 30 April annually	SEBI	Digital Accessibility Circular
FLA return	By 15 July 2026	RBI	Rule 4(2), FEMA Regulations 2019
Advance tax (4 instalments)	15 Jun / 15 Sep / 15 Dec 2026 / 15 Mar 2027	Income Tax Department	Section 207, Income Tax Act 1961
TDS payment	7th of following month (March: 30 April)	Income Tax Department	Income Tax Act 1961
TDS returns	31 Jul / 31 Oct 2026 / 31 Jan 2027 / 31 May 2027	Income Tax Department	Income Tax Act 1961
Income tax return	31 October 2026	Income Tax Department	Section 139, Income Tax Act 1961

Category III specific obligations explained

Three obligations in the Category III calendar deserve specific attention because they have no equivalent in the Category I or II framework:

First, the daily leverage amount report. Category III AIFs must report the amount of leverage at the end of each trading day to the Custodian by the end of the next working day (Para 5.2.13 of the 2024 Master Circular). This is a daily operational obligation. The Custodian maintains these reports and they form the basis for any leverage breach assessment.

Second, the leverage breach escalation protocol. If the AIF’s leverage at any point during the day exceeds the prescribed limit, the Manager must report the breach to the Custodian by end of day and to Investors before 10 a.m. on the next working day (Para 5.2.14(a)). The Custodian then reports to SEBI by 10 a.m. on the next working day. The excess position must be squared off and confirmed to both investors and the Custodian by end of the same day.

Third, the open-ended scheme corpus threshold notification. If the corpus of an open-ended Category III scheme falls below Rs. 20 crore following a redemption request, the Manager must notify SEBI within 2 working days of receiving that redemption request (Para 5.5.1 of the 2024 Master Circular). This is a real-time monitoring obligation built into the fund’s redemption processing workflow.

Credit Default Swap (CDS) reporting for Category II and III AIFs

AIFs that sell credit default swaps by earmarking unencumbered Government Bonds or Treasury Bills equal to the amount of CDS exposure carry specific CDS-related reporting obligations:

• Any unhedged CDS position resulting in gross unhedged positions exceeding 25% of investable funds must be reported to unitholders as and when it occurs (Para 9.3.5).
• All CDS transaction details must be reported to the Custodian by the next working day (Para 9.3.1 of the 2024 Master Circular).
• If earmarked securities fall below CDS exposure (a breach), the breach must be reported on the same day, rectification details by end of next trading day, and failure to rectify reported to SEBI by next working day (Para 9.3.4).

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.
• Managing FEMA filings including Form InVI, Form DI, DPIIT intimations, and annual FLA return with the RBI.
• Maintaining the PMLA compliance framework including FIU-IND filings, Principal Officer designation, and CKYCRR onboarding filings.
• Direct tax compliance support including Form 64C and 64D for Category I and II funds, advance tax planning for Category III, and TDS management.

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.

Mistake 6: Ignoring FEMA obligations when a foreign investor joins mid-fund

A fund that was 100% domestic at launch does not have FEMA obligations. The moment one foreign LP joins, Form InVI must be filed within 30 days of unit issuance and the FLA return obligation activates for all subsequent years. Many compliance teams operating domestic funds do not have the FEMA filing workflow built and are caught unprepared.

Correct approach: Build the FEMA workflow (Form InVI through FIRMS portal, DPIIT intimation template, FLA return calendar reminder) at fund setup regardless of whether foreign LPs are present at First Close. The cost of building it is far lower than the compounding cost under FEMA.

Mistake 7: Operating without a documented AML policy

SEBI inspections of AIFs now include verification that the Manager has a current, Board-approved AML/KYC policy under PMLA. Funds that treat AML as a one-time onboarding formality rather than an ongoing operational framework are exposed at inspection.

Correct approach: Review and update the AML/KYC policy at least annually. The policy must reflect current customer due diligence procedures, enhanced due diligence thresholds, and the current Principal Officer and Designated Director designations.

Frequently Asked Questions

Q: From what date do SEBI compliance obligations begin for an AIF?

A: Compliance obligations begin from the date of SEBI registration of the AIF, not from First Close. The first quarterly activity report is due within 15 calendar days from the end of the calendar quarter in which registration occurred.

Q: What are the quarterly filing deadlines for FY 2026-27?

A: Under para 15.1.1 of the 2024 Master Circular, the four deadlines for FY 2026-27 are 15 July 2026 (Q1), 15 October 2026 (Q2), 15 January 2027 (Q3), and 15 April 2027 (Q4).

Q: Is a Category III AIF required to file more frequently than Category I or II?

A: Yes. Category III AIFs must file a quarterly leverage report and AIF Data Repository (ADR) submissions in addition to the standard quarterly activity report and half-yearly reports applicable to all categories. The ADR deadline is 7 days from quarter-end, which is tighter than the standard 15-day deadline. Category III also carries daily leverage reporting to the custodian and quarterly investor reports (versus annual for Category I and II).

Q: What is the Compliance Test Report (CTR) and who prepares it?

A: The CTR is an annual self-assessment prepared by the Manager of the AIF confirming compliance with the AIFR 2012 and all applicable SEBI circulars. It is due within 30 days of financial year-end (by 30 April) and must be submitted to the Trustee and Sponsor for a trust-form AIF. As of FY 2026-27, the CTR must also include confirmation of NISM certification compliance for the Compliance Officer.

Q: When must the Compliance Officer of an AIF Manager obtain NISM certification?

A: Under SEBI Circular HO/19/(8)2025-AFD-POD1/I/1266/2025 dated 30 December 2025, Compliance Officers of AIF Managers must obtain NISM Series-III-C certification before 1 January 2027. From that date, only certified persons can be appointed or continue to act as Compliance Officers.

Q: What is the PPM compliance audit and how often must it be conducted?

A: The PPM compliance audit verifies that the fund’s actual operations are consistent with the terms of the Private Placement Memorandum filed with SEBI. It must be completed within six months of the financial year-end – by 30 September each year – and can be conducted by an internal or external auditor or legal professional.

Q: Are AIF units required to be held in dematerialised form?

A: Yes. Units issued from November 2023 onwards must be in dematerialised form. Portfolio investments held by the AIF must be in dematerialised form from October 2024 onwards, subject to exemptions for pre-October 2024 investments under conditions specified in the 2024 Master Circular.

Q: What triggers a SEBI filing for a PPM amendment?

A: Material changes to the PPM require SEBI intimation through a Merchant Banker. Non-material changes can be notified directly to SEBI. The distinction between material and non-material changes is based on SEBI’s Master Circular guidance. Fund managers should document their internal threshold and apply it consistently to avoid either over- or under-filing.

Q: What FEMA filings does an AIF need to make when it accepts a foreign investor?

A: The Manager must file Form InVI with the RBI through the FIRMS portal within 30 days of issuing units to any person resident outside India, under Rule 4(10) of the FEMA Regulations 2019. The AIF must also file an FLA return with the RBI annually by 15 July, covering all foreign investments received and made in the previous financial year. If the AIF makes downstream investments where the Manager is not Indian owned and controlled, Form DI must also be filed with RBI within 30 days of equity allotment.

Q: What is the difference between the Compliance Test Report under SEBI and the Cash Transaction Report under PMLA?

A: Both are abbreviated as “CTR” but are entirely separate documents filed with different regulators. The Compliance Test Report under Para 15.2 of the 2024 Master Circular is an annual SEBI filing prepared by the Manager and submitted to the Trustee and Sponsor by 30 April. The Cash Transaction Report under Rule 3(1)(E) of the PMLA Rules 2005 is a monthly AML filing prepared by the Principal Officer and submitted to FIU-IND within 15 days of the succeeding month.

Q: What cybersecurity compliance obligations does an AIF have under SEBI’s CSCRF Circular?

A: SEBI’s August 2024 CSCRF Circular requires all AIFs to comply with cybersecurity standards tiered by AUM. At a minimum, every AIF must maintain a cybersecurity policy, submit a VAPT report annually, and conduct a cyber audit with the report submitted to SEBI within one month of completion. AIFs with AUM above Rs. 100 crore must additionally submit a cyber resilience self-assessment using the Cyber Capability Index (CCI). AIFs with AUM above Rs. 500 crore carry additional quarterly obligations including IT committee meetings, and AIFs with AUM above Rs. 1,000 crore must conduct cyber audits twice yearly.

Q: Is the digital accessibility compliance applicable to all AIFs?

A: Yes. Under SEBI’s Digital Accessibility Circular, all SEBI-regulated entities including AIFs must conduct annual accessibility audits of their digital platforms in compliance with the Rights of Persons with Disabilities Act, 2016 and submit a compliance report to SEBI within 30 days from the end of each financial year, that is by 30 April.

Q: What are Form 64C and Form 64D and when must they be filed?

A: Form 64C and Form 64D are pass-through income reporting forms applicable to Category I and Category II AIFs under Section 115UB of the Income Tax Act, 1961. Form 64D is a statement of income distributed during the previous financial year, filed with the Income Tax Department by 15 June of the following year. Form 64C is the same statement given to each unit holder by 30 June of the following year. Investors use Form 64C to correctly report their share of AIF income in their personal income tax returns. Category III AIFs are not required to file these forms as they are taxed at the fund level.

Q: Does a Category I AIF need to disclose borrowings to investors?

A: Yes. The August 19, 2024 Circular on borrowing by Category I and II AIFs requires the Manager to disclose details of amount borrowed, terms of borrowing, and repayment to investors on a periodic basis as per the terms of the investor agreement. This applies when the AIF has borrowed funds as permitted under the Regulations.

Q: What is the AIF Liquidation Scheme and what compliance obligations does it create?

A: A Liquidation Scheme is a mechanism under Chapter 23 of the 2024 Master Circular that allows an AIF which has not fully liquidated its portfolio by end of tenure (including extended tenure) to deal with residual unliquidated investments. It requires consent of at least 75% of investors by value. Once activated, the Manager must report compliance with Chapter 23 provisions to SEBI quarterly, report the Liquidation Scheme’s performance to the Performance Benchmarking Agency half-yearly (within 45 days from the September half-year and within 6 months from the March half-year), and disclose the arrangement in the PPMs of subsequent schemes.

Q: How is the quarterly investor report for a Category III AIF different from the annual investor report for Category I and II?

A: Category I and II AIFs must provide investors with a comprehensive annual report within 180 days from the financial year-end, covering financial information of investee companies and material risks. Category III AIFs must provide a similar report quarterly, within 60 days of the end of each quarter. The content framework is similar (financial information and material risks including concentration, FX, leverage, realisation, strategy, reputation, and ESG risks) but the Category III frequency is four times higher.

Regulatory references

• SEBI (Alternative Investment Funds) Regulations, 2012, Regulations 12(4), 15, 20(4), 20(14), 20(19), 21(1), 22(a) to 22(j), 23(1), 23(2), 23(3), 24A(1), 29(5)
• SEBI Master Circular No. SEBI/HO/AFD-1/AFD-1-PoD/P/CIR/2024/3 dated 7 May 2024, Paras 2.3.1, 2.4.2, 2.4.3, 2.5.2, 5.1.3, 5.2.13, 5.2.14, 5.4.7, 5.4.9, 5.5.1, 7.3.1, 7.3.2, 7.3.3, 9.3.1, 9.3.4, 9.3.5, 13.1.3, 15.1.1, 15.2.2, 15.2.3, 15.2.4, 16.3.3, 16.4, 17.4, 19.1.1, 19.1.4, 20.12, 22.2.3, 23.1.14, 23.4.2, 23.4.3, 24.1.2
• SEBI Circular SEBI/HO/AFD/AFD-POD-1/P/CIR/2024/112 dated 19 August 2024 (borrowing by Category I and II AIFs)
• SEBI Circular SEBI/HO/ITD-1/ITD_CSC_EXT/P/CIR/2024/113 dated 20 August 2024 (Cybersecurity and Cyber Resilience Framework)
• SEBI Circular SEBI/HO/AFD/AFDPOD-1/P/CIR/2024/135 dated 8 October 2024 (specific due diligence of investors and investments)
• SEBI Digital Accessibility Circular SEBI/HO/ITD1/ITD_VIAP/P/CIR/2025/111
• SEBI Circular HO/19/(8)2025-AFD-POD1/I/1266/2025 dated 30 December 2025 (NISM certification for Compliance Officers)
• SEBI Stewardship Code Circular dated 24 December 2019
• Foreign Exchange Management Act, 1999
• Foreign Exchange Management (Mode of Payment and Reporting of Non-Debt Instruments) Regulations, 2019, Rules 4(2), 4(10), 4(11)(a), 4(11)(b)
• Prevention of Money Laundering Act, 2002
• Prevention of Money-Laundering (Maintenance of Records) Rules, 2005, Rules 3(1)(D), 3(1)(E), 3(1)(F), 7(1), 8(1), 8(2), 8(3), 9(1-A)
• Income Tax Act, 1961, Sections 115UB, 139, 195, 207, 234A, 234B, 234C, 234F
• Rights of Persons with Disabilities Act, 2016

External sources

• sebi.gov.in (SEBI AIF Master Circular and standalone circulars)
• rbi.org.in (FIRMS portal for FEMA filings; FLAIR portal for FLA return)
• incometaxindia.gov.in (TDS return schedules; Form 64C and 64D formats)
• dpiit.gov.in (downstream investment intimation)
• fiuindia.gov.in (FIU-IND reporting)
• nism.ac.in (NISM Series-III-C and Series-XIX-C examination details)