IFSCA Regulatory Newsletter – April 2025 to November 2025

Introduction

The International Financial Services Centres Authority (IFSCA) has demonstrated exceptional regulatory dynamism during the April-October 2025 period, introducing transformative frameworks that position GIFT IFSC as a globally competitive financial hub. This comprehensive newsletter provides detailed explanations of all regulatory developments, circulars, and notifications issued by IFSCA during this crucial period, ensuring readers understand not just what changed, but how these changes impact operations and compliance requirements.

Chronological Summary with Detailed Explanations

April 3, 2025 – Direction for All Regulated Entities

IFSCA issued comprehensive operational directions to all regulated entities operating in IFSC. These directions established uniform compliance standards across banking units, capital market intermediaries, insurance entities, and fund management companies. The directions covered areas including reporting requirements, governance standards, and operational protocols to ensure consistent regulatory oversight across the ecosystem.

April 4, 2025 – Enhanced Corporate Governance Framework for Finance Companies

This framework introduced stringent corporate governance requirements for Finance Companies and Finance Units. Key provisions include:

• Board Composition: Mandatory appointment of independent directors comprising at least one-third of board strength
• Committee Formation: Compulsory establishment of Audit Committee, Nomination & Remuneration Committee, and Risk Committee
• CEO/CFO Certification: Annual certification of financial statements by Chief Executive and Chief Financial Officers
• Disclosure Requirements: Enhanced transparency in related party transactions and risk management practices

April 4, 2025 – Global/Regional Corporate Treasury Centres Framework

A comprehensive framework was established allowing Finance Companies and Finance Units to undertake Global/Regional Corporate Treasury Centre activities. This framework enables:

• Multi-currency Operations: Ability to handle treasury operations in multiple foreign currencies
• Cross-border Cash Management: Centralized cash management for multinational corporate groups
• Risk Management Services: Provision of hedging and risk management solutions to group companies
• Investment Activities: Authority to invest surplus funds in permissible instruments globally

April 7, 2025 – Ship Leasing Framework Amendments

Significant amendments were introduced to enhance the operational flexibility of ship leasing entities:

• Currency Flexibility: Lessors can now raise invoices and receive payments in any foreign currency permitted under IFSCA Banking Regulations, 2020
• SNRR Account Opening: Permission to open Special Non-Resident Rupee (SNRR) accounts with authorized dealers outside IFSC for enhanced operational efficiency
• Documentation Simplification: Streamlined documentation requirements for lease agreements

April 8, 2025 – Fund Management Regulations Transition Guidelines

IFSCA issued crucial transition guidelines for the new Fund Management Regulations, 2025, which introduced several business-friendly changes:

Key Modifications for Non-Retail Schemes:

• Reduced Minimum Corpus: Lowered from USD 5 million to USD 3 million for Venture Capital and Restricted Schemes
• Extended PPM Validity: Private Placement Memorandum validity increased from 6 to 12 months, providing more time for fund raising
• FME Investment Flexibility: Fund Management Entities can now invest up to 100% in their own schemes (previously limited to 10%), subject to conditions
• Open-ended Scheme Benefits: Open-ended schemes can commence investment activities with just USD 1 million, with 12 months to achieve minimum corpus

April 17, 2025 – Capital Market Intermediaries Regulations, 2025

This landmark regulation introduced comprehensive changes to the capital market ecosystem:

New Intermediary Categories:

• Research Entity: New category for entities providing equity research and advisory services
• ESG Ratings and Data Products Providers (ERDPP): Formal regulation of ESG rating agencies previously governed by circulars
• Account Aggregator Removal: This category was eliminated from the regulatory framework

Enhanced Qualification Requirements:

• Principal Officer Standards: Minimum qualifications and experience requirements for key personnel
• Compliance Officer Norms: Dedicated compliance officers for each registration category
• Net Worth Requirements: Differentiated minimum net worth based on activity type

May 21, 2025 – Co-investment Framework

IFSCA introduced a framework facilitating co-investment by Venture Capital Schemes and Restricted Schemes. This framework allows:

• Joint Investment Opportunities: Multiple schemes can participate in single investment opportunities
• Risk Sharing: Enhanced risk distribution across participating schemes
• Due Diligence Sharing: Streamlined due diligence processes for co-invested deals
• Exit Coordination: Coordinated exit strategies for co-investing schemes

May 22, 2025 – International Payment Systems Participation

The Authority enabled IFSC Banking Units to participate in international payment systems, significantly expanding:

• Cross-border Payment Capabilities: Direct participation in global payment networks
• Settlement Efficiency: Reduced settlement times for international transactions
• Cost Optimization: Lower transaction costs through direct participation
• Currency Coverage: Enhanced support for multiple foreign currencies

May 24, 2025 – Custodian Appointment Extension

Timeline extensions were provided for custodian appointments under the Fund Management Regulations, 2025:

• Compliance Timeline: Extended deadline from 6 to 12 months for existing FMEs
• Exemption Criteria: Fund of Funds exempted if underlying funds already have custodians
• Operational Continuity: Ensuring uninterrupted fund operations during transition

May 30, 2025 – Global Access Framework Consultation

IFSCA released a revised consultation paper on the Global Access regulatory framework with key proposals:

• Broadened Provider Definition: Expanded definition to include various types of market access facilitators
• Differentiated Net Worth: Tiered capital requirements based on activity scope
• Client Fund Protection: Mandatory routing of investor funds through IFSC bank accounts
• Risk Management Standards: Enhanced risk management and internal control requirements

June 5, 2025 – AML Guidelines Modifications

Comprehensive modifications were introduced to the Anti Money Laundering, Counter-Terrorist Financing and Know Your Customer Guidelines, 2022:

• Enhanced Due Diligence: Strengthened customer identification and verification processes
• Transaction Monitoring: Improved systems for detecting suspicious transactions
• Reporting Requirements: Updated suspicious transaction reporting formats and timelines
• Record Keeping: Enhanced documentation and record retention requirements

June 6, 2025 – Payment Service Providers Framework

IFSCA enabled Payment Service Providers to participate in international payment systems:

• Service Expansion: PSPs can now offer cross-border payment services
• Technology Integration: Integration with global payment networks and platforms
• Regulatory Compliance: Adherence to international payment standards and protocols
• Customer Protection: Enhanced customer protection measures for cross-border transactions

June 13, 2025 – KYC Registration Agencies Fee Structure

A detailed fee structure was established for KYC Registration Agencies:

• Application Fees: Standardized fees for initial registration applications
• Annual Charges: Recurring fees for maintaining registration status
• Transaction-based Fees: Charges based on volume of KYC services provided
• Penalty Framework: Fee structures for non-compliance and violations

July 1, 2025 – Finance Company Guidance Framework

IFSCA issued comprehensive procedural guidance for Finance Companies and Finance Units:

• Approval Processes: Standardized procedures for seeking regulatory approvals
• Documentation Requirements: Clear specifications for submission formats and supporting documents
• Timeline Clarity: Defined processing timelines for different types of applications
• Intimation Procedures: Streamlined processes for regulatory notifications

July 10, 2025 – Video-Based KYC Consultation

A consultation paper proposing modifications to Video-based Customer Identification Process:

• Process Enhancement: Improved video KYC procedures for Indian nationals
• Technology Standards: Specifications for video quality, recording, and storage
• Security Protocols: Enhanced security measures for remote customer identification
• Compliance Requirements: Updated compliance obligations for entities conducting video KYC

July 11, 2025 – Master Circulars Consultation

IFSCA initiated consultation on Master Circulars for Capital Market Intermediaries:

• Consolidated Guidance: Single-source reference for all applicable regulations
• Operational Clarity: Simplified compliance procedures for intermediaries
• Regular Updates: Framework for periodic updates to maintain currency
• Stakeholder Input: Mechanism for incorporating industry feedback

July 24, 2025 – Regulations Making Procedure

The Authority established a transparent rule-making framework:

• Public Consultation Mandate: Minimum 30-day public consultation period for all new regulations
• Stakeholder Engagement: Structured processes for industry input and feedback
• Impact Assessment: Requirement for regulatory impact analysis before implementation
• Publication Standards: Standardized formats for regulatory publications

July 25, 2025 – TechFin and Ancillary Services Regulations

A comprehensive regulatory framework for technology and support service providers:

Registration Requirements:

• Entity Eligibility: Companies, LLPs, foreign branches, and partnership firms can apply for registration
• FATF Compliance: Entities must not be from high-risk jurisdictions identified by FATF
• 12-Month Transition: Existing providers have 12 months to comply with new registration requirements

Governance Standards:

• Principal Officer: Full-time IFSC-based principal officer appointment mandatory
• Compliance Officer: Dedicated compliance officer for regulatory adherence
• Fit and Proper Criteria: All key personnel must meet prescribed standards
• Code of Conduct: Comprehensive behavioral and operational guidelines

Operational Framework:

• Currency Requirements: Financial reporting in USD or designated foreign currencies
• Service Scope: Covers AI, blockchain, cybersecurity, IoT, and various ancillary services
• SWIT Platform: Registration through Single Window IT System for streamlined processing

July 29, 2025 – Transition Bonds Framework

IFSCA introduced a groundbreaking framework for ESG-labelled Transition Bonds:

Core Requirements:

• Entity-Level Transition Plan: Comprehensive decarbonization strategy aligned with Paris Agreement goals
• Taxonomy Alignment: Proceeds must align with recognized taxonomies (EU Taxonomy, Climate Bonds Taxonomy, IEA Roadmaps)
• Quantified Targets: Measurable GHG emission reduction targets covering Scope 1 and 2 emissions
• Governance Framework: Strong climate governance with board oversight

Independent Review Mechanism:

• External Validation: Mandatory appointment of independent external reviewers
• Review Types: Second Party Opinion, Verification, or Certification processes
• Eligible Reviewers: Registered credit rating agencies and ESG rating providers
• Ongoing Monitoring: Continuous assessment of transition plan implementation

Disclosure Requirements:

• Initial Disclosures: Comprehensive information at issuance including use of proceeds and transition plans
• Annual Reporting: Regular updates on progress toward decarbonization goals
• Impact Reporting: Quantitative reporting on environmental and social impacts
• Transparency Standards: Public disclosure of transition progress and challenges

July 31, 2025 – TechFin Transition Guidelines

Detailed guidelines for entities transitioning to new TechFin regulations:

• Migration Timeline: Clear timelines for transitioning from previous frameworks
• Fee Structure: Transparent fee schedules for registration and compliance
• Grandfathering Provisions: Protection for existing arrangements during transition
• Support Mechanisms: Regulatory guidance and support during migration process

August 5, 2025 – Master Circulars for Capital Market Intermediaries

IFSCA issued seven comprehensive Master Circulars providing consolidated guidance:

• Credit Rating Agencies: Comprehensive framework covering rating methodologies, independence requirements, and disclosure obligations
• Debenture Trustees: Guidelines for trustee responsibilities, conflict management, and investor protection measures
• Distributors: Regulatory framework for distribution activities, sales practices, and customer protection
• ESG Ratings and Data Products Providers: Standards for ESG rating methodologies, data quality, and transparency requirements
• Investment Advisers: Advisory service standards, client relationship management, and fiduciary responsibilities
• Investment Bankers: Underwriting standards, due diligence requirements, and market making obligations
• Research Entities: Research quality standards, independence requirements, and disclosure obligations

August 12, 2025 – Global Access Framework Notification

The regulatory framework for Global Access in IFSC was formally notified with detailed provisions:

Provider Categories:

• Global Access Providers (GAPs): Direct interface with foreign brokers for market access
• Introducing Brokers: IFSC broker dealers acting as intermediaries referring clients to GAPs
• Introducers: Any entity referring clients to GAPs for fee or compensation

Net Worth Requirements:

• GAP (Exchange Subsidiary): USD 500,000 minimum net worth
• GAP (Client Trading): USD 500,000 for entities handling client transactions
• GAP (Proprietary Trading): USD 200,000 for proprietary-only operations
• Introducing Brokers: USD 100,000 minimum requirement

Operational Standards:

• Client Fund Protection: Mandatory routing through IFSC bank accounts or authorized PSPs
• Risk Management: Adequate infrastructure and risk controls commensurate with operations
• Foreign Broker Agreements: Formal agreements with compliant foreign trading members
• Disclosure Requirements: Clear disclosure of investor protection limitations

August 13, 2025 – Opening of Accounts by Indian Residents

Corrigendum issued to correct reference dates in the circular concerning foreign currency account opening by Indian residents with International Banking Units in IFSC, ensuring clarity on applicable timelines and procedures.

September 3, 2025 – SWIT Portal for TechFin

IFSCA operationalized the Single Window IT System for TechFin and Ancillary Services entities:

• Digital Onboarding: Streamlined online registration and application processes
• Document Management: Centralized document submission and tracking system
• Status Tracking: Real-time application status updates for applicants
• Integration Benefits: Seamless integration with existing IFSCA systems

September 4, 2025 – Capital Market Intermediaries Compliance Extensions

Two significant deadline extensions were granted recognizing implementation challenges:

• Principal and Compliance Officer Norms: Extended compliance deadline to December 31, 2025, allowing entities adequate time to identify and appoint qualified personnel meeting revised standards
• Net Worth Compliance: Similar extension for meeting enhanced net worth requirements, ensuring operational continuity during transition

September 8, 2025 – Third-Party Fund Management Fee Structure

Detailed fee structures were specified for Fund Management Entities offering third-party services:

• Application Fee: USD 2,500 for initial application processing
• Authorization Fee: USD 7,500 upon grant of authorization
• Additional Net Worth: USD 500,000 additional capital requirement for third-party services
• Ongoing Charges: Annual fees based on assets under management

September 11, 2025 – Bullion Exchange Market Access

Market access frameworks were extended to Bullion Exchanges and Trading Members:

• Investor Access: Clear pathways for investor participation through Authorized Persons
• Cross-border Access: Access available through entities in India or foreign jurisdictions
• Risk Management: Enhanced risk management standards for bullion trading
• Settlement Mechanisms: Streamlined settlement processes for bullion transactions

September 12, 2025 – Global Access Framework Amendments

Critical amendments enhanced operational flexibility:

• Payment Options: GAPs and Introducing Brokers can maintain client accounts with IFSC Banking Units or authorized Payment Service Providers
• Operational Efficiency: Greater flexibility in payment processing and fund management
• Cost Optimization: Competitive options for payment service providers
• Regulatory Clarity: Clear guidelines on fund segregation and account management requirements

September 18, 2025 – Convertible Debt Securities Clarification

IFSCA clarified listing requirements for convertible debt securities:

• Listing Framework: Convertible debt securities may be listed under debt security norms until conversion
• Conversion Process: Clear procedures for handling conversion from debt to equity
• Disclosure Requirements: Enhanced disclosure standards for conversion features
• Investor Protection: Specific protections for holders of convertible securities

September 18, 2025 – Payments Regulatory Board Regulations

Comprehensive regulations established the Payments Regulatory Board:

• Board Composition: Clear membership structure including IFSCA representation and industry experts
• Governance Framework: Standards for board conduct, decision-making, and accountability
• Regulatory Oversight: Framework for overseeing payment systems under PSS Act, 2007
• Stakeholder Engagement: Mechanisms for industry consultation and feedback

October 3, 2025 – Foreign Currency Settlement System

A major milestone with the notification of comprehensive FCSS framework:

System Architecture:

• CCIL IFSC Operation: CCIL IFSC Limited authorized to operate the settlement system under PSS Act, 2007
• Multi-currency Support: Initial USD support with scope for additional foreign currencies
• Real-time Settlement: Immediate settlement of foreign currency transactions between IBUs
• Local Settlement: Reduced dependence on correspondent banking relationships

Risk Management Framework:

• Default Management: Robust procedures for handling participant defaults
• Netting Arrangements: Efficient netting mechanisms to reduce settlement volumes
• Liquidity Safeguards: Adequate liquidity provisions for smooth operations
• Collateral Management: Comprehensive collateral frameworks for risk mitigation

Operational Benefits:

• Cost Efficiency: Reduced transaction costs compared to traditional correspondent banking
• Speed Enhancement: Faster settlement times for cross-border transactions
• Regulatory Certainty: Clear legal framework under Indian jurisdiction
• Market Development: Enhanced attractiveness of GIFT IFSC for international banks

October 7, 2025 – Video-Based KYC for NRIs

IFSCA Chairman announced imminent guidelines for video-based KYC for Non-Resident Indians:

• Digital Onboarding: Complete elimination of paper-based account opening requirements
• Global Accessibility: NRIs can open accounts from any global location through video KYC
• Technology Standards: Specifications for video quality, security, and recording requirements
• November Launch: Guidelines to be issued by November 2025 for implementation

October 19, 2025 – FinTech Sandbox Framework

Consultation paper released for comprehensive FinTech Sandbox Framework:

• Multi-sector Coverage: Dedicated approaches for banking, capital markets, insurance, and related technologies
• Innovation Testing: Safe environment for testing innovative financial solutions
• Regulatory Relaxations: Specific regulatory relaxations for sandbox participants
• Graduation Pathways: Clear pathways from sandbox to full regulatory authorization

October 22, 2025 – Consultation Paper on Differential Distribution Framework for Blended Finance

IFSCA released a comprehensive consultation paper proposing a framework to facilitate blended finance and other fund structures in IFSC by permitting differential distribution in Venture Capital Schemes and Restricted Schemes:

Blended Finance Context:

• Concept: Strategic deployment of concessional or philanthropic capital to mobilize private capital towards sustainable development projects
• Global Momentum: USD 262 billion mobilized globally through blended finance; growth from USD 11.5 billion to USD 18.3 billion annually (2020-2024)
• Leverage Ratio: Each dollar of concessional capital mobilizes USD 3.76 in commercial capital; larger transactions attract USD 5.46 per dollar
• Indian Need: India requires USD 10.1 trillion financing for net zero by 2070

Proposed Framework:

• Eligible Schemes: Venture Capital and Restricted Schemes permitted to issue multiple classes of units with differential distribution rights (Senior units, Junior/Subordinate units, Mezzanine units)
• ESG Schemes: Permitted to accept up to 20% of corpus as grants from donors/DFIs
• Minimum Investment: USD 2 million for junior/subordinate classes; USD 1 million for accredited investors
• Investment Restrictions: Maximum 25% of corpus in single investee company; prohibition on using funds to discharge obligations to investors or associates

Risk Mitigation Safeguards:

• Ever-greening Prevention: Mandatory restriction preventing investee companies from using scheme investments to repay obligations to scheme investors or associates
• Valuation: Independent valuer mandated to compute NAV for each class of units
• Disclosure Requirements: Detailed PPM disclosures with examples in tabular format; enhanced risk disclosures for junior/subordinate class investors

October 27, 2025 – Consultation Paper on Dematerialisation of Securities by IFSC Entities

IFSCA issued a consultation paper proposing mandatory dematerialization of securities through IFSC depositories rather than domestic depositories:

Core Mandate:

• ISIN Requirement: All IFSC entities must obtain International Securities Identification Numbers (ISINs) from IFSCA-registered depositories instead of domestic depositories
• Rationale: Securities issued by IFSC entities are treated as foreign securities under FEMA; regulatory coherence requires alignment with IFSC depository infrastructure
• ICSD Exception: Issuers may continue using International Central Securities Depositories for issuance and listing as permitted under IFSCA (Listing) Regulations, 2024

Transition Timeline:

• Migration Deadline: Existing IFSC entities with securities dematerialized through domestic depositories must migrate by March 31, 2026
• Depository Responsibilities: IFSC depositories must ensure seamless migration, minimize disruption, and provide adequate disclosures on migration process
• Compliance Reporting: IFSC depositories must submit compliance report by April 30, 2026

October 28, 2025 – Consolidated IFSCA (Listing) Regulations, 2024 (Amended up to October 14, 2025)

IFSCA published a consolidated version of the Listing Regulations incorporating amendments effective October 14, 2025:

Key Amendments:

• SPAC Timeline Extension: Business combination information disclosure timeline extended from 5 to 8 working days
• DR Allotment Timeline: Depository receipt allotment and refund completion timeline extended from 5 to 8 working days from issue closure
• Quarterly Reporting: Enhanced flexibility in quarterly financial statement disclosure timelines with audit committee review requirements

Regulatory Framework:

• Applicability: Covers IPOs, FPOs, SPACs, rights/preferential issues, QIPs, DRs, debt securities, secondary listings, and other permitted financial products
• Eligible Issuers: Entities incorporated in IFSC, India, or foreign jurisdictions complying with home jurisdiction laws
• Clarifications: Authority empowered to issue clarifications through guidance notes or circulars for interpretation

October 31, 2025 – Modifications to AML/CFT/KYC Guidelines – Video-Based Customer Identification Process

IFSCA introduced comprehensive modifications enabling Video-based Customer Identification Process (V-CIP) for onboarding Indian nationals and Non-Resident Indians:

V-CIP for Indian Nationals:

• Authorized Operators: V-CIP may be operated by regulated entity officials, financial group entities in India supervised by financial regulators, or KYC Registration Agencies
• Infrastructure Requirements: Technology infrastructure housed within regulated entity or financial group premises; end-to-end encryption; anti-spoofing capabilities
• IP Address Restrictions: Resident Indians must have IP emanating from India
• Technology Standards: Face liveness/spoof detection; AI anti-deep fake checks; live GPS coordinates; date-time stamping

V-CIP for NRIs (Pilot Phase):

• Eligible Jurisdictions: Low-risk NRIs residing in 11 specified countries: USA, Japan, South Korea, UK (excluding British Overseas Territories), France, Germany, Canada, UAE, Singapore, Australia, European Union (excluding Croatia)
• Verification Requirements: IP address must emanate from jurisdiction in current address proof; bank account details from specified jurisdiction required for verification
• Debit Freeze Mechanism: Account opened in debit freeze mode upon identity verification; activation only upon receipt and verification of first credit from provided bank account
• Pilot Duration: 4-month pilot phase; expansion to additional countries after completion

Security and Compliance:

• Audit Requirements: Vulnerability Assessment, Penetration Testing, and Security Audit by CERT-In empaneled auditors
• Concurrent Audit: All V-CIP accounts operational only after concurrent audit ensuring process integrity
• Record Management: Video recordings stored securely with date-time stamps; activity logs preserved

November 3, 2025 – Consultation Paper on Amendments to CMI Regulations

IFSCA proposed multiple amendments to Capital Market Intermediaries Regulations, 2025 addressing industry concerns:

Principal Officer / Compliance Officer Eligibility Relaxations :

• Qualification Expansion: Post-graduate degrees in fintech, science, technology, engineering, and mathematics (STEM) added as valid qualifications
• Experience Reduction: Minimum experience for graduate degree holders reduced from 10 years to 5 years in financial services market
• Rationale: Addresses talent shortage in nascent IFSC capital markets ecosystem

Common Principal Officer for Multiple Registrations :

• Expanded Scope: Entities with registrations as broker dealers, clearing members, depository participants, custodians, and registered distributors may have same principal officer
• Distribution Vertical Head: Entities conducting distribution must appoint separate official with adequate financial services experience as vertical head for distribution activities
• Operational Benefits: Reduces impediments for entities offering complementary services

Net Worth Clarifications :

• Excluded from Liquid Assets: Base minimum capital and interest-free deposits with stock exchanges/clearing corporations
• Included in Liquid Assets: Margins deposited with clearing members and clearing corporations
• Custodian Net Worth: Unified USD 1 million minimum net worth requirement for all custodians (replacing complex tiered structure); existing custodians have until January 31, 2026 to comply

Umbrella Registration Framework :

• Singapore Model: IFSCA exploring unified Capital Markets Services (CMS) License model allowing entities to seek multiple activity registrations through single application
• Objective: Enhance ease of doing business and streamline registration processes

November 4, 2025 – Consultation Paper on Proposed IFSCA (Pension Fund) Regulations, 2025

IFSCA released comprehensive proposed regulations for establishing pension fund ecosystem in IFSC targeting NRIs and foreign citizens:

Regulatory Background:

• Expert Committee: Expert Committee on Sustainable Finance (chaired by Prof. Mukul G. Asher) recommended IFSCA-regulated pension products with non-INR denomination
• Government Notifications: Scheme operated by pension fund notified as ‘financial product’ (December 5, 2024); Section 25 of PFRDA Act 2013 exempted for IFSC (October 1, 2025)

Pension Fund Manager (PFM) Eligibility:

• Legal Structure: Company or branch in IFSC
• Experience Requirement: Applicant/parent/associate must have 10 years’ experience managing pension fund, retail fund, or insurance business
• Minimum Net Worth: USD 1 million at all times
• Infrastructure: Robust IT infrastructure, secure systems, defined processes for fund management, record keeping, administration, grievance redressal, cybersecurity, and compliance
• Staffing: Minimum three employees (including compliance officer) with specified qualifications and 3+ years’ relevant experience

Scheme Features:

• Voluntary Participation: Open exclusively to NRIs and foreign citizens above 18 years
• Contribution Flexibility: Subscribers determine frequency (monthly, quarterly, annually, lump sum) and amount
• Multiple Scheme Types: Distinct investment options with varied objectives, strategies, and risk profiles
• Exit Options: Systematic Withdrawal Plans (SWP) and annuity options

Governance and Compliance:

• Fit and Proper Criteria: All directors, key managerial personnel, and controlling shareholders must meet fit and proper criteria continuously
• Office Requirements: Dedicated, fully functional IFSC office with adequate infrastructure
• Technology Systems: Robust, scalable, secure systems for investment analysis, trading, risk monitoring, valuation, record-keeping, and cybersecurity
• Policy Framework: Comprehensive internal policies covering investment decisions, risk management, compliance, grievance redressal, AML/CFT

Value Propositions:

• Global Asset Access: Investment in wide range of global assets with high allocation permitted to Indian markets
• Healthcare Integration: Optional healthcare benefit integration
• Regulatory Oversight: Robust subscriber protection framework with operational flexibility

November 11, 2025 – Additional Reporting Directions for IFSC Banking Units (External Account Statistics)

IFSCA issued supplementary directions enhancing fortnightly Banking Asset Liability (BAL) statement reporting by IBUs:

Vostro Account Reporting Mandate:

• New Requirement: IBUs must report balances in foreign currency accounts of overseas banks (Vostro accounts) held/maintained with the IBU
• Rationale: IBUs have started maintaining such accounts which were not captured in existing BAL reporting framework
• Effective Period: Fortnightly reporting from second fortnight of November 2025

Vostro Account Reporting Instructions:

• Current Account Component: Report either net credit balance under Credit (Ct) or net debit balance under Debit (Dt) without negative sign; no simultaneous entries
• Book Value Reporting: Report book value of balances in respective currency
• Country/Currency Fields: “Country” represents overseas bank’s country; “Currency” represents account maintenance currency

Compliance and Enforcement:

• Accuracy Requirement: Failure to furnish mandated information accurately and timely will be viewed seriously
• Legal Basis: Issued under Section 35A of Banking Regulation Act, 1949 and Section 13(1) of IFSCA Act, 2019
• Platform: Reporting through RBI’s BoP portal (https://bop.rbi.org.in/)

Analysis of regulatory trends

Digital Transformation Leadership

The period demonstrates IFSCA’s commitment to digital-first regulation with initiatives including video-based KYC, SWIT portal operationalization, and FCSS implementation. These developments position GIFT IFSC as a digitally advanced financial center capable of serving global markets efficiently. 

Regulatory Harmonization and Simplification

The introduction of Master Circulars and consolidated frameworks reflects strategic regulatory maturity. By moving from fragmented guidelines to comprehensive frameworks, IFSCA has significantly enhanced regulatory clarity and ease of compliance for market participants. 

Sustainable Finance Innovation

The Transition Bonds Framework positions GIFT IFSC at the forefront of sustainable finance innovation, addressing the critical USD 100+ trillion funding gap for decarbonizing hard-to-abate sectors while maintaining rigorous environmental and governance standards. 

Global Market Integration

Multiple initiatives including the Global Access Framework, international payment system participation, and foreign currency settlement capabilities demonstrate IFSCA’s vision of positioning GIFT IFSC as a truly global financial hub with seamless cross-border connectivity. 

Technology-Enabled Financial Services

The TechFin and Ancillary Services Regulations recognize the critical role of technology in modern financial services delivery, providing a structured framework for fintech innovation while maintaining appropriate oversight and risk management standards. 

Conclusion

The April-October 2025 period represents a transformative phase in IFSCA’s regulatory evolution, characterized by comprehensive framework modernization, digital innovation leadership, and strategic positioning for global competitiveness. The Authority has successfully balanced innovation enablement with robust risk management, creating an ecosystem that supports diverse financial services while maintaining international regulatory standards.

The detailed nature of these regulatory updates demonstrates IFSCA’s proactive approach to addressing evolving market needs while maintaining high standards of governance, transparency, and investor protection. As these frameworks become fully operational, they are expected to significantly enhance GIFT IFSC’s attractiveness as a premier destination for international financial services and contribute substantially to India’s emergence as a global financial hub.

The comprehensive coverage of digital infrastructure, sustainable finance, global market access, and technology integration positions GIFT IFSC to compete effectively with established international financial centers while serving the unique needs of the Indian and global financial services ecosystem.