# Investor Relations and Reporting Services

Published: 22 Oct 2026
Author: Treelife
Practice area: Finance
Tags: AIF investor reporting, AIF performance reporting IRR DPI TVPI, AIF quarterly investor report format, Form 78 and Form 79 for AIF investors, investor reporting services India, LP reporting for AIF managers, outsourced investor reporting for fund managers, SEBI AIF Regulation 22 investor reporting
Source: https://treelife.in/finance/investor-relations-and-reporting-services/

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Blog Content Overview

- [0.1 What must an AIF report to its investors in India?](#What_must_an_AIF_report_to_its_investors_in_India)

- [1 What do investor reporting services in India cover, and where do they stop?](#What_do_investor_reporting_services_in_India_cover_and_where_do_they_stop)
- [2 What does an AIF owe its investors, and by when?](#What_does_an_AIF_owe_its_investors_and_by_when)
[2.1 What does the Regulation 22(g) annual report contain?](#What_does_the_Regulation_22g_annual_report_contain)
- [2.2 Which date governs when the contract is tighter?](#Which_date_governs_when_the_contract_is_tighter)
- [2.3 How do investor reporting duties differ by AIF category?](#How_do_investor_reporting_duties_differ_by_AIF_category)
- [2.4 Which event-based notices does the Master Circular add?](#Which_event-based_notices_does_the_Master_Circular_add)
- [2.5 What are the consequences of a late or wrong investor report?](#What_are_the_consequences_of_a_late_or_wrong_investor_report)
[2.5.1 Need an LP reporting calendar built around Regulation 22? 
Let’s Talk](#Need_an_LP_reporting_calendar_built_around_Regulation_22_Let8217s_Talk)

- [3 How is AIF performance measured, reported and benchmarked?](#How_is_AIF_performance_measured_reported_and_benchmarked)
- [4 What goes into a complete LP reporting pack?](#What_goes_into_a_complete_LP_reporting_pack)
[4.1 Quarterly pack or annual report: what changes?](#Quarterly_pack_or_annual_report_what_changes)
- [4.2 The tie-out before release](#The_tie-out_before_release)
- [4.3 What should an LP check in a report?](#What_should_an_LP_check_in_a_report)

- [5 What changed in 2026 that investor reports must now reflect?](#What_changed_in_2026_that_investor_reports_must_now_reflect)
[5.1 Why Form 78 and Form 79 sit at the centre of the pack](#Why_Form_78_and_Form_79_sit_at_the_centre_of_the_pack)
- [5.2 FATCA and CRS: why the investor reporting team touches it](#FATCA_and_CRS_why_the_investor_reporting_team_touches_it)

- [6 How do reporting duties differ for companies, listed entities and GIFT City funds?](#How_do_reporting_duties_differ_for_companies_listed_entities_and_GIFT_City_funds)
[6.1 How should a company report to its own investors?](#How_should_a_company_report_to_its_own_investors)
- [6.2 What do listed companies owe their investors?](#What_do_listed_companies_owe_their_investors)
- [6.3 What changes for a GIFT City fund?](#What_changes_for_a_GIFT_City_fund)

- [7 Which investor reporting services in India fit: in-house, administrator or hybrid?](#Which_investor_reporting_services_in_India_fit_in-house_administrator_or_hybrid)
[7.1 What technology sits behind a reliable reporting cycle?](#What_technology_sits_behind_a_reliable_reporting_cycle)

- [8 What should the service agreement, onboarding plan and fee define?](#What_should_the_service_agreement_onboarding_plan_and_fee_define)
[8.1 Which clauses belong in the contract?](#Which_clauses_belong_in_the_contract)
- [8.2 How should a fund onboard a provider?](#How_should_a_fund_onboard_a_provider)
- [8.3 How do you choose between providers?](#How_do_you_choose_between_providers)
- [8.4 What do investor reporting services in India cost, and what moves the fee?](#What_do_investor_reporting_services_in_India_cost_and_what_moves_the_fee)

- [9 Common mistakes that cost fund managers time and money](#Common_mistakes_that_cost_fund_managers_time_and_money)
- [10 Choosing among investor reporting services in India: the short answer](#Choosing_among_investor_reporting_services_in_India_the_short_answer)
- [11 FAQs on Investor Relations and Reporting Services](#FAQs_on_Investor_Relations_and_Reporting_Services)

[11.0.0.1 Regulatory references](#Regulatory_references)

Investor reporting services in India sit between the fund accountant who closes the books and the manager who has to explain the numbers to investors. For an Alternative Investment Fund (AIF), the duty is statutory: Regulation 22 of the Securities and Exchange Board of India (SEBI) (Alternative Investment Funds) Regulations, 2012 fixes what investors must receive and when. Since February 2026, three changes have altered the work: net asset value (NAV) uploads to depositories, a new SEBI activity-reporting cycle, and Form 78 under the Income-tax Act, 2025. This article sets out the obligations, the pack, performance metrics, the tax and compliance data behind it, the operating models and the contract terms.

### What must an AIF report to its investors in India?

Under Regulation 22 of the SEBI (Alternative Investment Funds) Regulations, 2012, an AIF must give investors periodic financial, risk, operational, portfolio and transactional information, with fee disclosures. A report on investee company financials and material risks is due annually within 180 days of year end. Category III AIFs report quarterly within 60 days. Category I and II valuations are due every six months under Regulation 23(2).

## What do investor reporting services in India cover, and where do they stop?

Investor reporting services prepare and deliver what a fund or company owes its investors: capital account statements, valuation and NAV disclosures, portfolio and risk reports, performance figures, tax statements and event notices. They support the manager’s judgement on valuation and disclosure. They do not replace it, and they do not file the manager’s returns to the regulator.

The phrase covers four relationships, and the rules differ for each.

**Table 1: Who reports to whom, and under which source**

RelationshipWhat is reportedGoverning sourceCadenceAIF to its limited partners (LPs)Capital accounts, NAV, portfolio, risk, performance, tax statementsSEBI AIF Regulations, 2012 (Regulations 22 and 23), the placement memorandum (PPM), contribution agreement and side lettersAnnual floor for all AIFs; quarterly for Category III; tighter by contractCompany to its institutional investorsFinancial statements, KPIs, cap table, board matters[Section 136(1), Companies Act, 2013](https://www.incometaxindia.gov.in/w/section-136-79); the shareholders’ agreementAnnual statutory floor; monthly or quarterly by contractListed company to shareholders and analystsResults, shareholding pattern, material eventsSEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015Quarterly, annual and event basedGIFT City fund to its investorsPortfolio, NAV, annual reportIFSCA (Fund Management) RegulationsAs the Regulations set; see the GIFT City section below

This article focuses on the first row. Two adjacent streams stay separate. The board’s management pack is covered in what founders should track and how often, and returns to SEBI sit in the [AIF compliance calendar](https://treelife.in/compliance/aif-compliance-calendar/). One dataset feeds all of them. The audiences, deadlines and liability differ.

Providers often bundle services that are not investor reporting: investor onboarding and KYC, FATCA and common reporting standard filings, demat and ISIN creation, and stamp duty payments. Treat each as a separate scope line in the contract. See Treelife’s fund operations and vendor management page for how such scope is split.

**Table 2: Who produces and signs each investor deliverable**

PartyRole in investor reportingSourceManagerAnswerable for transparency and disclosure; signs off valuation, NAV and the risk narrativeRegulations 22 and 24(e)Sponsor, trustee or board, by fund formOversees the fund; intimates the Board and investors of the circumstances leading to winding upRegulation 29(5)Independent valuerValues investments at least every six months for Category I and IIRegulation 23(2)AuditorAudits the fund’s books annuallyRegulation 20RTAUploads NAV per ISIN to depositories; collects stamp duty on unitsMaster Circular paras 11.3 and 11.5CustodianMandatory above ₹500 crore corpus and for Category III irrespective of corpus; receives Category III leverage reportsRegulation 20; Master Circular para 7.3Fund administrator or advisory firm (optional)Prepares data tie-out, capital accounts and statements; accountability stays with the ManagerContract; Regulation 24(e)

## What does an AIF owe its investors, and by when?

An AIF owes investors four things: periodic disclosure of financial, risk, operational, portfolio and transactional information; an annual report within 180 days of year end; event-based notices as they occur; and valuation or NAV disclosures on a cycle set by category. The first three sit in Regulation 22 and the last in Regulation 23 of the [SEBI AIF Regulations, 2012](https://www.sebi.gov.in/sebi_data/attachdocs/jul-2026/1785301664601.pdf).

**Table 3: Investor-facing reporting duties of an AIF**

DutyApplies toTimingSourceFinancial, risk, operational, portfolio and transactional informationAll AIFsPeriodically, frequency not fixed by the RegulationsRegulation 22(a)Fees to Manager or Sponsor, and fees charged to the fund or an investee company by their associatesAll AIFsPeriodicallyRegulation 22(b)Annual report: investee company financials and material risksAll AIFsWithin 180 days of year endRegulation 22(g)Quarterly report on the same itemsCategory IIIWithin 60 days of quarter endRegulation 22(h)Legal or regulatory inquiries, material liabilities, breaches of PPM or fund documents, change in control of Sponsor, Manager or investee companyAll AIFsAs and when they occurRegulation 22(c) to (f)Significant change in key investment teamAll AIFsOn occurrence, to all investorsRegulation 22(i)Description of valuation procedure and methodologyAll AIFsProvided to investorsRegulation 23(1)Independent valuationCategory I and IIAt least every six months; annual if investors holding 75% by value approveRegulation 23(2)NAV disclosureCategory IIIQuarterly (close ended), monthly (open ended)Regulation 23(3)Statement of income distributed (Form 78)Category I and II with pass-through statusBy 30 June after the tax yearSection 224, Income-tax Act, 2025; Rule 145, Income-tax Rules, 2026

### What does the Regulation 22(g) annual report contain?

Regulation 22(g) requires financial information of investee companies and the material risks and how they are managed. The listed risk heads are concentration risk at fund level, foreign exchange risk at fund level, leverage risk at fund and investee company levels, realisation risk (a change in the exit environment), strategy risk at investee company level, reputation risk at investee company level, and extra-financial risks, including environmental, social and governance risks, at fund and investee company level. A report that skips a head needs a stated reason, because the head is part of the rule, not a template choice.

### Which date governs when the contract is tighter?

The tighter date governs. Regulation 22 sets floors, and the PPM, contribution agreement and side letters can bring dates forward or add content. Outsourcing does not move accountability: Regulation 24(e) obliges the Manager to make sure transparency and disclosure requirements are met, and a contravention of any provision of the Regulations is dealt with under Regulation 35(1)(a) through the SEBI (Intermediaries) Regulations, 2008. Investor complaints are separate: Regulation 24(a) obliges the Manager to address all of them, and Regulation 25 requires a dispute resolution procedure. Para 2.3 of the Master Circular also requires complaints data in the Annexure 5 format to be disclosed in the PPM and compiled within 7 days of quarter end. The [manager obligations guide](https://treelife.in/finance/aif-sponsor-and-investment-manager-obligations-under-sebi-regulations/) covers the wider duties.

### How do investor reporting duties differ by AIF category?

Category III funds report more often and carry more event notices, while Category I and II funds carry the valuation and pass-through tax duties. The annual report applies to all three.

**Table 4: Investor reporting by AIF category**

ItemCategory ICategory IICategory IIIAnnual investor report within 180 days (Regulation 22(g))YesYesYesQuarterly investor report within 60 days (Regulation 22(h))Contractual onlyContractual onlyYesValuation or NAV to investorsIndependent valuation at least every six months (Regulation 23(2))Independent valuation at least every six months (Regulation 23(2))NAV independent of fund management, quarterly (close ended) or monthly (open ended) (Regulation 23(3))Pass-through tax statementForm 78Form 78Not applicable: taxed at fund levelLeverage breach and redemption suspension noticesNot applicableNot applicableYes (Master Circular paras 7.3 and 7.5)CustodianAbove ₹500 crore corpusAbove ₹500 crore corpusIrrespective of corpusPerformance data to benchmarking agenciesYesYesYes

### Which event-based notices does the Master Circular add?

Beyond Regulation 22(c) to (f), the Master Circular for AIFs adds triggers that put a notice in the investor’s inbox on a short clock. A calendar built only from Regulation 22 misses them.

**Table 5: Event-based investor notices under the Master Circular**

TriggerWhat investors receiveTimingSourceLeverage limit breach (Category III)Report with reasons, then confirmation of square-offReport before 10 a.m. on the next working day; confirmation by end of the day of square-offPara 7.3.3Suspension of redemptions (open-ended Category III)Documented reasons and planned actions, updates during the suspension, and notice of resumptionAs soon as decided and throughoutParas 7.5.7 and 7.5.9Unhedged credit default swap positions above 25% of investable fundsIntimation to all unit holdersBefore the position is takenPara 4.2.10Change in sponsor or manager, change in control, or a fee or hurdle change that raises feesExit option, with not less than one month to dissentPer the process in the Master CircularPara 13.1.1Change in key investment teamIntimation to all investorsOn occurrenceRegulation 22(i)

### What are the consequences of a late or wrong investor report?

A contravention of Regulation 22 is dealt with under the SEBI (Intermediaries) Regulations, 2008 (Regulation 35(1)(a)). After an inspection, Regulation 34 lets SEBI direct an AIF not to launch new schemes or raise money for a period, to refund investors, or bar persons from the capital market, and Regulation 35(2) keeps SEBI’s wider powers under the SEBI Act intact. This article quotes no penalty amounts because none attach to Regulation 22 itself.

> 

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Need an LP reporting calendar built around Regulation 22? 
[Let’s Talk](javascript:void(0))

[

](https://calendly.com/consulttreelife/20min?utm_source=blogbannertreelife)

## How is AIF performance measured, reported and benchmarked?

AIF performance is reported with IRR, DPI, RVPI and TVPI, and benchmarked half-yearly against category peers on data as of 30 September and 31 March. SEBI’s benchmarking framework requires each AIF to give data to a benchmarking agency notified by an industry association. Benchmarks are calculated post expense, pre carry and pre tax.

SEBI mandated performance benchmarking through its circular of 05/02/2020 (SEBI/HO/IMD/DF6/CIR/P/2020/24), extended by the circular of 12/06/2020 and now consolidated in Chapter 22 of the Master Circular for AIFs, as recorded by the [Indian Venture and Alternate Capital Association (IVCA)](https://www.ivca.in/resources/performance-aifs). An association representing at least 33% of AIFs by number appoints the agencies, and each AIF signs an agreement with them covering the data to be reported. The first benchmarks, launched by [Crisil in 2020](https://www.crisil.com/en/home/newsroom/press-releases/2020/10/crisil-launches-indias-first-aif-benchmark-indices.html), used pooled internal rate of return (IRR), multiples and realisation ratios by vintage for Category I and II.

**Table 6: Performance metrics an LP pack should define**

MetricWhat it measuresBasisCommon errorNet IRRAnnualised return, reflecting the timing of calls and distributionsAfter fees, expenses and carryMixing gross and net figures in one tableDPIDistributions divided by paid-in capitalCash actually returnedCounting unrealised value as distributedRVPIResidual (unrealised) value divided by paid-in capitalNAV at the reporting dateUsing a stale valuation dateTVPIDPI plus RVPITotal value per unit of capital paid inQuoting TVPI without its DPI splitPooled IRRIRR of combined cash flows of a peer groupBenchmark useComparing a single fund to a pooled figure of a different vintage

Three practical rules follow. State the basis of every return figure (net or gross, pre or post carry). Show DPI beside TVPI so investors can see how much is cash. And match the valuation date in the performance table to the NAV in the capital account and the NAV uploaded to depositories. The AIF valuation framework explains how the valuation date is set.

Angel funds are inside the net. From financial year 2025-26 they report investment-wise valuation and cash flow data to the benchmarking agencies, and where an angel fund cites past performance in its PPM or marketing, it must also provide the performance versus benchmark report (Master Circular paras 8.11 and 8.12). Existing angel funds have until 31/03/2027 to move to accredited investors only, after SEBI’s relaxation of 07/09/2026 (para 8.1.2).

## What goes into a complete LP reporting pack?

A complete pack has nine parts: a capital account statement for each investor, fund financial statements, a portfolio schedule with valuation and methodology, fee and expense disclosure, a risk section, performance figures, notices of calls and distributions, event notices and tax statements. Regulation 22 sets the risk heads, and every capital account must reconcile to units and NAV.

- Capital account statement per LP. Fields: opening balance, contributions called in the period, distributions by character (return of capital, gains, income), management fee and expenses charged, realised and unrealised gains, closing NAV, units held, commitment and undrawn commitment. The mechanics sit in [capital calls and drawdowns](https://treelife.in/finance/capital-calls-and-drawdowns-in-aifs/) and the distribution waterfall.

- Fund financial statements. Regulation 20 requires the fund’s books to be audited annually by a qualified auditor.

- Portfolio schedule: investee, cost, fair value, valuation methodology and movement since the last period (Regulations 22(a) and 23(1)).

- Fees and expenses charged to the fund, including fees from associates of the Manager or Sponsor (Regulation 22(b)), and any carry accrual shown under the waterfall.

- Risk section on the Regulation 22(g)(B) heads. Some investors also ask for investee-level data such as headcount and ESG scores, and Regulation 22(g)(B)(vii) already covers extra-financial risks.

- Performance: net IRR, DPI, RVPI and TVPI with the basis stated, and the latest category benchmark where available.

- Call and distribution notices issued in the period.

- Event notices: inquiries, material liabilities, PPM breaches, change in control or in the key investment team (Regulation 22(c) to (f) and (i)).

- Tax statement: Form 78 for pass-through funds.

### Quarterly pack or annual report: what changes?

The quarterly pack is the contractual workhorse for most LPs. It carries the capital account, a short portfolio update and the valuation status. The annual report is the statutory deliverable under Regulation 22(g), with audited financials, the full risk section and the investee company financial information. Many funds send both; the annual report must still stand alone, because Regulation 22(g) applies even where quarterly reports exist.

### The tie-out before release

Before release, five figures should agree: the capital accounts, the units in the register, the NAV in the report, the NAV in the depository, and the income in Form 79. A mismatch between any two is visible to an investor within minutes. Add a sixth check: the figures in the SEBI activity report for the same period, because both documents draw on the same dataset. Where units sit in an Aggregate Escrow Demat Account, the manager must also report investor-wise KYC details to depositories and custodians every month (Master Circular para 11.2.2(e)), so that register belongs in the same reconciliation.

### What should an LP check in a report?

An investor reading the pack can test it in six steps:

- The NAV matches the depository figure and the valuation date is stated.

- Every return figure states whether it is net or gross, and pre or post carry.

- Fees and expenses match the PPM’s tabular waterfall example.

- Each Regulation 22(g)(B) risk head is addressed, or a reason is given.

- Side letter commitments on content and dates have been met.

- The Form 78 figures match the capital account and the register details for that investor.

## What changed in 2026 that investor reports must now reflect?

Four changes affect what reaches investors. NAV must be uploaded to depositories within 30 days of valuation (SEBI circular of 06/02/2026). SEBI replaced quarterly activity reports with an annual report plus a lighter quarterly report (circular of 04/03/2026). Pass-through tax statements moved to Form 78 and Form 79 under the Income-tax Act, 2025, in force from 01/04/2026. FATCA and CRS statements moved from Form 61B to Form 166.

**Table 7: 2026 changes and their effect on investor reporting**

ChangeInstrument and dateEffect on investor reportingNAV to depositories[SEBI circular dated 06/02/2026](https://www.sebi.gov.in/sebi_data/attachdocs/sep-2026/1789554609420.pdf), now in the Master Circular for AIFs dated 03/06/2026 (last updated 07/09/2026)Para 11.3 of the Master Circular: the Registrar and Transfer Agent (RTA) uploads the latest NAV per ISIN within 30 days of valuation. The valuation date is the date of the independent valuer’s report, or the date the valuation is documented in internal records if valued internally. SEBI’s prescribed disclaimer must appear wherever NAV is displayed. The Manager is responsible for timely and accurate upload, so the NAV in the investor report must match it.Activity reporting to SEBI[SEBI circular dated 04/03/2026](https://www.sebi.gov.in/legal/circulars/mar-2026/regulatory-reporting-by-aifs_100120.html)Annual activity report within 30 calendar days of March end, first one due 31/05/2026. Quarterly report within 15 days, with none for the March quarter. Same data as the investor pack, different audience.Pass-through tax statements[Income-tax Act, 2025 and Rule 145 of Income-tax Rules, 2026](https://www.incometaxindia.gov.in/documents/d/guest/comprehensive-note-on-form-78), from 01/04/2026Form 79 (earlier Form 64D) is filed first, by [15 June](https://www.incometaxindia.gov.in/documents/d/guest/comprehensive-note-on-form-79), and now also carries the date of payment or credit. Form 78 (earlier Form 64C) is generated from it and goes to each unit holder by 30 June.FATCA and CRS[Section 508, Income-tax Act, 2025; Rules 238 to 240; Form 166](https://www.incometaxindia.gov.in/w/faqs-on-forms-as-per-income-tax-rules-2026-1)Form 166 replaces Form 61B from 01/04/2026; the due date remains 31 May. Investor self-certification data collected at onboarding feeds it.Circular consolidationMaster Circular for AIFs dated 03/06/2026, last updated 07/09/2026 (Chapter 21 covers periodic reporting and Chapter 22 performance benchmarking)Earlier AIF circulars are rescinded to the extent they relate to AIFs (Annexure 24), so report templates citing them need updating. See the June 2026 Master Circular summary.Data protection[Digital Personal Data Protection (DPDP) Rules, 2025](https://static.pib.gov.in/WriteReadData/specificdocs/documents/2025/nov/doc20251117695301.pdf), notified 14/11/2025Operational duties apply 18 months after notification, around 13/05/2027. A January 2026 proposal to shorten the period for significant data fiduciaries had not been notified as at 12/10/2026, and the Removal of Difficulties Order of 05/10/2026 made only editorial corrections to Sections 9 and 10 of the Act. Investor names, PAN and bank details in reports and portals fall within the duties.

### Why Form 78 and Form 79 sit at the centre of the pack

Form 78 is where the fund’s books meet the investor’s tax return. Because the portal generates it from the unit holder rows in Form 79, a unit holder register with mismatched names or PANs produces wrong statements at scale. Investors need the statement to complete the Pass Through Income schedule of their return, and the Department’s guidance note ties the 30 June date to the 31/07 filing date for individuals not requiring audit. Older documents that still cite Section 115UB or Forms 64C and 64D need rewriting for tax years under the 2025 Act. Income keeps its character in the investor’s hands: the Finance Act, 2025 amended Section 2(14) to treat securities held by investment funds as capital assets from assessment year 2026-27, as set out in the Category III tax guide, which also records that Category III funds were not addressed in Finance Act, 2026. The AIF taxation guide covers the pass-through rules.

### FATCA and CRS: why the investor reporting team touches it

AIFs typically report as investment entities under FATCA and CRS, which means investor onboarding must capture tax residency and self-certification, and the same investor register must feed the annual statement. Under the Income-tax Act, 2025 the statutory basis is Section 508 with Rules 238 to 240, and the annual statement is Form 166, replacing Form 61B from 01/04/2026. The due date stays 31 May each year, per the CBDT’s revised guidance note of 24/07/2026. The practical point is data discipline: one investor master record should serve capital accounts, Form 79 and Form 166.

## How do reporting duties differ for companies, listed entities and GIFT City funds?

The Regulation 22 duties bind AIFs. A company reporting to its investors works from the shareholders’ agreement and the Companies Act. A listed entity works from the SEBI listing regulations. A GIFT City fund works from the IFSCA regulations. The same dataset discipline applies to all four, but the deliverables and dates are not interchangeable.

### How should a company report to its own investors?

Information rights come from the shareholders’ agreement, not from statute. The statutory floor is Section 136(1) of the Companies Act, 2013: financial statements go to every member at least 21 days before the general meeting, and shorter notice is possible under Section 101 with the consents it requires. The [Corporate Laws (Amendment) Bill, 2026](https://prsindia.org/billtrack/the-corporate-laws-amendment-bill-2026), introduced on 23/03/2026 and referred to a Joint Parliamentary Committee, proposes electronic-only service of prescribed documents on members for prescribed classes of companies. It had not been enacted when this article was last checked on 21/10/2026, so Section 136(1) stands as written. Everything else, including monthly updates, is contractual. A workable investor update has a fixed order:

- Headline numbers: revenue, gross margin, cash, burn and runway, against plan

- Product and customer movements that explain the numbers

- Hiring and organisation changes

- Risks and what management is doing about them

- Specific asks of investors, such as introductions or hiring help

The monthly management pack feeds it, as set out in [monthly MIS reporting services](https://treelife.in/finance/monthly-mis-reporting-services-for-businesses/), and what institutions test in a software company is in SaaS metrics investors track. Where an investor holds a board observer seat, the board observer guide explains what the seat does and does not entitle them to. Keep the cap table current, because a stale cap table is the first thing found in investor due diligence and the cap table guide shows how to keep it clean.

### What do listed companies owe their investors?

Listed entities report under the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015. Treelife’s core practice is private companies and funds, so this section is a map, not a manual.

**Table 8: Core investor-facing filings of a listed entity**

FilingRegulationTimingQuarterly and year-to-date financial results, with limited review reportRegulation 33Within 45 days of quarter end (first three quarters)Annual audited financial resultsRegulation 33Within 60 days of financial year endShareholding patternRegulation 31Within 21 days of quarter endStatement of investor complaintsRegulation 13(3)Within 21 days of quarter endMaterial events and informationRegulation 30Within the timelines the Regulation and its schedules set

These timelines should be confirmed against the Regulations as last amended. Investor relations agencies for listed companies add earnings materials, roadshow support and shareholder engagement on top of these filings. That is a different service from the one this article describes.

### What changes for a GIFT City fund?

A fund in GIFT City reports under the IFSCA (Fund Management) Regulations. The [2022 text, as amended to 11/04/2023](https://ifsca.gov.in/Document/Legal/ifsca-fund-management-regulations-2022-as-amended-upto-april-11-202324042023105305.pdf), required portfolio disclosure to investors at least quarterly, within one month of quarter end. IFSCA has amended the Regulations since, so confirm each date against the current text at ifsca.gov.in before building a calendar. The Income Tax Department’s Form 78 note also covers funds regulated under the IFSCA (Fund Management) Regulations, 2022, so pass-through statements apply there as well.

## Which investor reporting services in India fit: in-house, administrator or hybrid?

Treelife’s position is that a hybrid model fits most first-time Category II funds. The manager owns valuation sign-off, the risk narrative and investor communication. An outsourced provider runs data tie-out, capital accounts, tax statements and the calendar. Full outsourcing suits funds with many LPs or several schemes. In-house suits only a fund with a dedicated operations team.

**Table 9: Operating models for investor reporting**

ModelFitsStrengthWhere it breaksIn-house teamFew LPs and a dedicated operations hireFull control of data and toneQuarter end depends on one or two peopleIndependent fund administrator or RTAMany LPs, several schemes or foreign investorsCapital accounting, investor portal and RTA functions in one placeStandard formats; valuation inputs, narrative and Indian tax interplay stay with the managerAccounting and advisory firmFunds wanting tax, SEBI filings and LP reporting from one datasetForm 79, SEBI activity reports and the LP pack run off one sourceRTA and depository functions still sit with a registered RTASoftware onlyFunds with a strong in-house finance teamSpeed and LP self-service: onboarding, capital calls and an investor portalSoftware does not tie out data or sign off; errors scale faster

Pick: hybrid. Regulation 24(e) keeps disclosure accountability with the Manager, while the data work scales better outside it. For Category III, Regulation 23(3) requires NAV calculation to be independent of the fund management function. This article found no equivalent appointment requirement for Category I and II funds in Regulations 22 and 23. Fund operations support of this kind is described on Treelife’s [fund operations and vendor management](https://treelife.in/services/lifecycle-assistance/) page.

### What technology sits behind a reliable reporting cycle?

Five components matter, and the weak link is usually the join between them: a fund accounting system, an investor register held with the RTA, an investor portal, a reporting or business intelligence layer, and a document store with access controls. A unified platform with automated reconciliation, an audit trail and maker-checker review reduces the error risk of manual accounting. Whatever the stack, three controls are non-negotiable: reconciliation of capital accounts to the register, role-based access to investor data, and a log of every change to reference data. When choosing an investor portal, test role-based access, an audit log of document downloads, India-based hosting of investor data and export of the register on exit. Cyber resilience duties for AIFs are set out in the SEBI cybersecurity mandate for AIFs.

## What should the service agreement, onboarding plan and fee define?

The agreement should fix four things: what data the provider receives and when, who signs off each number, the release date for each deliverable in working days, and how errors are corrected after release. It should also allocate data protection duties and set exit terms so the register and reports transfer cleanly. Onboarding follows in four phases, and the fee follows scope.

### Which clauses belong in the contract?

- Scope by deliverable: quarterly pack, annual report, Form 79 and Form 78 data, Form 166 data, NAV data for the depository upload, call and distribution notices, performance figures.

- Inputs and cut-off: valuer report, bank statements, unit holder register, KYC records, prior-period pack.

- Sign-off chain: provider prepares, manager approves, valuation inputs come from the independent valuer.

- Service clock: statutory outer limits (60 days, 180 days, 30 June, 31 May) as hard stops, with contractual dates set earlier and a manager review window inside them.

- Correction protocol: re-issue with a correction note, version control and an audit trail.

- Side letter register: each bespoke reporting promise logged against the LP and its due date. See [LP agreement essentials](https://treelife.in/legal/lp-agreement-essentials/), and the PPM guide for the disclosures the PPM already makes.

- Data protection: the manager decides why and how investor data is processed, so it is the data fiduciary and the provider a processor. Under the [DPDP framework](https://static.pib.gov.in/WriteReadData/specificdocs/documents/2025/nov/doc20251117695301.pdf) the data fiduciary stays answerable for processing done by its processor, so the processor clause belongs in the contract before May 2027, not after.

- Quality measures: write accuracy of statements, timeliness of release, efficiency of the record-to-report process and cost at scale into the contract as service levels.

- Review rights: the manager should be able to review the provider’s work independently, with maker-checker approval and an audit trail. Every change to investor reference data, such as a name change after onboarding, must flow into the reporting system.

- Exit: transfer of the register, templates and history within an agreed period.

### How should a fund onboard a provider?

Run four phases. First, inventory every document that creates a reporting promise: the PPM, contribution agreements, side letters and prior reports. Second, clean the unit holder register against PAN and KYC records and agree one investor master record. Third, run a dry cycle on the last closed period and compare the output to what investors actually received. Fourth, run the first live cycle with the manager reviewing each number before release. Skip the dry cycle and the first live cycle becomes the test.

### How do you choose between providers?

Ask each provider for specifics, not capabilities:

- Which Regulation 22 and 23 deliverables do you prepare, and which do you leave to the manager?

- How is Form 79 data generated, and who verifies the unit holder register before filing?

- How do you coordinate NAV with the RTA for the depository upload?

- Where is investor data hosted, which sub-processors touch it, and what is the breach notification process?

- Who is the named lead, and what happens when that person leaves?

- What is your correction and re-issue policy, and can you show an anonymised example?

- What does exit look like: formats, timelines and who owns the templates?

### What do investor reporting services in India cost, and what moves the fee?

Fees follow scope, not the page count of the report. The drivers are the number of investors, schemes and portfolio companies, valuation frequency, the share of foreign investors, bespoke LP formats and portal needs. No verified public price benchmark exists for India, so none is quoted here. The investor register and the PPM are the two documents that fix a quote.

- Investors and schemes: each added scheme multiplies capital accounts and tax statements.

- Portfolio companies: each needs valuation inputs and a schedule line.

- Valuation frequency: Category I and II funds value at least every six months under Regulation 23(2); Category III NAV runs monthly or quarterly under Regulation 23(3).

- Foreign investors: extra FEMA, FATCA and currency presentation work.

- Bespoke reporting: look-through data and extra frequency promised in side letters.

- Platform: whether an investor portal is part of the scope.

## Common mistakes that cost fund managers time and money

Most first-cycle errors come from treating one dataset as one deliverable. The five below recur because each document has a different audience, a different date and a different source of authority.

- Treating the SEBI activity report as the investor report. Both draw on the same data, so teams assume one file serves both. They are separate: the SEBI report goes through the SEBI Intermediary Portal, the investor report is owed under Regulation 22. Failing to submit periodic reports to the Board is itself a ground for action under Regulation 35(1)(d).

- Letting the investor NAV differ from the depository NAV. The depository figure is uploaded by the RTA within 30 days of valuation and carries a SEBI disclaimer. Use one NAV, reconcile it before release, and make the Manager’s sign-off explicit.

- Using Form 64C, Form 64D, Form 61B and Section 115UB references for tax years under the 2025 Act. The correct references are Form 78, Form 79, Form 166 and Section 224, with the unit holder statement due by 30 June.

- Changing valuation methodology without telling investors. Regulation 23(1) requires a description of the valuation procedure and methodology. The [AIF valuation guide](https://treelife.in/finance/aif-valuation-in-india/) sets out when a change triggers disclosure.

- Leaving side letter promises outside the calendar. They live in separate documents, so they are missed at quarter end. Log each against the LP and its due date.

## Choosing among investor reporting services in India: the short answer

Pick a hybrid model run by a provider that can do the tax, SEBI and LP pack from one dataset. The reason is simple: the same numbers feed Form 79, Form 166, the SEBI activity report and the LP pack, and one team removes the reconciliation step between them. Choose a pure administrator if your LP count or scheme count is high, and software only if your finance team is already strong.

## FAQs on Investor Relations and Reporting Services

**Q: What tax statement does an AIF give its investors?** 
**A:** Category I and II funds with pass-through status furnish Form 78 to each unit holder under Section 224 of the Income-tax Act, 2025, by 30 June after the tax year. The portal generates it from the fund’s Form 79 filing. Investors use it in their return, as set out in the [Income Tax Department’s guidance note](https://www.incometaxindia.gov.in/documents/d/guest/comprehensive-note-on-form-78).

**Q: Do Category III AIFs issue Form 78?** 
**A:** The guidance note scopes Form 78 to Category I and II AIFs with pass-through status and funds regulated by the International Financial Services Centres Authority (IFSCA). Category III funds follow a different tax structure, explained in Category III AIF taxation.

**Q: Is Form 64C still the right statement for AIF investors?** 
**A:** For tax years under the Income-tax Act, 1961, yes. For tax years under the 2025 Act, which began on 01/04/2026, the statement is Form 78 and the fund-level filing is Form 79. On the guidance note’s timing, the first Form 78 for tax year 2026-27 falls due by 30/06/2027. Several AIF pages still cite only Forms 64C and 64D, so check the date of any template you inherit.

**Q: Do AIFs still file quarterly activity reports with SEBI?** 
**A:** Yes, in a lighter form. From the quarter ending June 2026 the quarterly report is due within 15 days of quarter end, with none for the March quarter, and a new annual activity report is due within 30 days of March end (SEBI circular of 04/03/2026). Pages describing a full quarterly report for every quarter predate this change. Investor reports are separate and sit under Regulation 22.

**Q: How are fees for investor reporting structured?** 
**A:** Fees follow scope: investors, schemes, portfolio companies, valuation frequency, foreign investors, bespoke formats and portals. No verified public benchmark exists for India. A quote follows a review of the investor register and the PPM.

**Q: How long does the first reporting cycle take?** 
**A:** The outer limits are fixed: annual report within 180 days of year end, Category III quarterly report within 60 days, Form 78 by 30 June, Form 166 by 31 May. Internal dates should sit well inside them with a manager review window. The valuer’s delivery date usually decides the schedule.

**Q: Which documents does a provider need before the first cycle?** 
**A:** The PPM, contribution agreements and side letters, the unit holder register with PAN and KYC, bank statements, independent valuer reports, audited accounts and prior investor reports. Without the register, tax statements cannot be prepared.

**Q: Do foreign investors change investor reporting duties?** 
**A:** Regulation 22 applies to every investor alike. Foreign investors add FEMA filings by the fund, covered in the AIF compliance calendar, FATCA and CRS self-certification at onboarding, and reporting currency set by the fund documents.

**Q: Can a family office receive consolidated reporting across its entities?** 
**A:** Yes, by contract. Each registered unit holder is still a separate recipient of Form 78 and Form 79 data, so a consolidated view is a supplement to the individual statements, not a replacement.

**Q: Does DPIIT recognition change what a company owes its investors?** 
**A:** No. Recognition under the Department for Promotion of Industry and Internal Trade (DPIIT) startup notification does not by itself set reporting duties to investors. Those come from the Companies Act, 2013 and the shareholders’ agreement.

**Q: What must a private company send its investors by law?** 
**A:** Section 136(1) of the Companies Act, 2013 requires financial statements to reach every member at least 21 days before the general meeting. Shorter notice is possible under Section 101 with the consents it requires. Monthly or quarterly updates are contractual.

**Q: What happens if an investor report is late or wrong?** 
**A:** A late or wrong report is a contravention of Regulation 22 and can draw action under Regulation 35(1)(a). Breaches of PPM terms must themselves be disclosed as and when they occur (Regulation 22(e)). Re-issue with a correction note and keep the audit trail.

**Q: What can an LP ask for beyond the standard report?** 
**A:** Beyond Regulation 22, rights come from the contribution agreement and side letters. Requests for look-through data or higher frequency are negotiated there. Each commitment should sit in the reporting calendar with an owner.

**Q: What does an investor need to be told when a fund winds up?** 
**A:** Regulation 29(5) requires the circumstances leading to winding up to be intimated to the Board and investors. Regulation 29 was amended on 18/04/2026 to add an inoperative fund route, so check the Chapter 25 framework in the Master Circular. See winding up an AIF.

**Q: What is the difference between investor reporting and MIS?** 
**A:** MIS is the management’s internal pack for decisions. Investor reporting is controlled disclosure to investors under law and contract. They share data and differ in audience, sign-off and liability. See monthly MIS reporting services.

**Q: What is the difference between DPI and TVPI?** 
**A:** DPI divides cash distributed by capital paid in, so it shows how much has actually come back. TVPI adds the unrealised value (RVPI) to DPI, so it shows total value. A fund with a high TVPI and a low DPI has returned little cash yet. Show both, with the basis stated.

**Q: How often must AIF performance be benchmarked?** 
**A:** Half-yearly, on data as of 30 September and 31 March, under SEBI’s benchmarking framework (circulars of 05/02/2020 and 12/06/2020). Each AIF gives data to a benchmarking agency notified by an industry association, per the [IVCA benchmarking page](https://www.ivca.in/resources/performance-aifs).

**Q: Does an AIF have to file FATCA and CRS statements?** 
**A:** AIFs generally qualify as reporting financial institutions and file the annual statement, now Form 166 under Section 508 of the Income-tax Act, 2025, replacing Form 61B from 01/04/2026, due 31 May. Confirm classification for each fund with its tax adviser.

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##### **Regulatory references**

- Securities and Exchange Board of India (Alternative Investment Funds) Regulations, 2012, as amended to 14/07/2026: Regulations 20, 22(a) to (j), 23(1) to (3), 24(a) and (e), 25, 28, 29(5) and 35(1)(a), (d)

- SEBI Master Circular for Alternative Investment Funds, No. HO/19/34/11(6)2025-AFD-POD1/I/12928/2026, issued 03/06/2026, last updated 07/09/2026: paras 2.3, 4.2.10, 7.3, 7.5, 8.1.2, 8.11, 8.12, 11.2.2, 11.3, 11.5 and 13.1.1, Chapters 21 and 22, Annexures 5 and 24

- SEBI circular, Reporting of value of units of AIFs to Depositories, 06/02/2026, No. HO/19/34/11(8)2025-AFD-POD1/I/4335/2026

- SEBI circular, Regulatory reporting by AIFs, 04/03/2026, No. HO/19/28/(1)2026-AFD-SEC3/I/6176/2026

- SEBI circulars on performance benchmarking of AIFs, SEBI/HO/IMD/DF6/CIR/P/2020/24 dated 05/02/2020 and the circular of 12/06/2020

- Income-tax Act, 2025, Sections 224 and 508 (Forms 78 and 79 guidance notes of the Income Tax Department); Income-tax Rules, 2026, Rules 145 and 238 to 240; Forms 78, 79 and 166 (earlier Section 115UB, Rule 12CB, Forms 64C, 64D and 61B under the 1961 Act and 1962 Rules)

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This is informational content from Treelife. For advice specific to your situation, contact support@treelife.in