SEBI AIF circular 2024-2025 – key changes in India

Between January 2024 and the end of 2025, the Securities and Exchange Board of India (SEBI) reshaped how Alternative Investment Funds operate through a dense series of circulars and amendments to the SEBI (Alternative Investment Funds) Regulations, 2012. The changes touched almost every part of a fund’s life: how units are held, how investors are treated, how co-investments are routed, and how lightly a fund can be regulated if it admits only accredited investors. For a manager running a live scheme, the difficulty is not understanding any single circular. It is tracking all of them together and knowing which deadline applies to which scheme. This article maps the SEBI AIF circular 2024-2025 key changes in India in the order a compliance team needs them, with circular numbers, the regulation each one amended, and the action each one demands.

What are the main SEBI AIF circular changes in 2024-2025?

The main SEBI AIF circular changes across 2024 and 2025 fall into two groups. The first group tightens investor protection: pro-rata and pari-passu rights (Circular dated 13 December 2024), and the dematerialisation of investments (Circular dated 12 January 2024, relaxed February 2025). The second group eases the regime for sophisticated capital: the co-investment vehicle route under the Second Amendment, 2025, and the accredited-investor-only framework under the Third Amendment, 2025, notified 18 November 2025 with operational detail in the Circular dated 08 December 2025.

Read together, the arc is consistent. SEBI removed the discretion that let large investors negotiate side deals inside a pooled fund, and in exchange gave funds that deal only with truly sophisticated investors a lighter compliance load. A manager who treats these as separate events will miss the trade-off the regulator built in.

The cycle has carried straight into 2026, and a few of those developments change live obligations rather than sitting in the background. The revised regulatory reporting framework (Circular dated 04 March 2026) replaces the old quarterly regime with an Annual Activity Report plus a slimmer quarterly filing, with the first annual report due 31 May 2026 for FY 2025-26. The SEBI (Alternative Investment Funds) (Amendment) Regulations, 2026 introduced an inoperative fund classification and eased a registration threshold, and a Circular dated 06 February 2026 added NAV reporting to depositories. The sections below take each change in turn, including these 2026 items, then close with a single deadline map.

How did the December 2024 circular change pro-rata and pari-passu rights?

The Circular dated 13 December 2024 (Circular No. SEBI/HO/AFD/AFD-POD-1/P/CIR/2024/175) made equal treatment of investors a hard rule rather than a market convention. It implemented the SEBI (Alternative Investment Funds) (Fifth Amendment) Regulations, 2024, notified on 18 November 2024, which inserted sub-regulations 21 and 22 into Regulation 20 of the AIF Regulations. Pro-rata means each investor’s rights in a scheme track the size of their commitment. Pari-passu means investors in the same class are treated equally, with no priority distribution that lets one walk away richer than another in the same deal.

Before this, a large investor could negotiate early payouts or priority exits, and many funds obliged. SEBI had already flagged the priority distribution model in 2022 and barred such schemes from taking fresh commitments. The December 2024 circular closed the gap formally. From here, rights and distribution of proceeds must be proportional to commitment, with a short list of exceptions.

The circular permits departures from strict pro-rata in defined cases: where an investor has been excused or excluded from a particular investment for legal, regulatory or contractual reasons, where an investor has defaulted on a capital call for that investment, and where returns are shared with the investment manager or sponsor in line with the contribution agreement. Outside these, differential rights are not allowed for ordinary schemes. The one structural carve-out sits with Large Value Funds for Accredited Investors (LVFs), which can offer differential rights if the PPM discloses it and each investor signs a specific waiver acknowledging that pari-passu rights may not be maintained.

Pro-rata and pari-passu: what changed and what a manager must do

Item	Position before	Position after 13 December 2024	Manager action
Distribution rights	Negotiable by side letter	Must be pro-rata to commitment	Review all side letters against Regulation 20(21)
Equal treatment in a class	Not mandated	Pari-passu required (Regulation 20(22))	Remove priority distribution terms
Differential rights	Common for large tickets	Permitted only in listed exceptions	Document each exception in writing
LVF flexibility	Same as other AIFs	Exemption available with waiver	Add disclosure and investor waiver in PPM

Existing schemes that had granted differential rights inconsistent with the new standard were required to report them to SEBI and discontinue any rights found adverse to other investors. Where compliance with the circular caused a breach of the investment limits under the AIF Regulations, that breach is not treated as non-compliance, but the manager must record it in the Compliance Test Report under Chapter 15 of the Master Circular for AIFs dated 07 May 2024.

One layer competitors tend to skip: the circular does not stand alone. It works alongside the implementation standards issued by the Standard Setting Forum for AIFs (SFA), the industry body SEBI relies on to translate principle into operating detail. In practice, a manager complies against the SFA standards, not just the bare text of the circular, since the standards set out how to test and document pro-rata treatment scheme by scheme. Reading the circular without the SFA standards is the most common reason a fund thinks it is compliant when its documentation is not.

Why did SEBI mandate dematerialisation of AIF investments?

SEBI mandated dematerialisation to create a clean electronic record of what every AIF actually holds, reducing the room for opacity in unlisted portfolios. The requirement first came through the Circular dated 12 January 2024 (Circular No. SEBI/HO/AFD/PoD/CIR/2024/5), which amended the AIF Regulations notified on 05 January 2024 and was later folded into Chapter 21 of the Master Circular for AIFs dated 07 May 2024. It is separate from the older mandate to dematerialise units of the fund itself, which ran on corpus-based deadlines through 2023 and April 2024.

The investment-side rule was relaxed in early 2025 to ease compliance. Under the revised position, any investment made by an AIF on or after 01 July 2025 must be held in dematerialised form, whether bought directly in the investee company or acquired from another entity. Investments made before 01 July 2025 are exempt, with two exceptions. The exemption falls away where the investee company is legally required to dematerialise its securities, and where the AIF, alone or with other intermediaries that must hold investments in demat form, controls the investee company within the meaning of Regulation 2(1)(f) of the AIF Regulations. In those two cases, the legacy holdings had to be dematerialised within the timeline SEBI set in the modified Paragraph 21.

For a manager, the practical work is in the diligence. Every new cheque from 01 July 2025 must close into demat, which means the investee company needs a depository connection and an ISIN before money moves. Where the fund sits on a control position in an older portfolio company, the pre-July exemption does not save it. Many teams discovered this only when a secondary buyer asked for demat-ready stock.

A related thread worth noting alongside demat is valuation. SEBI’s valuation norms, updated in 2023, align most AIF portfolio securities with the methodology under the SEBI (Mutual Funds) Regulations, 1996, leaving unlisted, non-traded and thinly traded securities to be valued under recognised principles by an independent valuer. The PPM must disclose the valuation methodology, and the manager carries responsibility for fair valuation and for reporting any deviation. This is the standing backdrop against which the demat record is read, since a clean holding record is only useful if the value attached to it is defensible.

What is the co-investment vehicle (CIV) introduced in 2025?

The co-investment vehicle is a dedicated route that lets accredited investors invest directly in an unlisted company alongside an AIF, introduced through the SEBI (Alternative Investment Funds) (Second Amendment) Regulations, 2025. It follows SEBI’s consultation paper dated 09 May 2025 and answers a long-running demand from LPs who wanted to put extra capital into specific deals beyond their fund commitment without the friction of the older Portfolio Management Services route.

The CIV simplifies what was previously a clumsy structure. Rather than running co-investments through a separate PMS licence, the manager can offer them inside the AIF framework, scheme by scheme, to accredited investors. This matters for venture and growth managers whose anchor LPs increasingly want concentrated exposure to a flagship portfolio company. The detail of ring-fencing, fees and reporting for each CIV needs to be set in the fund documents, since a CIV is deal-specific rather than blind-pool.

A point teams miss: a CIV is not a way to reintroduce the differential economics the December 2024 circular removed from the main fund. It is a parallel, disclosed vehicle for incremental capital, not a side door around pari-passu inside the pooled scheme.

How does the accredited-investor-only (AI-only) AIF framework work?

The AI-only framework, introduced through the SEBI (Alternative Investment Funds) (Third Amendment) Regulations, 2025 notified on 18 November 2025, creates a separate category of AIF or scheme open exclusively to accredited investors, in return for a lighter-touch regulatory regime. The operational guidelines, including how an existing scheme migrates to AI-only status, came in the Circular dated 08 December 2025. The logic is that investors who clear the accreditation bar need less protective regulation, so the regulator can step back.

An existing AIF or scheme launched before the amendment can convert to an AI-only fund or to an LVF, subject to the conditions in the December 2025 circular and after obtaining approval from all investors. That all-investor consent threshold is the friction point. A single non-accredited or unwilling investor blocks the conversion, so managers planning to migrate need to map their investor base and accreditation status well before they file.

The lighter regime is the draw. AI-only funds and LVFs sit outside several requirements that bind ordinary AIFs, which is why this framework reads as the most consequential structural change of the 2024-2025 cycle for managers raising from sophisticated capital. The benefits overlap heavily with the LVF relaxations covered next.

What relaxations did Large Value Funds receive?

Large Value Funds for Accredited Investors received the most generous treatment in the 2024-2025 cycle. The Third Amendment, 2025 lowered the minimum investment for an LVF from ₹70 crore to ₹25 crore, widening the pool of investors who qualify. LVFs are also exempt from the standard Private Placement Memorandum format and from the mandatory PPM audit that other AIF categories must complete, and, as noted earlier, they can offer differential rights with disclosure and an investor waiver.

Large Value Fund treatment after the Third Amendment, 2025

Requirement	Standard AIF	Large Value Fund
Minimum investor commitment	₹1 crore (Cat I and II)	₹25 crore (reduced from ₹70 crore)
Standard PPM format	Mandatory	Not required
Mandatory PPM audit	Mandatory	Not required
Pari-passu rights	Required	Exemption available with waiver

For a manager, the LVF route is now materially more accessible than it was. Dropping the ticket to ₹25 crore brings family offices and large single LPs into reach that the ₹70 crore floor excluded. The trade-off is that the investor must genuinely qualify as accredited, and the reduced disclosure means the fund documents carry more weight, since there is no standard PPM safety net behind them.

What other operational changes came through in 2024-2025?

Beyond the headline reforms, SEBI made several operational changes that reduce day-to-day friction. A dissolution period was introduced through the Second Amendment, 2024 (Circular dated 26 April 2024), allowing an AIF to wind down unliquidated investments in an orderly way after the liquidation period ends, rather than being stuck. SEBI later set out the filing requirements and the conditions for in-specie distribution of unliquidated investments, with such distributions, other than mandatory in-specie distribution, needing approval from at least 75 per cent of investors by value. In August 2024, SEBI allowed Category I and Category II AIFs to borrow for up to 30 days to meet temporary shortfalls and operating needs, subject to a limit on frequency and a cap tied to investible funds.

SEBI also cut compliance cost on PPM changes. Certain amendments to the PPM, including changes to fund size, commitment period, the key investment team, key management personnel, and reductions in fees or costs charged to the fund, no longer need to be routed through a merchant banker and can be filed directly with SEBI. Contact-detail changes for the AIF, sponsor, manager, trustee, custodian, auditor, RTA and legal advisor are similarly exempt from merchant banker filing.

One cross-regulator point belongs here. The Reserve Bank of India (RBI) notified the Reserve Bank of India (Investment in AIF) Directions, 2025 on 29 July 2025, superseding its earlier circulars of 19 December 2023 and 27 March 2024. Funds with regulated lenders as investors should read the SEBI changes alongside these RBI Directions, since the two regimes now interact on investor diligence.

What changed for AIFs in early 2026?

The reform cycle did not stop at the end of 2025. The most consequential 2026 change for a compliance team is the revised regulatory reporting framework introduced through the Circular dated 04 March 2026. It replaces the old, data-heavy quarterly reporting regime with a two-part structure: a detailed Annual Activity Report covering investment strategy, sectoral allocation, investor composition, performance, valuation practices, risk management and compliance, plus a slimmer quarterly filing limited to what SEBI needs for ongoing monitoring. The first Annual Activity Report is due by 31 May 2026 for the financial year ending March 2026.

For a manager, this is a real change to the reporting calendar, not a formatting tweak. Teams that built quarterly processes around the old detailed format need to rebuild data capture around the annual report and pare back the quarterly submission. The reconciliation point remains the same: what is reported has to line up with the Compliance Test Report and the holdings record.

Two further 2026 items round out the picture. The SEBI (Alternative Investment Funds) (Amendment) Regulations, 2026 introduced a new sub-regulation 10A allowing a fund to be classified as an inoperative fund subject to conditions, reduced the threshold under Regulation 10(c) from ₹2 lakh to ₹1,000, and modified Regulation 29 to give more flexibility on distribution of proceeds subject to conditions SEBI may specify. Separately, the Circular dated 06 February 2026 added a requirement to report the net asset value of AIF units to depositories, building on the dematerialisation regime so that the depository infrastructure carries valuation data alongside holding records. A fund that already sorted its demat position now has a NAV-reporting step to add.

How does the CSCRF cybersecurity framework apply to AIFs?

The Cybersecurity and Cyber Resilience Framework (CSCRF), issued through the SEBI Circular dated 20 August 2024, brought AIFs into a single, standards-based cybersecurity regime for the first time, replacing the patchwork of earlier sector circulars. It sets out cyber resiliency goals (anticipate, withstand, contain, recover, evolve) and obligations such as constituting an IT committee, obtaining ISO 27001 certification, and running vulnerability assessment and penetration testing. AIFs and VCFs had to implement the framework by 30 June 2025, after the original timeline was extended.

The detail that decides how hard this hits is categorisation, and it is assessed at the manager level, not the individual fund. Under the Clarifications Circular dated 30 April 2025, an AIF or VCF manager’s category is set by the combined corpus of all schemes it manages, fixed at the start of each financial year on the previous year’s data. A manager running several sub-threshold funds whose combined corpus crosses a category line is treated as the higher category for every fund, which surprises managers who assume each fund is judged alone.

The April 2025 clarifications also delivered real relief for smaller managers. Managers classified as self-certification regulated entities with a client base of fewer than 100 are exempt from the mandatory Market-SOC (M-SOC) requirement, the 24×7 security operations centre that is the most expensive part of the framework. They comply through self-certification on a SEBI-prescribed format instead. For a sub-100-client venture or growth manager, this is the difference between a manageable compliance task and a disproportionate cost. The thresholds were further refined through the Circular dated 28 August 2025, so a manager near a category boundary should confirm its current classification each financial year.

What is the NISM certification mandate for AIF key personnel?

SEBI made professional certification a registration condition for AIF managers. Through an amendment to Regulation 4(g)(i) of the AIF Regulations and the SEBI (Certification of Associated Persons in the Securities Markets) Regulations, 2007, at least one key personnel in the manager’s key investment team must hold a valid certification from the National Institute of Securities Markets (NISM). The requirement came into force on 10 May 2024 and applied immediately to all registration applications and scheme launches filed after that date.

The certification options widened in 2025. Originally the route was the NISM Series-XIX-C: Alternative Investment Fund Managers Certification Examination, common to all categories. The gazette notification dated 25 June 2025 added category-specific alternatives: Series-XIX-C or the newer Series-XIX-D for Category I and Category II AIFs, and Series-XIX-C or Series-XIX-E for Category III AIFs. The certificate is valid for three years and must be renewed before expiry to keep the manager compliant.

For existing schemes, the compliance deadline ran to 31 July 2025, extended from 09 May 2025 through the Circular dated 13 May 2025 (SEBI/HO/AFD/AFD-PoD-1/P/CIR/2025/066) and reiterated in the June 2025 notification. The trustee or sponsor is responsible for confirming compliance and recording it in the Compliance Test Report. A manager whose certified key person leaves, or whose certificate lapses without renewal, falls out of compliance even if it cleared the original deadline, so this is a standing obligation rather than a one-time tick.

Common mistakes that cost AIF managers time and money

Managers tend to trip on the same points when absorbing the 2024-2025 changes. Each of these is avoidable with a documented process.

• Treating the circulars as separate events. The pro-rata rule and the LVF differential-rights exemption are two halves of one design. Reading them in isolation leads managers to either over-restrict a legitimate LVF or wrongly assume a standard scheme can still offer priority economics. Map them together.
• Missing the 01 July 2025 demat trigger on new investments. Teams that planned around the older unit-dematerialisation deadlines assumed the work was done. The investment-side mandate is separate, and a new cheque into a company without an ISIN cannot close in compliant form.
• Assuming the pre-July exemption covers control positions. Where the fund controls the investee company under Regulation 2(1)(f), the pre-01 July 2025 exemption does not apply, and legacy holdings had to be dematerialised on SEBI’s timeline. Funds with board control on older portfolio companies are most exposed.
• Forgetting all-investor consent for AI-only conversion. Migrating an existing scheme to AI-only or LVF status needs approval from every investor under the Circular dated 08 December 2025. Starting the legal work before checking investor accreditation and willingness wastes a filing cycle.
• Routing routine PPM changes through a merchant banker. Several PPM amendments can now be filed directly with SEBI. Continuing to pay for merchant banker filing on exempt changes is a straight cost leakage.
• Judging CSCRF category by a single fund. A manager’s cybersecurity category is set by the combined corpus of all schemes it runs, not by each fund alone. A house with several sub-threshold funds can find the combined number pushes it into a higher category, with the M-SOC requirement attached, when each fund on its own looked exempt.
• Running 2026 reporting on the old quarterly template. The Circular dated 04 March 2026 moved AIFs to an Annual Activity Report with a slimmer quarterly filing, the first annual report due 31 May 2026 for FY 2025-26. Continuing to capture data on the old detailed quarterly format means rebuilding the process under deadline pressure rather than ahead of it.

Case study

Situation: A Category II growth fund based in Mumbai, mid-deployment, with two anchor LPs holding negotiated priority distribution terms agreed before the December 2024 circular.

Challenge: The legacy side letters breached the new pari-passu rule, an incoming portfolio investment needed demat treatment under the 01 July 2025 trigger, and the manager wanted to explore LVF migration for a future scheme.

What Treelife did: Reviewed every side letter against Regulation 20(21) and 20(22), restructured the priority terms into a compliant model, built a demat check into the diligence template, and mapped investor accreditation to test LVF feasibility at the reduced ₹25 crore floor.

Outcome: The fund closed its pending investment on schedule in demat form, brought existing investor terms into compliance ahead of its next Compliance Test Report, and shortlisted three LPs who qualified for a planned LVF scheme.

Frequently asked questions

Q: Which SEBI circular governs pro-rata rights for AIF investors?
A: The Circular dated 13 December 2024, numbered SEBI/HO/AFD/AFD-POD-1/P/CIR/2024/175. It implemented the Fifth Amendment, 2024, which inserted sub-regulations 21 and 22 into Regulation 20 of the AIF Regulations, mandating pro-rata rights and pari-passu treatment with limited exceptions.

Q: When must AIF investments be held in dematerialised form?
A: Any investment made by an AIF on or after 01 July 2025 must be held in demat form. Investments made before that date are exempt, except where the investee company is legally required to dematerialise or where the AIF controls the company under Regulation 2(1)(f).

Q: What is the new AIF reporting framework from March 2026?
A: The Circular dated 04 March 2026 replaced the old detailed quarterly reporting regime with an Annual Activity Report plus a slimmer quarterly filing. The first Annual Activity Report is due by 31 May 2026 for the financial year ending March 2026, so managers need to rebuild data capture around the annual report rather than the old quarterly format.

Q: How much does AIF compliance advisory typically cost?
A: Advisory on these changes is usually scoped as a fixed-fee review of fund documents and side letters, plus an ongoing retainer for the Compliance Test Report and PPM filings. Cost depends on the number of schemes and the volume of legacy side letters to be unwound, not on fund size alone.

Q: What is the minimum investment for a Large Value Fund now?
A: The Third Amendment, 2025 reduced the LVF minimum from ₹70 crore to ₹25 crore per accredited investor, widening the set of family offices and large single LPs that qualify.

Q: Can an existing AIF scheme convert to an accredited-investor-only fund?
A: Yes, subject to the conditions in the Circular dated 08 December 2025 and approval from all investors in the scheme. The all-investor consent requirement is usually the binding constraint, so investor accreditation should be checked before filing.

Q: What documents need to change after the pro-rata circular?
A: Side letters, the contribution agreement and the PPM are the three documents to review. Priority distribution terms must come out for standard schemes, and any permitted exception under Regulation 20(21) must be recorded in writing.

Q: Do these SEBI changes apply to GIFT City AIFs?
A: AIFs set up in GIFT City are regulated by the International Financial Services Centres Authority (IFSCA) rather than directly by these SEBI circulars, so the framework differs. Managers running both domestic and GIFT City vehicles should not assume the SEBI position carries across.

Q: What happens if a fund cannot meet the dematerialisation requirement on a new deal?
A: The investment cannot close in compliant form until the investee company’s securities are available in demat. In practice the deal stalls while the company obtains an ISIN, which is why the check belongs at term sheet stage, not closing.

Q: How do the RBI Investment in AIF Directions, 2025 interact with the SEBI changes?
A: The RBI Directions notified on 29 July 2025 govern regulated lenders investing in AIFs and supersede the earlier RBI circulars of December 2023 and March 2024. Funds with bank or NBFC investors must read the SEBI investor-rights and diligence changes alongside these Directions.

Q: Which PPM changes can now be filed directly with SEBI?
A: Changes to fund size, commitment period, the key investment team, key management personnel, reductions in fees or costs, and contact details of service providers can be filed directly, without routing through a merchant banker.

Q: Does the co-investment vehicle let large LPs negotiate special terms?
A: No. The CIV is a disclosed, deal-specific route for accredited investors to add capital alongside the AIF. It is not a way to reintroduce the priority economics the December 2024 circular removed from the pooled scheme.

Q: Which NISM certification must an AIF manager’s key personnel hold?
A: At least one key personnel in the manager’s investment team must pass a NISM examination under Regulation 4(g)(i). Category I and II AIFs can use Series-XIX-C or Series-XIX-D, and Category III can use Series-XIX-C or Series-XIX-E, per the notification dated 25 June 2025. The certificate is valid for three years and must be renewed before expiry. For existing schemes the deadline was 31 July 2025.

Q: Does the CSCRF cybersecurity framework apply to my AIF?
A: Yes. The CSCRF issued on 20 August 2024 brought AIFs into SEBI’s cybersecurity regime, with implementation due by 30 June 2025. Your category is set by the combined corpus of all schemes your house manages, fixed at the start of the financial year. Managers that are self-certification entities with fewer than 100 clients are exempt from the mandatory Market-SOC requirement.

Q: What is the Compliance Test Report and where does it sit in all this?
A: It is the manager’s annual self-assessment of compliance under Chapter 15 of the Master Circular for AIFs dated 07 May 2024. Most of the 2024-2025 changes, from pro-rata breaches to demat status to certification, eventually have to reconcile in this report.

Where the 2024-2025 changes leave AIF managers

The SEBI AIF circular 2024-2025 key changes in India are best understood as a single negotiation between the regulator and the industry. SEBI removed the informal flexibility that let large investors cut side deals inside a pooled fund, and gave funds dealing only with accredited or large investors a lighter regime in return. That cycle has carried into 2026, with the revised reporting framework due for its first Annual Activity Report by 31 May 2026 and the 2026 amendment regulations adding an inoperative fund route. For a manager, the work is operational, not theoretical: review side letters against the pro-rata rule, build the demat check into deal diligence, decide whether an AI-only or LVF structure fits the next raise, rebuild reporting around the annual report, and reconcile all of it in the Compliance Test Report. The funds that absorbed these changes cleanly treated them as one connected system, which is exactly how the regulator built them.

Regulatory references

• SEBI (Alternative Investment Funds) Regulations, 2012, Regulation 20(21) and 20(22), Regulation 2(1)(f), Regulation 4(g)(i), Regulation 10(aa)
• SEBI (Alternative Investment Funds) (Second Amendment) Regulations, 2024 (Circular dated 26 April 2024, dissolution period)
• SEBI (Alternative Investment Funds) (Fifth Amendment) Regulations, 2024, notified 18 November 2024 (pro-rata and pari-passu)
• SEBI Circular No. SEBI/HO/AFD/AFD-POD-1/P/CIR/2024/175, dated 13 December 2024 (pro-rata and pari-passu rights)
• SEBI Circular No. SEBI/HO/AFD/PoD/CIR/2024/5, dated 12 January 2024 (dematerialisation of investments and custodian appointment)
• Master Circular for AIFs dated 07 May 2024, Chapter 15 (Compliance Test Report) and Chapter 21 (dematerialisation), as modified February 2025
• SEBI (Alternative Investment Funds) (Second Amendment) Regulations, 2025 (co-investment vehicle)
• SEBI (Alternative Investment Funds) (Third Amendment) Regulations, 2025, notified 18 November 2025 (AI-only funds and LVF relaxations)
• SEBI Circular dated 08 December 2025 (operational guidelines for migration to AI-only and LVF)
• SEBI (Certification of Associated Persons in the Securities Markets) Regulations, 2007, read with Regulation 4(g)(i) of the AIF Regulations (NISM certification); NISM Series-XIX-C, XIX-D and XIX-E examinations
• SEBI Circular No. SEBI/HO/AFD/AFD-PoD-1/P/CIR/2025/066, dated 13 May 2025 (certification timeline extension), gazette notification dated 25 June 2025
• SEBI Cybersecurity and Cyber Resilience Framework (CSCRF), Circular dated 20 August 2024, as clarified by Circulars dated 30 April 2025 and 28 August 2025 (AIF implementation by 30 June 2025)
• SEBI valuation norms for AIF portfolios (2023), aligning most securities with the SEBI (Mutual Funds) Regulations, 1996
• Standard Setting Forum for AIFs (SFA) implementation standards on pro-rata and pari-passu rights
• Reserve Bank of India (Investment in AIF) Directions, 2025, notified 29 July 2025
• SEBI Circular dated 06 February 2026 (reporting of NAV of AIF units to depositories)
• SEBI Circular dated 04 March 2026 (revised regulatory reporting framework, first Annual Activity Report due 31 May 2026 for FY 2025-26)
• SEBI (Alternative Investment Funds) (Amendment) Regulations, 2026 (inoperative fund classification under sub-regulation 10A, Regulation 10(c) threshold reduced to ₹1,000, Regulation 29 on distribution of proceeds)

External sources

• Securities and Exchange Board of India
• Reserve Bank of India
• IFSCA