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

Compliance obligations begin from the date of SEBI registration of the AIF, not from First Close. The first quarterly activity report is due within 15 calendar days from the end of the calendar quarter in which registration occurred. A fund registered in November and hitting First Close in February has already missed a quarterly report if it has not filed.

What are the quarterly filing deadlines for AIFs in FY 2026-27?

Under Para 15.1.1 of the SEBI Master Circular dated 7 May 2024, the four quarterly activity report deadlines for FY 2026-27 are: Q1 (April to June 2026) by 15 July 2026, Q2 (July to September 2026) by 15 October 2026, Q3 (October to December 2026) by 15 January 2027, and Q4 (January to March 2027) by 15 April 2027. These deadlines apply to Category I, II, and III AIFs.

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

Yes. Category III AIFs must file a quarterly leverage report and AIF Data Repository (ADR) submissions in addition to the standard quarterly activity report applicable to all categories. The ADR deadline is 7 days from quarter-end, which is tighter than the standard 15-day deadline. Category III also carries daily leverage reporting to the custodian, monthly NAV disclosure for open-ended schemes, and quarterly investor reports within 60 days of each quarter-end, compared to an annual investor report for Category I and II.

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

The Compliance Test Report (CTR) is an annual self-assessment prepared by the Manager of the AIF confirming compliance with the SEBI (Alternative Investment Funds) Regulations, 2012 and all applicable SEBI circulars. Under Para 15.2.2 of the 2024 Master Circular, it must be submitted to the Trustee and Sponsor within 30 days of financial year-end, that is by 30 April each year. As of FY 2026-27, the CTR must also expressly confirm that the Compliance Officer holds or is on track to obtain NISM Series-III-C certification before 1 January 2027.

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

Under SEBI Circular No. HO/19/(8)2025-AFD-POD1/I/1266/2025 dated 30 December 2025, the Compliance Officer of an AIF Manager must obtain NISM Series-III-C: Securities Intermediaries Compliance (Fund) Certification before 1 January 2027. From that date, only persons who have obtained this certification can be appointed or continue to act as Compliance Officers for AIF Managers. The NISM Series-III-C examination became available from 24 November 2025.

What is the PPM compliance audit for an AIF and how often must it be conducted?

The PPM compliance audit verifies that the fund's actual operations are consistent with the terms of the Private Placement Memorandum filed with SEBI. Under Para 2.4.2 of the 2024 Master Circular, it must be completed within six months of the financial year-end, that is by 30 September each year. It can be conducted by an internal or external auditor or legal professional. The audit findings must be communicated to the Trustee, Board of Directors or Designated Partners of the Manager, and SEBI. This requirement does not apply to Angel Funds or Large Value Funds where each investor has provided a waiver.

Are AIF units required to be held in dematerialised form?

Yes. Units issued by an AIF from November 2023 onwards must be in dematerialised form only. Portfolio investments held by the AIF must be in dematerialised form from October 2024 onwards, subject to specific exemptions for investments made prior to that date. Investors who have not provided demat account details are covered under the Aggregate Escrow Demat Account mechanism, which is a transitional measure under the 2024 Master Circular and not a permanent compliance solution.

What triggers a SEBI filing for a PPM amendment?

Material changes to the PPM require SEBI intimation through a Merchant Banker. Non-material changes can be notified directly to SEBI without routing through a Merchant Banker. The 2024 Master Circular relaxed the earlier requirement for all PPM changes to go through a Merchant Banker; only material changes now require it. PPM changes must be reported to SEBI and investors on a consolidated basis within one month of the end of each financial year under Para 2.5.2 of the 2024 Master Circular.

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

The Manager must file Form InVI with the RBI through the FIRMS portal within 30 days of issuing units to any person resident outside India, under Rule 4(10) of the Foreign Exchange Management (Mode of Payment and Reporting of Non-Debt Instruments) Regulations, 2019. Additionally, the AIF must file a Foreign Liabilities and Assets (FLA) return with the RBI annually by 15 July, covering all foreign investments received and made in the previous financial year. If the AIF makes downstream investments where the Manager or Sponsor is not Indian owned and controlled, Form DI must also be filed with RBI within 30 days of equity allotment under Rule 4(11)(b). A separate intimation to DPIIT is required within 30 days of the downstream investment under Rule 4(11)(a).

What is the difference between the Compliance Test Report and the Cash Transaction Report, both abbreviated as CTR?

Both are abbreviated as CTR but are entirely separate documents filed with different regulators. The Compliance Test Report under Para 15.2 of the 2024 SEBI Master Circular is an annual SEBI filing prepared by the Manager and submitted to the Trustee and Sponsor by 30 April each year. The Cash Transaction Report under Rule 3(1)(E) of the Prevention of Money-Laundering (Maintenance of Records) Rules, 2005 is a monthly anti-money laundering filing prepared by the Principal Officer of the Manager and submitted to the Financial Intelligence Unit, India (FIU-IND) within 15 days of the succeeding month. AIF compliance teams must maintain both and treat them as entirely separate obligations.

What cybersecurity compliance obligations does an AIF have under SEBI's CSCRF Circular?

SEBI's Cybersecurity and Cyber Resilience Framework Circular dated 20 August 2024 (SEBI/HO/ITD-1/ITD_CSC_EXT/P/CIR/2024/113) requires all AIFs to comply with cybersecurity standards tiered by AUM. Every AIF must maintain a cybersecurity policy, submit a VAPT (Vulnerability Assessment and Penetration Testing) report annually, and conduct a cyber audit with the report submitted to SEBI within one month of completion. AIFs with AUM above Rs. 100 crore must additionally submit a cyber resilience self-assessment using the Cyber Capability Index (CCI). AIFs with AUM above Rs. 500 crore carry additional quarterly obligations including IT committee meetings and threat hunting. AIFs with AUM above Rs. 1,000 crore must conduct cyber audits twice yearly.

Does SEBI's digital accessibility compliance requirement apply to all AIFs?

Yes. Under SEBI's Digital Accessibility Circular (SEBI/HO/ITD1/ITD_VIAP/P/CIR/2025/111), all SEBI-regulated entities including AIFs must conduct annual accessibility audits of their digital platforms in compliance with the Rights of Persons with Disabilities Act, 2016. A compliance report must be submitted to SEBI within 30 days from the end of each financial year, that is by 30 April annually. This applies to any digital platform operated by or on behalf of the AIF, including investor portals and fund reporting dashboards.

What are Form 64C and Form 64D for AIFs and when must they be filed?

Form 64C and Form 64D are pass-through income reporting forms applicable to Category I and Category II AIFs under Section 115UB of the Income Tax Act, 1961. Form 64D is a statement of income distributed during the previous financial year, filed with the Income Tax Department by 15 June of the following year. For FY 2025-26, the due date is 15 June 2026. Form 64C is the same statement furnished to each unit holder by 30 June of the following year. Investors use Form 64C to correctly report their share of AIF income in their personal income tax returns. Category III AIFs are not required to file these forms as they are taxed at the fund level rather than under the pass-through regime.

Does a Category I or II AIF need to disclose borrowings to investors?

Yes. SEBI's Circular dated 19 August 2024 (SEBI/HO/AFD/AFD-POD-1/P/CIR/2024/112) on guidelines for borrowing by Category I and II AIFs requires the Manager to disclose details of amount borrowed, terms of borrowing, and repayment to investors on a periodic basis as per the terms of the investor agreement. This obligation is triggered when the AIF has borrowed funds as permitted under the SEBI (Alternative Investment Funds) Regulations, 2012.

What is an AIF Liquidation Scheme and what compliance obligations does it create?

A Liquidation Scheme is a mechanism under Chapter 23 of the 2024 Master Circular that allows an AIF which has not fully liquidated its portfolio by the end of its tenure (including extended tenure) to deal with residual unliquidated investments. It requires the consent of at least 75% of investors by value. Once activated, the Manager must report compliance with Chapter 23 provisions to SEBI on a quarterly basis (Para 23.4.2), report the Liquidation Scheme's performance to the Performance Benchmarking Agency half-yearly (within 45 days from the September half-year end and within 6 months from the March half-year end under Para 23.1.14), and disclose the Liquidation Scheme arrangement in the PPMs of subsequent schemes launched by the Manager.

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

Category I and II AIFs must provide investors with a comprehensive annual report within 180 days from the financial year-end, covering financial information of investee companies and material risks including concentration risk, foreign exchange risk, leverage risk, realisation risk, strategy risk, reputation risk, and ESG risks. Category III AIFs must provide a report with similar content on a quarterly basis, within 60 days of the end of each quarter, under Regulations 22(g) and 22(h) of the SEBI (Alternative Investment Funds) Regulations, 2012. The Category III frequency is four times higher, creating a continuous investor reporting obligation that requires a standing internal workflow.

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

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

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

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May 14,2026

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May 14, 202617:56

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May 14,
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May 14, 2026
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