Securities and Exchange Board of India (“SEBI”) issues Compliance reporting formats for Specialized Investment Funds (“SIFs”) .
SEBI vide circular no. HO/24/13/12(4)2025-IMD-POD-1/I/2062/2026 dated 08.01.2026, issued compliance reporting formats for SIFs under the mutual fund regulatory framework.
Key Takeaways:
- SEBI has clarified that SIF reporting must align with the existing compliance regime for mutual funds. All reporting requirements under the SEBI (Mutual Funds) Regulations, 1996, including the Master Circular for Mutual Funds, now apply uniformly to SIFs.
- The Compliance Test Report (“CTR”) has been amended to include a new Part IV dedicated to SIF-specific disclosures. Asset Management Companies (“AMCs”) are required to report detailed compliance checks relating to key investment parameters such as minimum investment thresholds, strategy features, limits on fees and expenses, and investment restrictions.
- SEBI has introduced Clause 72A in the Half Yealy Trustee Report (“HYTR”) requiring trustees to formally certify the AMCs compliance, including the adequacy of expertise and risk controls, adherence to investment and disclosure norms, and compliance with branding, advertising and investor protection norms.
- SEBI has embedded SIF compliance within existing mutual fund formats (CTR and HYTR) to ensure consistency and avoid duplication.
- The new formats are effective from 08.01.2026 with no transitional period, requiring immediate implementation by all AMCs and trustees managing SIFs.
Reserve Bank of India (“RBI”) notifies Foreign Exchange Management (Guarantees) Regulations, 2026.
RBI vide notification no. FEMA/8(R)/2026-RB dated 06.01.2026 notified the Foreign Exchange Management (Guarantees) Regulations, 2026 (“Regulations 2026”) to supersede the Foreign Exchange Management (Guarantees) Regulations, 2000.
Key Takeaways:
- The regulations apply to all guarantees, including counter-guarantees, where one or more parties are non-residents. Guarantees in foreign exchange transactions must be compliant with these regulations, except where specific exemptions apply under FEMA or other RBI rules.
- Guarantees involving cross-border residents are generally prohibitedunless permitted under specific regulations or with thegeneral or special permission of the RBI, ensuring that international exposure is monitored and regulated.
- Guarantees covered under the Regulations 2026 shall be reported by: (a) the surety, where the surety is a person resident in India; (b) the principal debtor (who arranged the guarantee), where the surety is a person resident outside India; or (c) the creditor, where both the surety and principal debtor are persons resident outside India or where the creditor has arranged the guarantee.
- A person resident in India who has delayed reporting may regularise the delay by completing the reporting and/or paying the applicable Late Submission Fee (“LSF”). The LSF is calculated as INR 7,500 + (0.025% × Amount Involved × Number of Years of delay) (rounded up to the nearest hundred).
- The Regulations 2026 have come into force on the date of publication in the Official Gazette i.e., 06.01.2026.
Insolvency and Bankruptcy Board of India (“IBBI”) launches Revised Liquidation Reporting Forms to streamline compliance.
The IBBI vide circular no. IBBI/LIQ/91/2026 dated 05.01.2026 has amended the IBBI (Liquidation Process) Regulations, 2016 which provides that the insolvency professionals to file the Forms, along with enclosures thereto, as notified by the Board, from time to time, on an electronic platform of the Board as per the timelines stipulated for each form.
Key Takeaways:
- The revised form framework comprises of Forms LIQ-1, LIQ-2, LIQ-3, and LIQ-4 covering the entire liquidation lifecycle: from commencement and public announcement (LIQ-1), quarterly progress (LIQ-2), pre-dissolution reporting (LIQ-3), to final closure reporting (LIQ-4).
- All existing liquidation forms are discontinued effective 01.01.2026, and only the revised forms will be accepted for filings related to liquidation proceedings. LIQ-2 will be enabled on the portal from01.02.2026, while the other forms are available on the IBBI website.
- IBBI has waived penalties for delayed filings during the initial quarter (January – March 2026).
- All subsequent filings shall be made only through the revised forms by the Insolvency Professional (“IP”) who is in office as Liquidator as on the last date of the month preceding the month in which the form is due to be filed.
- Failure by an IP to comply with the applicable provisions of the IBC and the Regulations may attract liability for (a) non-filing of prescribed forms along with requisite information and records, and/or (b) submission of inaccurate or incomplete information or records.
Securities and Exchange Board of India (“SEBI”) simplifies the requirements for grant of accreditation to investors.
SEBI vide circular no. HO/19/34/11(9)2025-AFD-POD1/I/2286/2026 dated 09.01.2026 has introduced simplifications to the accreditation requirements for investors under the SEBI (Alternative Investment Funds) Regulations, 2012 (“AIF Regulations”).
Key Takeaways:
- Investment managers may now finalize and execute contribution agreements with investors and initiate related operational procedures based on their assessment of the investor’s eligibility, even while accreditation from an accreditation agency is pending.
- Any commitment made by such an investor shall not be counted towards the scheme’s corpus until the official accreditation is received. Additionally, funds from the investor can only be accepted after the accreditation certificate is issued, ensuring prudential norms tied to corpus thresholds remain intact.
- The requirement to submit a detailed break-up of net worth as an annexure to the net-worth certificate has been eliminated.
- Trustees, sponsors, or managers of AIFs must ensure that the CTR prepared under Chapter 15 of the Master Circular for AIFs includes compliance with the provisions of this AIF Circular.
- The simplified accreditation framework is applicable immediately upon issuance of the circular.
