Compilation of Regulatory Updates in Relation to AIFs

April 30, 2026: This circular introduces a fast-track mechanism for the launch of AIF schemes in respect of private placement memoranda (“PPMs”) filed by angel funds and schemes other than large value funds (“LVFs”), as an ease of doing business measure. Key provisions include: 

1. AIFs may proceed with the launch of new non-LVF schemes and circulate the PPM to investors 30 days after filing with SEBI, unless otherwise advised, and in case of first schemes, from the date of SEBI registration or 30 days after filing, whichever is later; and comments made by SEBI should be complied with before launching the scheme; 
2. the first close must be declared within 12 months from the date the AIF becomes eligible to launch the scheme (which modifies Para 2.3.1 of the Master Circular for AIFs); 
3. the merchant banker and the manager of the AIF are jointly responsible for accuracy and completeness of all PPM disclosures for non-LVF schemes; 
4. PPMs of non-LVF schemes must be filed on the SEBI Intermediary Portal along with prescribed documents; and 
5. a mandatory disclaimer clause must be included in PPMs of all non-LVF schemes clarifying that SEBI does not approve or assume responsibility for the PPM disclosures.

April 16, 2026: This notification amends the AIF Regulations to, inter alia: 

1. minimum investment threshold for social impact funds reduced from INR 2 lakhs to INR 1,000; 
2. SEBI may specify conditions for distribution of liquidated assets during winding up; and 
3. a new sub-regulation 10A is inserted in Regulation 29, providing that an AIF may be tagged as an “inoperative fund” in such manner and subject to conditions as may be specified by SEBI from time to time. 

March 4, 2026: The circular revises the reporting framework under Regulation 28 of the AIF Regulations and the Master Circular for AIFs. It replaces the quarterly activity reporting with a comprehensive annual activity report (due within 30 days from the end of financial year) along with a revised limited quarterly report (from June 2026 onwards), both to be filed on the SEBI Intermediary Portal.

February 26, 2026: This circular mandates that all persons regulated by SEBI (including AIFs) and their agents shall prominently disclose their registered name and registration number on the home page of their social media handles as well as at the beginning of each video/content related to the securities market uploaded by them. For entities with multiple registrations, a web link directing to their website listing all SEBI registered names and registration numbers shall be provided. 

February 12, 2026: This circular provides clarifications on provisions relating to insurers’ investments in AIFs under paragraph 1.5 of the Master Circular on Actuarial, Finance and Investment Functions of Insurers dated May 17, 2024. It clarifies that compliance with Section 27E of the Insurance Act, 1938 may be achieved through “Excusal Rights” as per SEBI Circular dated April 10, 2023, subject to conditions.

February 6, 2026: This circular mandates operational enhancements for valuation and net asset value (“NAV”) dissemination in AIFs, particularly in light of compulsory dematerialization of AIF units. It requires AIFs, through registrars and transfer agents, to upload the latest NAV for each ISIN in the depository system within prescribed timelines (by May 1, 2026 or within 30 days of valuation), with clear responsibility placed on the AIF manager. Further, it also sets obligations for depositories to build infrastructure, display NAV with disclaimers, and amend bye-laws accordingly.

January 9, 2026: This circular provides operational relaxations under the accredited investor framework, allowing AIF managers to onboard investors and execute contribution agreements pending accreditation, subject to conditions (no corpus inclusion and no fund receipt until certification). It also simplifies net-worth certification requirements by removing the need for a detailed breakdown and making disclosure of exact net worth optional. 

December 30, 2025: This circular mandates that compliance officers of AIFs must obtain the NISM Series-III-C (Securities Intermediaries Compliance – Fund) certification to meet eligibility requirements under the AIF Regulations. It requires that from January 1, 2027, only certified individuals can be appointed or continue as compliance officers, with responsibility on managers to ensure compliance. 

December 10, 2025: This master circular prescribes investment guidelines for NPS Tier-I and Tier-II accounts in the Non-Government Sector. It permits pension fund investments in SEBI-regulated debt-oriented AIFs (Category I and Category II only) under Scheme/Asset Class C and equity-oriented AIFs (Category I and Category II only) under Scheme/Asset Class E, subject to conditions. 

December 10, 2025: This master circular prescribes investment guidelines for UPS/NPS/APY Schemes in the Government Sector. It permits pension fund investments in SEBI-regulated AIFs (Category I and Category II only) under the asset-backed, trust-structured and miscellaneous investments category, subject to conditions. 

December 8, 2025: This circular introduces accredited investors-only (“AI-only”) schemes and expands flexibilities for LVFs to enhance ease of doing business. It allows new and existing AIF schemes to operate as AI-only schemes or LVFs (subject to investor consent), mandates naming conventions, and provides operational relaxations including exemption for LVFs from standard PPM template and audit requirements. It also clarifies treatment of accredited investor status, reporting obligations and compliance requirements.

December 8, 2025: This circular provides clarifications on earlier digital accessibility circulars applicable to all regulated entities, including AIFs. Key provisions include: 

1. the “Investors’ Right to have digital accessibility” will be included in the respective Investor Charters; 
2. regulated entities shall submit a status of their readiness and compliance with the accessibility requirements for each of their digital platforms by March 31, 2026 to the specified reporting authorities (AIFs are to report directly to SEBI’s Alternative Investment Fund Department); 
3. investors may lodge accessibility-related complaints against regulated entities on SCORES under the “Accessibility” complaint category; and 
4. all regulated entities shall conduct periodic accessibility audits of their digital platforms through certified accessibility professionals. 

November 18, 2025: This notification amends the AIF Regulations to, inter alia: 

1. introduce the definition of “Accredited Investors only fund” (i.e., an AIF or scheme in which each investor, other than the manager, sponsor, employees or directors, is an accredited investor), with a proviso allowing pre-existing AIFs/schemes to convert subject to SEBI specified conditions, and an explanation that “Accredited Investors only fund” includes “large value fund for accredited investors”; 
2. reduce the minimum investment threshold for “large value fund for accredited investors” from INR 70 crores to INR 25 crores, with a proviso permitting pre-existing AIFs/schemes to convert; 
3. exclude the eligibility requirement under Regulation 4(g)(i) for AI- only funds; 
4. exclude accredited investors from the investor count under Regulation 10(f); 
5. extending the relaxations on tenure extension and differential investor rights that were previously available only to LVFs for accredited investors to AI-only funds; 
6. exclude Regulation 20(8), which governs valuation and pricing of units, for LVFs for accredited investors; and 
7. provide that in case of AI-only funds, the responsibilities and obligations of the trustee under the AIF Regulations shall be carried out by the manager. 

October 15, 2025: This circular extends the timeline for existing angel funds to implement a defined investment allocation methodology in their PPMs from October 15, 2025 to January 31, 2026, based on industry representations. Accordingly, all investments made on or after February 1, 2026 must comply with the disclosed allocation methodology.