portfolio management services

SEBI Introduces Framework to Streamline Transfer of Portfolio Management Services

The Securities and Exchange Board of India (“SEBI”) has issued a circular introducing a framework for the transfer of Portfolio Management Service (“PMS”) businesses between registered Portfolio Managers. The framework, effective immediately, requires prior SEBI approval for all transfers, whether within the same group or to an unrelated entity. It sets out clear procedures, timelines, and responsibilities for both transferor and transferee, including requirements for joint applications, client consent, undertakings, and surrender of registration where applicable. The framework provides regulatory clarity and operational flexibility for business reorganizations, group consolidations, and exits in the PMS sector while maintaining investor protection.


CIV scheme

Regulatory Update: Introduction of a New Co-Investment Scheme for AIFs by SEBI

The Securities and Exchange Board of India has introduced a new Co-Investment Vehicle Scheme (“CIV Scheme”) under the AIF Regulations, effective September 9, 2025, allowing Category I and II AIFs to offer co-investment opportunities directly to accredited investors. The CIV Scheme serves as an in-house alternative to the Co-investment PMS route, with clear rules on eligibility, investment limits, governance, and exits. Exemptions from certain AIF requirements provide operational flexibility, while safeguards such as ring-fencing of assets, pro-rata rights, and strict compliance standards ensure investor protection.


Alternative Investment Funds

The RBI’s New Directions on Investments by Regulated Entities in Alternative Investment Funds

In the past few years, the Reserve Bank of India (“RBI”) has issued directions to regulate investments by banks, non-banking financial companies and other regulated entities (collectively, “REs”) in alternative investment funds (“AIFs”). These regulatory measures have been primarily intended to curb evergreening of loans by REs, where REs substitute their direct exposure to debtor companies with indirect exposure by investing in AIFs that, in turn, have investments in such debtor companies.
Recently, on July 29, 2025, the RBI introduced the Reserve Bank of India (Investment in AIF) Directions, 2025 (“New Directions”), which increase regulatory oversight over REs’ investments in AIFs while also relaxing some of the prohibitions of the prior regime. The New Directions will supersede the RBI’s prior circulars on this subject, in relation to new investment commitments made by REs in AIFs. This note analyzes the New Directions, the improvements from the prior regulatory framework and the concerns that remain to be addressed.


infrastructure investment trusts

From Private to Public: SEBI’s New Roadmap for InvIT Conversion

SEBI has proposed reforms to simplify the conversion of private listed InvITs into public ones by removing sponsor lock-ins and minimum contribution requirements, easing post-conversion liquidity norms, and aligning disclosure standards with follow-on offers. The changes aim to reduce compliance, attract investors, and foster InvIT market growth.


Corporate Debt Securities

RBI Eases Investments by FPIs in Corporate Debt Securities

The Reserve Bank of India recently issued a circular onInvestments by Foreign Portfolio Investors in Corporate Debt Securities through the General Route(“RBI Circular”) on May 08, 2025, to withdraw short term investment limits and concentration limits, applicable on investments by FPI in corporate debt securities under the general route. This note highlights the changes to the regulatory framework brought about by the RBI Circular that are intended to provide greater flexibility and ease of investments for FPIs investing in corporate debt securities in India under the general route.


Real Estate Investment Trusts in India

Regulatory Landscape for SM REITs in India

In March 2024, the Securities and Exchange Board of India (“SEBI”) amended the SEBI (Real Estate Investment Trusts) Regulations, 2014, to introduce Small and Medium Real Estate Investment Trusts (“SM REITs”), aiming to regulate fractional ownership platforms (“FOPs”) that offer retail investors access to real estate. This move addresses concerns related to investor protection, regulatory gaps, and operational transparency in FOPs. SM REITs are structured as SEBI-registered trusts and are required to comply with specific eligibility, investment, and governance criteria. This note outlines procedures for registration, scheme launches, and investor safeguards intended to enhance investor confidence, market liquidity, and standardized practices in India’s evolving real estate sector.


ifsca fund management regulations

Regulatory Updates: IFSCA (Fund Management) Regulations, 2025

The International Financial Services Centres Authority (“IFSCA”) has introduced the IFSCA (Fund Management) Regulations, 2025 (“FM Regulations 2025”) to further streamline fund management activities in GIFT-IFSC. The FM Regulations 2025 introduce investor-friendly measures, reduced entry barriers, and increased operational flexibility, while also strengthening investor protection. These regulations aim to foster a business-friendly environment, align with global standards, and reinforce GIFT-IFSC’s position as a global financial hub.


specialized investment fund

Regulatory Landscape for Specialized Investment Fund: A New Asset Class

The Securities and Exchange Board of India (“SEBI”) amended the SEBI (Mutual Funds) Regulations, 1996, to introduce a new asset class, the Specialized Investment Fund, effective December 16, 2024. The amendment aims to bridge the gap between Mutual Funds (“MFs”) and Portfolio Management Services (“PMS”) by offering a product suited for sophisticated investors with a risk-return profile between that of MFs and PMS.