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The Securities and Exchange Board of India (“SEBI”) under Regulation 28 of the SEBI (Alternative Investment Funds) Regulations, 2012 (“AIF Regulations”) read with Clause 15.1.1 of the SEBI Master Circular for Alternative Investment Funds dated May 7, 2024 (“Master Circular”) requires all Alternative Investment Funds (“AIF”) to submit a report on their activities as an AIF to SEBI on a quarterly basis. Under the pre-existing framework, AIFs were required to submit such reports within 15 (fifteen) calendar days from the end of each quarter, in accordance with the reporting format hosted on the website of the AIF industry associations i.e. the Indian Venture and Alternate Capital Association (“IVCA”) and Equalifi.
Clause 15.1.4 of the Master Circular further provides that the reporting format shall be reviewed periodically to keep pace with the rapidly evolving AIF industry and to support regulatory policy and supervisory objectives. Accordingly, the reporting formats were reviewed to incorporate amendments made to the AIF Regulations and related circulars. Further, to improve ease of doing business, the frequency of reporting by AIFs was also reviewed in consultation with the Standards Forum of AIFs. In this regard, a working group constituted by SEBI on “Ease of Doing Business and Reducing Cost of Compliance” recommended reducing the frequency of regulatory reporting by AIFs.
Pursuant to these developments, on March 4, 2026, SEBI issued a circular (“Circular”) introducing changes to the reporting requirements applicable to AIFs in India. The Circular comes into force with immediate effect.
As per the Circular, the existing reporting framework has been revised as follows:
Introduction of Annual Activity Report
AIFs are now required to submit a comprehensive annual activity report at the end of each financial year. The report is required to be filed online through the SEBI Intermediary Portal (“SI Portal”) within 30 (thirty) calendar days from the end of March of the relevant financial year.
The first such annual activity report will be required to be submitted for the financial year ending March 2026 and must be filed on or before May 31, 2026.
Revised Quarterly Activity Report
AIFs will continue to submit a quarterly activity report, albeit in a revised format. Such report is required to be submitted online through the SI Portal within 15 (fifteen) calendar days from the end of each quarter.
The revised quarterly activity report will apply from the quarter ending June 2026. However, no separate quarterly activity report will be required for the quarter ending March each year, as the annual activity report will capture the relevant data points otherwise required to be reported for that quarter.
Updated Reporting Format
SEBI has also reviewed and updated the reporting formats to incorporate amendments made to the AIF Regulations and related circulars. The revised reporting formats have been made available on the website of the Standards Forum, i.e. IVCA.
By reducing the regulatory reporting compliance by introducing a comprehensive annual activity report and streamlining quarterly framework, the amendments are expected to improve ease of doing business, while maintaining adequate regulatory oversight.
AIFs should note that the first annual activity report will be required to be submitted by May 31, 2026, for the financial year ending March 2026. Further, the revised quarterly activity reporting framework will apply from the quarter ending June 2026. As a practical matter, AIFs may consider reviewing internal compliance processes.
Please find attached a copy of the Circular, here.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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