Key Decisions From The IFSCA Meeting Held On The 22nd December 2025

At its 26th meeting, the International Financial Services Centres Authority ('IFSCA') approved a series of regulatory measures aimed at enhancing the ease of doing business in GIFT-IFSC while continuing to safeguard investor interests. The said amendments and regulatory measures were announced by IFSCA pursuant to a press release dated 23rd December 2025. The key decisions are summarised in this alert.

IFSCA (FUND MANAGEMENT) REGULATIONS, 2025

Eligibility Criteria for Key Managerial Personnel ('KMPs'):

• IFSCA (Fund Management) Regulations, 2025 ('FME Regulations') provide a minimum experience of 5 years in related activities in securities market or financial products for the Principal Officer, Compliance Officer and other KMP.
• Alongside the aforesaid existing criteria, a certification-based alternative eligibility criterion with reduced work experience for KMP appointment shall be introduced.
• The scope of eligible KMP work experience will be expanded to include experience in consulting / advisory firms, private or public companies where nature of work comparable to that of financial institutions – such expansion shall be applicable to both existing and alternative criteria.

Validity of Private Placement Memorandum ('PPM') of Schemes

• The FME Regulations currently provide that a PPM shall be valid for 12 months and a one-time extension of 6 months may be availed by paying 50% of the scheme fees.
• It is now proposed to permit multiple 6-month extensions for Venture Capital and Restricted Schemes, subject to prescribed fees and timely filing during the validity of the PPM. OVERVIEW
• Additionally, where the PPM has expired, a one-time 3-month extension shall be allowed, including for open-ended schemes that have raised USD 1 Mn but not achieved the minimum corpus of USD 3 Mn within 12 months

Appointment of Custodian registered with IFSCA

• FMEs required to appoint an IFSC-based custodian shall be granted a 24-month migration window, subject to certain conditions.

IFSCA (GLOBAL-IN-HOUSE CENTRE) REGULATIONS, 2025

New IFSCA (GIC) Regulations, 2025 to be introduced, salient features of which include:

• Financial Institution Groups ('FIGs') permitted to set up Global-InHouse Centre ('GIC') units in GIFT IFSC directly or via third-party service providers to serve group entities.
• Multiple operating models recognised, including Captive Centre, Shared Services Centre, BOT, JV, Hybrid, and others, allowing flexibility in structuring.
• GIC units permitted may provide services to Indian group entities up to 10% of total annual revenue.
• Offshore FIGs serving India can establish GICs in GIFT IFSC to cater to their Indian group entities.
• The 20% cap on transfer of employees to GIFT-IFSC eased.
• Third-party service providers shall be permitted to support GIC setup and operations, including co-delivery models.

IFSCA (BOOK KEEPING, ACCOUNTING, TAXATION AND FINANCIAL CRIME COMPLIANCE SERVICES) REGULATIONS, 2025

• Requirement of minimum office space of 60 sq. ft per employee to be removed

IFSCA (CAPITAL MARKET INTERMEDIARY) REGULATIONS, 2025

Eligibility criteria for Principal Officer and Compliance Officer

• Postgraduate degree in STEM and fintech are now recognized as eligible qualification for Principal and Compliance Officers
• The minimum experience for a graduate to act as a principal/compliance officer has been reduced from 10 to 5 years

Capital Market Intermediaries ('CMI') with multiple registration

• A capital market intermediary having multiple registrations such as broker dealer, investment adviser, research entity, clearing member, DP, custodian and distributor may have the same Principal Officer, provided a separate vertical head is appointed for "Distribution" activities.

Liquid Net Worth

• Base minimum capital and interest-free deposits with Stock Exchanges and Clearing Corporations shall be considered as liquid net worth.
• Margins maintained for activities on IFSC stock exchange / Global Access activities shall be considered as liquid net worth.
• Liabilities shall be excluded while computing liquid net worth, in accordance with the CMI Regulations' definition of net worth

Net worth requirement for custodians