The International Financial Services Centres Authority (IFSCA) has issued an important circular providing relief to Fund Management Entities (FMEs) whose Placement Memorandums (PPMs) have expired.
Under the circular, IFSCA may now consider extending the validity of an expired Placement Memorandum, even where the application for extension is filed after the expiry of its validity period.
Key highlights:
🔹 Expired PPMs can now potentially be extended
FMEs can apply for an extension even after the validity of the Placement Memorandum has expired.
🔹 Extension fees and late fees apply
The application must be accompanied by the prescribed extension fee and late fee, with the fee structure linked to the applicable fee for filing a fresh scheme.
🔹 No material changes permitted
The scheme cannot undergo material changes to its name, investment objective, investment strategy, structure, category or nature. Any such change would require filing a fresh Placement Memorandum.
🔹 Multiple six-month periods may be considered
Where the application is made after a longer period of expiry, IFSCA may grant an extension covering additional six-month blocks, subject to applicable fees.
⚠️ Important: The extension does not prejudice IFSCA’s right to take action for regulatory non-compliance during the period in which the Placement Memorandum remained expired.
This is a significant development for FMEs managing Venture Capital Schemes and Restricted Schemes in IFSC, providing a mechanism to address situations where a PPM has expired while also maintaining regulatory accountability.
📄 Circular: Extension of validity of expired Placement Memorandum – Reg.
Issued by IFSCA on September 11, 2026, with immediate effect.