IFSCA (Fund Management) Regulations, 2025 — Key Amendments and Proposals
Published: October 2025
Source: International Financial Services Centres Authority (IFSCA) – Consultation Paper on Amendments to Fund Management Regulations, 2025
📘 Background
The International Financial Services Centres Authority (IFSCA) has released a comprehensive consultation paper proposing amendments to the IFSCA (Fund Management) Regulations, 2025.
This follows the rapid growth of the fund management industry at GIFT-IFSC, which now hosts 177 registered Fund Management Entities (FMEs) managing 272 schemes with cumulative commitments exceeding USD 22 billion (as of June 2025).
The review aims to enhance ease of doing business (EoDB), strengthen investor safeguards, and clarify regulatory intent, ensuring GIFT-IFSC continues to evolve as a globally competitive fund domicile.
🔑 Key Highlights
1️⃣ Ease of Doing Business (EoDB)
IFSCA has proposed several reforms to simplify operations and reduce compliance burden for FMEs:
Extension of Placement Memorandum validity: FMEs can now extend validity beyond 12 months to accommodate dynamic fundraising timelines.
Flexible appointment timelines for certain service providers (auditors, fund administrators, valuers), recognizing that their role becomes critical post first close.
Custodian flexibility: FMEs may temporarily appoint regulated custodians outside IFSC for up to 24 months, until IFSC custodians build sufficient capacity.
Extended audit submission window: Annual scheme reports may be submitted within 6 months of financial year-end (earlier 4 months).
Skin-in-the-game exemptions: Reduced FME capital contribution requirements for schemes where managerial discretion is limited.
2️⃣ Safeguards & Governance Enhancements
To ensure investor protection and transparent fund operations:
Expanded definition of “associate” to include a broader range of related entities, enhancing oversight of related-party transactions.
Mandatory board-level approval for all internal policies and frameworks to ensure governance accountability.
Enhanced disclosure requirements in offer documents — including NAV computation methodology, conflict-of-interest policy, and risk management framework.
Annual investor disclosure obligations clarified for NAV, portfolio composition, and valuation.
3️⃣ Clarifications
The 2025 amendments also address ambiguities in earlier regulations to improve interpretation consistency:
Clear timelines for NAV and portfolio disclosures (starting from the financial year of first close).
Explicit linkage between portfolio valuation and NAV computation.
Recognition of Family Investment Funds (FIFs) under AIF categories (I, II, or III) based on investment strategy.
Investor rights clarified — all investors to be treated pari passu unless otherwise specified in placement documents.
💬 Public Consultation
IFSCA invites comments on these proposals until November 6, 2025.
Submissions may be emailed to:
📩 bharat.singh@ifsca.gov.in, abhineet.panwar@ifsca.gov.in, and aditya.sarda@ifsca.gov.in.
🧩 Summary — Why It Matters
For AIFs, VCs, and FMEs operating within or through GIFT-IFSC:
The 2025 amendment set makes fund setup, compliance, and operations simpler, faster, and globally aligned.
Investor protection mechanisms have been strengthened without increasing regulatory friction.
The co-investment SPV framework and third-party fund management reforms create new structuring opportunities for global managers.