Date: January 27, 2026
Issuing Authority: International Financial Services Centres Authority (IFSCA) Circular: International Financial Services Centres Authority (IFSCA)
The International Financial Services Centres Authority (IFSCA) has issued a circular providing a one-time window of three (3) months to extend the validity of Placement Memorandums (PPMs) for certain Venture Capital Schemes and Restricted Schemes operating in IFSCs.
This move comes in response to representations from market participants highlighting fundraising delays due to prevailing market conditions.
Regulatory Background
Under the IFSCA (Fund Management) Regulations, 2025:
The PPM of a Venture Capital Scheme or Restricted Scheme is valid for 12 months from the date it is taken on record by IFSCA.
For open-ended Restricted Schemes, investment activities may begin after raising USD 1 million, but the scheme must reach a minimum corpus of USD 3 million within 12 months.
One-Time PPM Extension Window – Key Highlights
IFSCA has announced proposed FM (Amendment) Regulations, 2026, along with a temporary relaxation allowing eligible schemes to extend PPM validity.
⏳ Duration of the Window
3 months from the date of issuance of the circular (January 27, 2026)
1️⃣ Schemes That Have NOT Commenced Investments
This applies to Venture Capital Schemes and Restricted Schemes where:
The PPM has already expired, or
The PPM is set to expire within 30 days from notification of the amendment regulations, and
No investment activity has commenced
Conditions for Extension
Fund Management Entities (FMEs) must:
Re-file the PPM within 3 months, clearly stating the intent to seek extension under this one-time window
Avoid any material changes to:
Scheme name
Investment objective or strategy
Structure (open-ended / close-ended)
Scheme type (VC Scheme or Category I/II/III Restricted Scheme)
Pay a filing fee equal to 50% of the fee applicable for a fresh scheme
Extension Granted
6 months from the date IFSCA communicates that the re-filed PPM has been taken on record
2️⃣ Open-Ended Restricted Schemes That Have Commenced Investments
This applies where:
The scheme has commenced investments after raising USD 1 million
The minimum corpus of USD 3 million could not be achieved within the PPM validity or extended validity
The PPM has expired or is expiring within the prescribed timeline
Conditions
Submit a formal request to IFSCA within 3 months of the circular
Pay 50% of the applicable fresh scheme filing fee
Extension Period
The extension will be deemed to start from the original expiry date of the PPM
Further Extensions Beyond the One-Time Window
Schemes that avail this one-time extension may apply for additional extensions as permitted under the FM Regulations, subject to:
Compliance with prevailing regulatory provisions
Payment of 50% of the applicable fresh scheme filing fee at the time of such request
Effective Date
This circular has been issued under Sections 12 and 13 of the IFSCA Act, 2019, read with Regulation 146 of the FM Regulations, and is effective immediately.
Our Take (AIF Services Insight)
This one-time relaxation is a practical and fund-friendly move, especially for managers facing prolonged fundraising cycles. However, FMEs must act swiftly—the 3-month window is non-extendable and comes with strict conditions on PPM modifications.
For fund managers, this is a crucial opportunity to regularize scheme validity without restarting the entire filing process.