Date: 6/012/2026
February 6, 2026 — The Securities and Exchange Board of India (SEBI) has issued a circular mandating reporting of Net Asset Values (NAVs) of AIF units to Depositories. The move expands the infrastructure around dematerialised AIF units and enhances transparency and operational standardisation across the Alternative Investment Fund ecosystem.
This update is significant for all Category I, II and III AIFs, their managers, trustees, sponsors and service providers — especially RTAs and compliance teams.
Background
SEBI’s regulatory framework for AIFs has progressively leaned into dematerialisation and institutional-grade infrastructure. With AIF units required to be in dematerialised form, the next logical step — adopted through this circular — is to leverage depository systems for NAV dissemination.
Depositories already host information for listed securities and mutual funds. Bringing AIF NAVs into this infrastructure results in:
Standardised NAV visibility
Better investor information flow
Consistent reporting protocols across the industry
What SEBI has mandated
1. NAV reporting to Depositories
AIFs must ensure upload of the latest available NAV (for each ISIN / class) to the Depository system:
Within 30 days from the valuation date; or
By May 1, 2026, whichever is later
This upload is to be facilitated through the AIF’s Registrar & Transfer Agent (RTA).
2. Valuation date specification
SEBI has clarified how to determine the valuation date for reporting:
Independent valuer: valuation date is the date on the valuer’s report
Internal valuer: valuation date is the date on which the valuation is formally recorded by the AIF
This removes ambiguity and aligns industry practice on reporting timelines.
3. Manager responsibility
While RTAs will undertake the technical upload process, the responsibility for timely, accurate reporting rests with the AIF Manager.
SEBI has explicitly placed ultimate accountability on the Manager rather than the service provider.
4. Depository obligations
Depositories are required to:
Build technical capability to accept NAV uploads from AIF RTAs
Display the NAV data with a regulatory disclaimer
Modify bye-laws, regulations, and agreements as needed
Disseminate the circular to participants and publish updates on their platforms
5. Compliance Test Reports (CTR)
Trustees / sponsors will need to ensure that CTR templates and attestations explicitly cover this reporting requirement as part of regular compliance certification.
Who this applies to
All AIFs under the SEBI (AIF) Regulations including:
Category I AIFs
Category II AIFs
Category III AIFs
This requirement is effective immediately, with the first formal compliance deadline being May 1, 2026.
Action points for AIF businesses
To comply smoothly, AIF Managers should – as a priority – undertake the following:
Coordinate with the RTA to build NAV upload schedules
Confirm valuation calendars against reporting timelines
Update internal processes to formalise valuation documentation
Modify CTR templates to include NAV reporting attestations
Brief compliance and operations teams on responsibilities
Why this matters
This circular marks a structural improvement in how AIFs engage with market infrastructure:
It bridges privately negotiated fund NAVs with publicly accessible depository systems
It aligns AIF NAV transparency with broader capital markets norms
It embeds AIF valuation reporting into formal operational and compliance workflows
Over time, this will enhance trust and standardisation in private market investment reporting.