Date: December 30, 2025
Circular No.: HO/19/34/11(9)2025-AFD-POD1/I/2286/2026
SEBI has issued a circular dated January 9, 2026, introducing further simplifications in the accredited investor framework under the SEBI (Alternative Investment Funds) Regulations, 2012. These changes aim to reduce procedural friction while preserving prudential safeguards for AIFs.
Key Highlights of the Circular
1. Early Execution of Contribution Agreements Allowed
Pending receipt of the formal accreditation certificate from a SEBI-recognized accreditation agency, AIF managers may now proceed with executing contribution agreements and initiating operational processes, based on their internal assessment of investor eligibility.
However, two important safeguards apply:
Investor commitments cannot be included in the scheme corpus until accreditation is formally granted.
Funds can be accepted only after the investor receives the accreditation certificate.
This change helps reduce deal execution delays without compromising regulatory compliance.
2. Simplification of Net-Worth Documentation
SEBI has removed the requirement to submit a detailed net-worth break-up as an annexure to the net-worth certificate.
Further clarifications:
Chartered Accountants may simply certify whether the investor meets the prescribed net-worth threshold.
Disclosure of the actual net-worth amount is optional.
The net-worth certificate must be not older than six months.
This significantly reduces documentation burden for investors and accreditation agencies.
3. Updated List of Documents for Accreditation
The revised Annexure A streamlines documentation requirements across individuals, HUFs, corporates, and trusts. Key documents include:
PAN and proof of identity/address
Authorization letter (for entities)
Financial information via ITRs, audited financials, or net-worth certificate
Applicant declaration confirming accuracy of submissions
Accreditation agencies may still request additional documents where submissions appear inconsistent or suspicious.
4. Compliance and Applicability
AIF trustees, sponsors, and managers must ensure compliance with this circular is captured in the Compliance Test Report.
The circular comes into force with immediate effect.
What This Means for AIFs and Investors
These changes strike a balance between ease of onboarding accredited investors and maintaining corpus-based prudential discipline. Fund managers benefit from faster closures, while investors face reduced certification friction—without dilution of regulatory oversight.
For AIF managers, investment teams, and compliance officers, internal processes and checklists should be updated immediately to reflect these changes.