IFSCA prescribes procedure for scheme filings by FMEs for Third-Party Fund Management

With a view to streamlining the launch of schemes managed on behalf of third‑party fund managers within the International Financial Services Centre (IFSC) ecosystem, the International Financial Services Centres Authority (IFSCA) has issued a circular dated January 16, 2026 (Circular) addressed to Fund Management Entities (FMEs) authorised to provide third‑party fund management services under Part D of Chapter VI introduced vide the International Financial Services Centres Authority (Fund Management) (Amendment) Regulations, 2025 notified on July 24, 2025 (which can be accessed here).

The Circular, effective immediately, prescribes the specific documentation and information to be submitted when filing scheme applications for third‑party fund management arrangements and mandates electronic filing through IFSCA’s online portal.

Key highlights of the Circular are outlined below:

1. Alignment with existing scheme filing framework: Registered FMEs authorised to launch schemes on behalf of third-party fund managers are required to use the format and submit documents already prescribed under IFSCA’s circular titled “Ease of doing business – Filing of Schemes or funds under International Financial Services Centres Authority (Fund Management) Regulations, 2022” dated April 5, 2024 (which can be accessed here).

2. Additional disclosures relating to the third-party fund manager: To enhance transparency and regulatory oversight over third‑party fund management arrangements, the Circular requires submission of detailed information on the third-party fund manager, including:

• • • the full legal name, registered office address, together with the proof of registration with, or license issued by, the regulatory authority in its home jurisdiction;

• • • a look-through ownership chart identifying the ultimate beneficial owners (UBOs) of the third-party fund manager;

• • • names and profiles of its board of directors or designated partners (as applicable) and key managerial personnel (KMPs), or equivalent officers including details related to appointment or change of KMPs;

• • • complete details of the assets under management (AUM), together with historical records of investment strategies adopted by the third‑party fund manager which are similar to those proposed under the scheme to be launched by the registered FME;

• • • outline of the deal execution, conflict-of-interest disclosures (if any), and remuneration policies of the third-party fund manager;

• • • a declaration‑cum‑undertaking from the registered FME confirming compliance with the obligations, criteria and requirements set out under regulations 107H and 107K of the International Financial Services Centres Authority (Fund Management) Regulations, 2025; and

• • • submission of the document evidencing the third‑party fund management arrangement between the registered FME and the third‑party fund manager.

3. Mode of filing scheme applications: All scheme applications in respect of third-party fund management arrangements are required to be filed electronically via the IFSCA Single Window IT System portal.

Conclusion:

By consolidating and clarifying procedural requirements for scheme filings in respect of third-party fund management arrangements, and by mandating detailed disclosures on third‑party managers, ownership, governance, conflicts and remuneration, IFSCA seeks to streamline filings and strengthen oversight of outsourced fund management within the IFSC framework.