IFSCA Revises the Reporting Formats for FMEs and Initiates Transition to the Fund Management Regulations, 2025

The International Financial Services Centres Authority (IFSCA) through circulars dated April 3, 2025, and April 8, 2025, has, (i) revised the reporting formats for fund management entities (FMEs); and (ii) provided the framework for transitioning to the recently notified IFSCA (Fund Management) Regulations, 2025 (FM Regulation, 2025), respectively (Circulars).

Key highlights from the Circulars are outlined below:

• • Revised Reporting Formats for FMEs
    IFSCA has released updated reporting formats for FMEs vide circular dated April 3, 2025. This comes in continuation of circulars dated May 31, 2023, and November 3, 2023, which introduced and later amended the reporting norms for FMEs. These circulars provide that reporting formats may be updated or supplemented, if required.
    Accordingly, the formats have been revised to seek specific details of retail schemes, capture granular information for supervisory purposes, restructure tables to provide greater clarity to FMEs, include guidance notes, and align the formats with FM Regulations, 2025.

• Transition to FM Regulations, 2025
  The FM Regulations, 2025, have, (i) extended the validity period of the private placement memorandums (PPMs) for venture capital schemes and restricted schemes from six months to 12 months; and (ii) lowered the minimum corpus requirement from USD Five Million to USD Three Million for various schemes, including venture capital schemes and restricted schemes.

Vide circular dated April 8, 2025, IFSCA has permitted venture capital schemes and restricted schemes filed under IFSCA (Fund Management) Regulations, 2022 to launch schemes under FM Regulations, 2025, if the schemes were either taken on record by IFSCA during the six month period ending February 19, 2025, or if the validity of a scheme’s PPM was extended by IFSCA and such extension expires or after February 19, 2025.

For PPMs whose validity expired before February 19, 2025, IFSCA has given a one-time opportunity to FMEs to seek extension of such expired PPMs (in case of venture capital schemes and restricted schemes) to enable them to be launched under the FM Regulations, 2025.

The opportunity to seek an extension is subject to the following conditions:

• FMEs shall re-file the PPMs with IFSCA within three months from April 8, 2025;
• no material changes can be made to key aspects of PPMs which include name, investment objective and strategy, structure of the scheme, and type of the scheme. Material changes may be permitted in so far as they have been undertaken to align the PPM with the requirements of FM Regulations, 2025; and
• payment of a filing fee equal to 50% of the fee required for filing a fresh scheme of the same nature under FM Regulations, 2025.

If these conditions are met, the revised PPM will be taken on record by IFSCA and the same will be communicated to the FMEs. Subsequently, an additional validity of six months from the date of communication will be granted to the PPMs.

Additionally, IFSCA has clarified that processing fees will not be applicable for filings related to material changes in the information provided in the PPM if such filings are due to any action of the IFSCA or revisions in the regulatory regime.

Conclusion:
With the rollout of FM Regulations, 2025, IFSCA is actively encouraging a forward looking and innovation driven financial ecosystem. These Circulars reflect IFSCA’s efforts to streamline operations, improve compliance mechanisms, and provide flexibility to FMEs during this regulatory transition.