SEBI proposes mandatory NAV reporting by AIFs to depositories

Reinforcing its commitment to improve transparency and investor safety within the Alternative Investment Fund (AIF) ecosystem, the Securities and Exchange Board of India (SEBI) has released a draft circular dated September 19, 2025 (Draft Circular), proposing mandatory reporting of net asset value (NAV) of all International Securities Identification Numbers (ISINs) for units issued to investors, by AIFs or their Registrars and Share Transfer Agents (RTAs) through the depository system. Public and stakeholder inputs on the Draft Circular are invited until October 9, 2025.

SEBI intends to facilitate leveraging of the depository infrastructure for maintenance of updated NAV data in respect of AIF units issued to investors to ensure real-time availability of data relating to the value of AIF investments for both investors and the regulatory authorities.

Key highlights of the proposed framework for NAV reporting are outlined below:

1. All categories of AIFs or their RTAs shall be required to upload NAV of all ISINs of AIF units in the depository system within 15 days of portfolio valuation.

2. Category I and Category II AIFs must report NAVs at least semi-annually (or annually with investor approval), while Category III AIFs must adhere to quarterly/monthly reporting as applicable based on the nature of the schemes (close-ended/open-ended).

3. For existing AIF schemes, the latest available NAV as on date of the Draft Circular must be uploaded within 45 days of its issuance.

4. The valuation date will be reckoned as the date of the valuation report if done by an external valuer, and as the date it is recorded in the fund’s internal records if done by an internal valuer.

5. Depositories are tasked with building suitable infrastructure, amending bye-laws, and ensuring awareness of the new framework governing NAV reporting by AIFs.

Conclusion:

The proposal to introduce demat-based NAV reporting promises to improve AIF market transparency and facilitate greater trust among investors, supporting SEBI’s broader goal of securities market development and investor protection.