SWAGAT-FI Framework: SEBI Streamlines Compliance for Low-Risk Foreign Investors

The Securities and Exchange Board of India (SEBI) issued a consultation paper dated August 8, 2025 (Consultation Paper, which can be viewed by clicking on this link) seeking public comments on the proposed Single Window Automatic and Generalised Access for Trusted Foreign Investors (SWAGAT-FI) framework, aimed at providing a single point of contact for objectively identified and verified low-risk foreign investors governed under the SEBI (Foreign Portfolio Investors) Regulations, 2019 (FPI Regulations) and SEBI (Foreign Venture Capital Investors) Regulations, 2000 (FVCI Regulations). The framework seeks to facilitate easier investment access for trusted Foreign Portfolio Investors (FPIs) and Foreign Venture Capital Investors (FVCIs), enable a unified registration process, and minimize compliance requirements for such investors.

On September 12, 2025, SEBI, in its 211th board meeting (Board Meeting, press release for which can be viewed by clicking on this link), has approved the SWAGAT-FI framework, however, the framework has not been notified yet. The key aspects of the framework, as approved by SEBI, are as follows:

1. Eligible Investor Categories under SWAGAT-FI

The framework identifies the following foreign investors as eligible for SWAGAT-FI status:

• • • Government and government-related investors, such as central banks, sovereign wealth funds (SWFs), international or multilateral organisations/agencies, and entities controlled or at least 75% owned (directly or indirectly) by such entities.

• • • Appropriately regulated Public Retail Funds (PRFs) with diversified investors and investments, managed independently and regulated in their home jurisdiction, including (i) mutual funds and unit trusts open to retail investors, operating as blind pools with diversified investments and independent investment managers; (ii) insurance companies investing proprietary funds without segregated portfolios; and (iii) pension funds regulated in their home jurisdictions.

2. Relaxations for SWAGAT-FIs under FPI Regulations and FVCI Regulations

Under the framework, SWAGAT-FIs will be entitled to the following relaxations: 

3. Registration, Implementation Timeline and Eligible Fund Structures 

• • • Registration: Eligible FPI applicants may opt for SWAGAT-FI identification at the time of initial FPI registration, while existing FPIs meeting eligibility, may also convert to SWAGAT-FI status.

• • • Implementation Timeline: Given the necessary system and process modifications, SEBI has provided a 6-month timeframe for full implementation of the SWAGAT-FI framework.

• • • Eligible Fund Structures: SEBI will publish jurisdiction-wise lists of eligible fund structures based on a trust-but-verify approach aligned with the exemptions under the Additional Disclosure Framework (ADF) dated August 24, 2023 (which can be assessed using this link).