A S BANKA ADVISORS

A Fundamental Shift in AIF Compliance

If you are involved with an Alternative Investment Fund in any capacity, whether as a fund manager, LP, or a startup receiving AIF investment, SEBI’s March 4, 2026 circular represents a significant change to the compliance landscape. Issued under Regulation 28 of the SEBI (Alternative Investment Funds) Regulations, 2012, the circular replaces the longstanding detailed quarterly reporting system with a streamlined annual framework.

For an industry managing over Rs. 12 lakh crore across 1,300+ registered AIFs, this is not a minor procedural update. It is a fundamental rethinking of how regulatory oversight balances information needs with compliance burden.

What Changes for Your Fund

The new framework introduces two reporting obligations in place of four detailed quarterly filings:

Annual Activity Report: A comprehensive year-end submission covering fund activity, portfolio composition, and investor data. The deadline is April 30 each year (30 calendar days from March 31). For FY 2025-26, SEBI has extended this to May 31, 2026, giving funds a one-time transition window.

Limited Quarterly Report: A reduced-scope quarterly filing due within 15 days of each quarter-end, covering only time-sensitive data. The March quarter is completely exempt since the annual report covers it. This means three quarterly filings per year instead of four detailed ones.

The previous reporting requirements under Clause 15.1 of the SEBI Master Circular for AIFs (May 7, 2024) are now fully superseded.

Three Areas That Need Immediate Attention

1. Template Mapping: The revised reporting templates are published on the IVCA (Indian Venture and Alternate Capital Association) website. These are not minor format changes. The Annual Activity Report consolidates data points that were previously spread across four quarterly submissions, and may require data that your fund has not been systematically capturing.

2. Data Gap Analysis: Start mapping your existing data collection systems against the new annual template now. Pay particular attention to portfolio valuations, investor schedules, distribution details, and NAV reporting. Gaps identified early can be addressed before the May 31 deadline.

3. SI Portal Readiness: All submissions go through the SEBI Intermediary Portal. If your fund has not registered or tested the submission process, do so well before the deadline. Last-minute technical issues can turn a compliance advantage into a missed filing.

What This Means for Startup Founders

If your company has received investment from an AIF, expect information requests in the coming weeks. Fund managers will need current financials, cap table data, and valuation information to populate their Annual Activity Reports. Being responsive to these requests strengthens your relationship with AIF investors and supports their compliance obligations.

Key Dates to Track

• May 31, 2026: First Annual Activity Report (FY 2025-26)
• July 15, 2026: First Limited Quarterly Report (Q1 FY 2026-27)
• April 30, 2027: Second Annual Activity Report (FY 2026-27 onwards)

Download the full carousel PDF for a visual summary of the new framework

Need Help Navigating This?

Our team at A S Banka Advisors Private Limited works with fund managers and startups on SEBI compliance, fund structuring, and regulatory reporting. If you need help mapping data gaps, reviewing templates, or coordinating your first annual filing, get expert guidance.