What goes through SWIT
In IFSCA's set-up workflow, SWIT carries:
- the application itself, made jointly to IFSCA as SEZ Administrator and to IFSCA as regulator;
- any in-principle approval, where the activity regulation provides for one;
- the application for GST registration;
- a copy of the lease of the IFSC premises, filed within 6 months of the SEZ Letter of Approval;
- the certificate of registration, IFSCA's final approval.
Many post-registration filings and IFSCA queries are also handled through the portal. The SEZ side of the process, from the Unit Approval Committee to the Letter of Approval, the bond-cum-legal undertaking and the date of commencement, runs on the separate SEZ Online portal.
The Common Application Form and the annexures
Most applicants file the Common Application Form (CAF) with an annexure for their activity. IFSCA's How to Apply page lists the following:
| Activity | Annexure or form |
|---|---|
| Capital market intermediaries | CMI annexure |
| Fund management entities, funds, pension | Fund Management Entity annexure |
| Banking | Banking annexure |
| Finance company, aircraft leasing, ship leasing | Finance company or finance unit annexure |
| Ancillary services, Global In-House Centres | Ancillary service provider annexure; GAO annexure |
| Insurance | Insurance intermediary annexure; annexures under Schedule I, regulations 4(2) and 5(1) |
| Metals and commodities | Vault manager annexure; trading member or clearing member application |
| FinTech sandbox | Preliminary sandbox application form; sandbox application form |
Market infrastructure institutions, foreign universities and payment service providers do not use the CAF, and follow the application route in their own frameworks.
What the CAF asks for
The CAF collects the applicant's details, its ownership down to the ultimate beneficial owner, its directors or partners and KMPs, the business plan, capital, fit-and-proper declarations and, where relevant, home-regulator information. In our experience the form is organised around four blocks:
- entity and ownership;
- business plan, with projections and an organisation chart;
- KMPs and fit-and-proper declarations;
- infrastructure: the IFSC address, IT systems and banking arrangements.
The activity annexure then adds the framework's own requirements, such as net worth, scheme types or capital adequacy.
Before you log in
- Talk to IFSCA first if useful. Before deciding to apply, an applicant may ask IFSCA's development team for an overview or a slot to present its business plan. Once it has decided, it may ask the relevant regulatory team for a short call.
- Prepare the ownership chain to the ultimate beneficial owner before starting. It is asked for early, and a chain that stops part-way is a common cause of queries.
- Finalise board resolutions and home-regulator letters. Drafts invite queries.
- Identify the principal officer and KMPs and collect their qualification and experience records.
- Read the framework, its circulars and FAQs. IFSCA asks applicants to review them before applying, and to keep up with changes.
- Check the fee. The applicable fee is set by IFSCA's fee circular for the activity. See fees.
After filing
Queries come through the portal. IFSCA says its regulatory team will contact the applicant within 7 working days of submission, and that it will strive to take a final decision within 45 days. Both periods are aims, and run in practice from a complete application.
Keep one person responsible for SWIT correspondence, with authority to answer queries and upload documents, so that nothing waits in an unwatched inbox. Where an application stalls, IFSCA's How to Apply page gives a route to raise difficulties with the Chairperson's office. Where the question is one of interpretation rather than process, the Informal Guidance Scheme, 2024 may be the better tool.