The framework
IFSCA's circular of 12 August 2025, "Regulatory Framework for Global Access in the IFSC", replaced the circulars of 25 November 2021 (Global Access to Broker Dealers) and 6 June 2024 (Global Access Clarifications). It was issued under sections 12 and 13 of the IFSCA Act, 2019 and regulations 27 and 45 of the IFSCA (Capital Market Intermediaries) Regulations, 2025. Regulation 27 requires an intermediary dealing in securities in foreign jurisdictions to follow IFSCA's norms.
"Global markets" means stock exchanges in foreign jurisdictions. The circular applies to global access providers, and to broker dealers and clients reaching global markets directly or through a provider.
Who may provide it
- Global Access Provider (GAP). Either an IFSC subsidiary of a recognised stock exchange, or an IFSCA-registered broker dealer with a direct arrangement with one or more foreign brokers, for clients or for its own account. An exchange subsidiary is treated as a broker dealer for this purpose but needs no trading membership.
- Introducing broker. An IFSCA-registered broker dealer with no direct relationship with a foreign broker, which introduces clients to a GAP.
- Proprietary traders. A broker dealer dealing only for its own account may also take direct membership of a foreign exchange.
A GAP needs IFSCA's authorisation before it starts. Providers already operating had to apply by 31 October 2025. The authorisation fee is USD 10,000, with quarterly turnover-based fees.
| Entity | Minimum net worth |
|---|---|
| GAP | USD 500,000 |
| GAP accessing global markets for its own account only | USD 200,000 |
| Other broker dealer trading for its own account through a GAP | USD 100,000 |
This net worth is segregated and additional to the net worth for other activities. SEBI's circular of 2 May 2025 lets SEBI-registered stockbrokers carry on activities in GIFT IFSC through a separate business unit under IFSCA's framework.
Clients and products
Clients may be persons resident outside India, as FEMA provides, and persons resident in India, to the extent FEMA permits. For resident individuals, access is limited to products permitted under the RBI's Liberalised Remittance Scheme, and the GAP must have systems to enforce that limit (see Foreign-currency accounts for residents).
Clients may be onboarded directly or through a referral arrangement with an entity in India, the IFSC or abroad. The referral fee must be disclosed to the client and the arrangement put in writing. The GAP or introducing broker stays responsible for compliance.
Only products listed on foreign exchanges that are "financial products" in the IFSC may be offered. Crypto-assets and crypto-linked instruments are excluded. A GAP may not give access to foreign index derivatives, single stock derivatives, bond derivatives or USD-INR derivatives that are available on IFSC exchanges. Those are traded on the IFSC exchanges instead. An exchange subsidiary acting as GAP may also have referral agreements with foreign brokers, platforms, advisers and asset managers, for example for mutual funds and alternative investment funds.
Obligations of providers
- Each foreign broker must be regulated in its own jurisdiction. The agreement must let the GAP obtain data on the global access activity. Any regulatory action against the foreign broker must be reported to IFSCA at once.
- All client funds must be routed through a bank account in the IFSC. Global access business and client money must be kept in separate accounts with an IFSC banking unit.
- Written disclosures must cover risks, roles, custody, account structure, profit and loss methodology, all fees and charges, investor protection, tax and foreign regulatory requirements. Key risks must be shown at every login.
- Clients must be told that the IFSC exchanges' investor protection, dispute resolution and grievance mechanisms do not cover global access trades.
- KYC, AML and CFT checks must meet IFSCA's standards, whatever the foreign broker's own processes. All user, transaction and trade data must be kept in the IFSC.
- The provider must file quarterly reports with IFSCA, have an independent audit completed within six months of each financial year-end, keep a dedicated webpage on the arrangements, and follow the CMI code of conduct and an advertising code.
In practice
For a foreign broker, the usual route is to register an IFSC broker dealer (see Master Key), seek GAP authorisation, and contract with its own group broker abroad as the foreign broker. For a resident client, the binding limits are the LRS and the product filter, not the GAP's own catalogue.