Unified registration for multiple activities (Master Key)

What the Master Key is

The IFSCA (Capital Market Intermediaries) Regulations, 2025 (the CMI Regulations) were amended to let an IFSC unit that wants to carry on several capital-market activities obtain a unified registration, called the Master Key or MKY. IFSCA set out the process in circular F No. IFSCA-PLNP/80/2024-Capital Markets of 13 February 2026, in force from 16 February 2026. The circular was issued under sections 12 and 13 of the IFSCA Act, 2019, read with regulations 4(1) and 45 of the CMI Regulations.

Any of the eleven intermediary categories in the CMI Regulations may be combined:

• broker dealer, clearing member and depository participant;
• custodian and debenture trustee;
• investment banker, investment adviser, research entity and distributor;
• credit rating agency, and ESG ratings and data products provider.

How the application works

1. One application is filed on IFSCA's Single Window IT System (SWIT). The applicant selects the activities it wants to carry on in the IFSC.
2. The applicant pays the application fee for each activity applied for, under IFSCA's fee circular IFSCA-DTFA/1/2025 of 8 April 2025.
3. On grant, IFSCA issues one certificate titled "Capital Market Intermediary" followed by the permitted activities.
4. After registration, registration fees, annual fees and other recurring fees are payable separately for each activity, by the deadlines in the fee circular.

Applications to act as a broker dealer, clearing member or depository participant still go through the relevant stock exchange, clearing corporation or depository. It has 30 days from receiving a complete application to forward it to IFSCA with its recommendation (regulation 5).

What does not change

The Master Key simplifies the filing. It does not merge the rules. Each activity's conditions still apply, and several CMI Regulations provisions decide how a multi-activity entity is built:

• Net worth. An entity in several categories must keep the highest of the applicable minimum net worth requirements, unless IFSCA specifies otherwise (regulation 7(4)). The requirement is separate from, and in addition to, net worth needed for other activities in or outside the IFSC (regulation 7(3)). A branch may keep it at parent level, earmarked for the IFSC branch (regulation 7(2)).
• Principal officer. A principal officer must be appointed for each registration separately. The exceptions are that one person may act for broker dealer, clearing member and depository participant together, and one person for credit rating agency and ESG ratings and data products provider together (regulation 9(8)).
• Compliance officer. One person may act as compliance officer for all the entity's CMI activities (regulation 9(9)).
• Exchange memberships. With the exchange's or clearing corporation's approval, a clearing member may act as a broker dealer, and a broker dealer as a clearing member, without a separate certificate (regulation 5(4) and (5)).
• Global access. Acting as a global access provider needs a separate authorisation and its own segregated net worth (see Global access).

Minimum net worth by category

Planning a multi-activity entity

A group that wants to act as broker, adviser and distributor can now use one IFSC entity rather than three, provided each activity's requirements are met. In practice:

• work out the highest net worth figure early, including the exchange's figure for broking;
• count heads: separate principal officers may be needed, and IFSCA requires manpower in the IFSC proportionate to the business;
• budget for per-activity fees, which the Master Key does not reduce; and
• build conflict controls between advice, distribution and broking from the start, under the code of conduct in Schedule II.

For the registration sequence generally, see IFSCA registration and Fees.