Entities authorised under the 2022 framework

What the 2022 framework covered

IFSCA's circular of 27 April 2022, the Framework for FinTech Entity in the IFSCs, had two chapters.

• Chapter I, authorisation. An applicant with a deployable product and revenue in at least one of the last three financial years could be authorised as a FinTech Entity. It could provide a FinTech solution in financial services regulated by IFSCA (clause 7(a)), or a TechFin solution aiding financial activities (clause 7(b)). The entity had to be incorporated in the IFSC or set up as a branch or subsidiary there.
• Chapter II, sandbox. A limited use authorisation to test in the Regulatory Sandbox, the Innovation Sandbox, the Inter-Operable Regulatory Sandbox or through the overseas referral mechanism.

IFSCA's FinTech page now lists the 2022 framework under 'Archives'.

Sandbox entities with a live limited use authorisation

The FinTech Sandbox Framework, 2026, issued on 16 March 2026, superseded all earlier sandbox provisions from that date. Two savings apply:

• actions taken under the earlier instruments before 16 March 2026 remain valid (paragraph 5 of the covering circular); and
• entities with a valid limited use authorisation under the 2022 framework continue to be governed by the 2022 circular until their existing authorisation expires (clause 2 of Part I of the framework).

The 2022 terms therefore continue to govern the test, including its boundary conditions, reporting and exit, but only for the life of the existing authorisation. When it ends, the relaxations end with it. To keep testing, the entity would need a new authorisation under the 2026 framework. To go live, it would need registration under the framework that governs the activity. A TechFin entity in the 2022 sandbox must exit successfully and then apply afresh on SWIT under the TechFin and Ancillary Services Regulations (IFSCA's TAS FAQ 10).

TechFin entities authorised under Chapter I

The IFSCA (TechFin and Ancillary Services) Regulations, 2025 took over the TechFin route. They were made on 8 July 2025 and came into force on publication in the Gazette, dated 10 July 2025. For existing TechFin entities authorised under the 2022 framework:

• they must obtain a certificate of registration under the 2025 regulations within twelve months of commencement (regulation 4(1), first proviso);
• on application, the Chairperson may extend that period for recorded reasons, but not beyond twenty-four months in total (second proviso);
• until they receive the certificate, they continue to be governed by the 2022 framework (third proviso); and
• IFSCA may issue the certificate on a declaration of compliance with the 2025 regulations (regulation 4(2)). Its FAQs provide a declaration format, which refers to holding an SEZ Letter of Approval for the services concerned.

IFSCA's FAQs state that an existing entity that does not obtain its certificate within twelve months, unless the period is extended, will have its authorisation deemed invalid and must cease operating under the old framework. The TechFin provisions of the 2022 framework, clause 7(b) and the related part of Annexure I, are repealed twenty-four months after commencement (regulation 20(2)). The twelve months counted from 10 July 2025 have now run. An entity that has neither a certificate nor an extension should take advice without delay.

FinTech entities authorised under clause 7(a)

The texts we have reviewed deal expressly with sandbox entities and with TechFin entities. They do not expressly address an entity authorised under clause 7(a), for a FinTech solution in a regulated financial service, outside the sandbox. Such an entity should check its authorisation letter. It should also confirm with IFSCA whether its activity now needs registration under a sector framework, such as the Payment Services Regulations, 2024.

What to do now

1. Identify which chapter and clause of the 2022 framework your authorisation was granted under, and its expiry date if any.
2. For a limited use authorisation, plan the next step before expiry: a new sandbox application, or registration under the relevant framework.
3. For a TechFin authorisation, confirm whether a certificate of registration under the 2025 regulations has been issued, or an extension granted, and file the declaration if not.
4. Check fees. IFSCA's fee circular of 2 March 2026 notes that existing entities continue under the old frameworks only until the certificate is granted or the transition period ends, whichever is earlier.
5. Review any transition steps IFSCA has communicated to you directly.