The statutory definitions
Section 3(1) of the IFSCA Act, 2019 defines the building blocks.
- Financial product means securities, contracts of insurance, deposits, credit arrangements, and foreign currency contracts other than spot exchanges of one currency for another. It also covers any other product or instrument notified by the Central Government.
- Financial service lists fourteen heads. They include dealing in financial products, accepting deposits, safekeeping and administering assets, effecting insurance, managing assets, operating investment schemes, keeping ownership records, underwriting, credit information, stored value and payment services, making arrangements for any of these, and advising on them. Here too, the Central Government may notify further services.
- Financial institution means a unit set up in an IFSC that renders financial services in respect of a financial product.
Under section 12, IFSCA regulates what was already permitted in an IFSC before the Act, regulates whatever else the Central Government notifies, and may recommend further products and services to the Government.
Two steps: notification, then a framework
First, the activity must be within the definitions or notified. Notifications have widened the field over time. GIFT City's guide records, for example, that on 31 August 2020 the Government notified the bullion spot delivery contract and the bullion depository receipt as financial products, and related services as financial services. In 2020 it also notified aircraft leasing and global in-house centres.
Second, IFSCA issues the regulatory framework: regulations or a circular setting out who may carry on the activity, with what capital, people and conduct rules. Without a framework there is no registration to apply for, even if the activity is within the definitions. IFSCA's frameworks are listed by sector on its website, and the registration routes are summarised in Register of registrations.
Support services are a separate category
Not every business serving financial institutions is itself carrying on a financial service. The IFSCA (TechFin and Ancillary Services) Regulations, 2025 cover services that aid or assist in making arrangements for the financial services listed in sub-clauses (i) to (xi) of section 3(1)(e). Examples are legal, audit, fund administration and technology services. The Third Schedule to those regulations bars a TechFin and ancillary service provider from undertaking activities regulated under any other IFSCA regulations or framework. A provider that wants to do both must obtain the separate registration. See TechFin service providers.
When the model does not fit
If a business model does not fit an IFSCA framework, the options are:
- Fit the model into an existing category. This often means separating a regulated core from support functions that can be provided under a different registration.
- Use the FinTech sandbox if the model is genuinely innovative. The FinTech Sandbox Framework, 2026 allows testing of ideas linked to activities regulated by IFSCA, within boundary conditions and for a limited period. It requires applicants first to consider whether the TechFin and Ancillary Services Regulations fit. See Sandbox tracks.
- Seek informal guidance from IFSCA on how the rules apply to the specific proposal. See Informal guidance.
A common error is to treat IFSCA's development remit as permission. IFSCA can recommend new activities to the Government, but until an activity is permitted and a framework exists, an IFSC unit cannot lawfully offer it.