Who is responsible for what
- The FME. Its chief executive must ensure compliance and is responsible for overall risk management. The FME is liable for its employees and service providers. It must keep written conflict-of-interest policies, and its policies and frameworks must be approved by its board or an authorised committee or official (Third Schedule).
- Principal officer. Responsible for all the FME's activities, including fund management, risk and compliance. Must act on and report any breach to IFSCA.
- Compliance officer (Registered FMEs). Monitors compliance, deals with investor grievances and reports non-compliance to IFSCA independently.
- Investment committee. Optional. Its members carry the same duties as the FME and fund managers.
All of them must be fit and proper, and the KMPs must be based out of the IFSC. See fit and proper.
Fiduciaries and the April 2026 segregation rule
Before filing a scheme, the FME appoints its fiduciaries (regulation 17): the board for a company, designated partners for an LLP, or trustees for a trust. Fiduciaries of a retail scheme need IFSCA's prior approval. Among other duties, the fiduciaries:
- ring-fence each scheme's assets and accounts;
- review transactions with associates every quarter;
- review the FME's net worth every year; and
- before the first investor agreement, make sure an auditor, a fund administrator (or adequate in-house capability), an independent valuer and, where required, a custodian are in place.
IFSCA's circular of 10 April 2026 adds that an FME may not appoint a fiduciary of a scheme, or its associate, to provide fund administration, valuation, audit, or lending or financing to that same scheme. Schemes already filed or taken on record had until 30 September 2026 to comply. The scheme auditor must not be associated with the FME and is appointed by the fiduciaries (regulation 135).
KMP appointments and certification
- Changes. Appointments and changes of KMPs after registration are made by filing an intimation with IFSCA in the prescribed format, with the fee (circular of 20 February 2025). A vacancy must be notified with a candidate within three months, and no KMP post may stay vacant for more than six months. The paragraph that gave IFSCA seven working days to comment before the change took effect was omitted on 1 April 2026.
- Qualifications. The 30 January 2026 amendment recast the experience test around "eligible institutions" and added routes based on IFSCA-specified certifications.
- Certification. Every KMP, and every employee in core fund management activities, must complete either the ICSI course "Regulatory Framework for Fund Management in IFSC: AIFs and Retail Schemes" (circular of 1 April 2026) or the ICAI course "Regulatory Framework for Fund Management in IFSC" (circular of 10 August 2026). The deadline, originally 30 September 2026, was extended to 31 December 2026 by circular of 29 September 2026. The FME and its controlling persons are responsible for continuing compliance.
See also KMP certification.
Website or webpage from 1 December 2026
Under IFSCA's circular of 26 August 2026, every FME must maintain a public website or webpage, and tell IFSCA its address by 1 December 2026. Authorised and Non-Retail FMEs may use a dedicated page on a group website, linked from its home page. Retail FMEs need their own site. The site must show, among other things:
- the FME's registered name, category and registration number;
- its IFSC address and contacts;
- its schemes and portfolio management activity, and any schemes managed for managers outside the IFSC;
- its custodian, trustee, fund administrator and auditor;
- the grievance process, with complaint statistics updated quarterly;
- its principal officer, compliance officer and other KMPs;
- material regulatory actions in the last three years; and
- a statement that registration does not mean IFSCA endorsement.
Information must be in English, dated, and kept available for three years. FMEs registered after 1 December 2026 must comply before starting business.
Records and reporting
Books and records must be kept electronically for at least eight years, and scheme records for five years after winding up. Since 10 September 2026, scheme annual reports go to IFSCA, and abridged summaries to investors, within six months of the financial year end (previously four). The FME must also maintain a business continuity plan, reviewed each year, and a cyber security framework. See returns and the compliance calendar.