Register of certification requirements
| Who | Course | Deadline | Instrument |
|---|---|---|---|
| Fund management entities: KMPs and all other employees discharging core fund management activities | ICSI "Regulatory Framework for Fund Management in IFSC: AIFs and Retail Schemes" or ICAI "Regulatory Framework for Fund Management in IFSC" (either is sufficient) | 31 December 2026 (extended from 30 September 2026) | FM Regulations 2025, regulation 7(6); circulars of 1 April, 10 August and 29 September 2026 |
| Capital market intermediaries: KMPs and all other employees discharging core business activities | ICSI "Regulatory Framework for Capital Market Intermediaries in IFSC" | 31 December 2026 (extended from 30 September 2026) | CMI Regulations 2025, regulation 9(5); circulars of 2 April, 6 August and 30 September 2026 |
| All regulated entities: Designated Directors and Principal Officers under the AML Guidelines | NISM-IFSCA-01: Certification Course on Anti-Money Laundering and Counter-Terrorist Financing in the IFSC | Course launched 18 November 2025; the certification must be held at all times while in the role | Circular of 17 November 2025 under the AML Guidelines, 2022 |
The extension circulars of September 2026 change only the deadline; the other terms of the earlier circulars remain.
Who is responsible
- Fund management entities. The FME and the persons in control of it are responsible for continuous adherence to the KMP eligibility criteria and for timely completion of the course by its employees.
- Capital market intermediaries. The CMI and the persons in control of it are responsible for timely completion of the course.
- AML officers. The direction applies to every Designated Director and Principal Officer under the Guidelines.
IFSCA also encourages employees in support roles, and entities supporting the fund ecosystem such as trustees, intermediaries and fund administrators, to take the FME course. For CMIs it encourages support staff to take the CMI course.
Qualifications and presence
Certification sits on top of the qualification and experience rules in each framework:
- Fund management. The principal officer, compliance officer and other KMPs must meet the prescribed qualification and experience standards and be based out of the IFSC. The 30 January 2026 amendment recast the experience test and added routes based on IFSCA-specified certifications. See fund governance.
- GIC, TechFin and ancillary, BATF and credit rating agencies. The principal officer and compliance officer must be full-time employees based in the IFSC, and in some frameworks must hold specified professional qualifications.
All of them must also be fit and proper at all times. See fit and proper.
Managing the deadline
- List everyone in scope: KMPs and every employee whose work is a core activity under the framework. Record how the line between core and support work was drawn.
- Enrol them in good time, and keep evidence of completion on the personnel file.
- For new joiners, make completion a condition of taking up a core role, and confirm with IFSCA how the requirement applies to people who join after the deadline.
- Check that the AML Designated Director and Principal Officer hold NISM-IFSCA-01, and that any replacement does too before appointment.
- Link certification to KMP change procedures, so an appointment is not intimated to IFSCA before the person qualifies.
- Watch for further circulars. IFSCA has changed these requirements several times in 2026.