Compliance Reporting Formats for Specialized Investment Funds (SIFs)

CIRCULAR HO/24/13/12(4)2025-IMD-POD-1/I/2062/2026 January 08, 2026 To, All Mutual Funds All Asset Management Companies (AMCs) All Registrar and Share Transfer Agents (RTAs) All Trustee Companies/ Board of Trustees of Mutual Funds Association of Mutual Funds in India (AMFI) Madam/ Sir,

Subject: Compliance reporting formats for Specialized Investment Funds (SIF)

1. SEBI vide circular dated February 27, 2025 and subsequent circulars issued thereunder, has specified the regulatory framework for Specialized Investment Funds (‘SIFs’).

2. In order to ensure uniformity and clarity in compliance reporting for SIFs, the

compliance reporting formats applicable to SIFs shall be as follows:

2.1. In terms of Regulation 49V(2) of the SEBI (Mutual Funds) Regulations, 1996, all reporting requirements applicable to mutual funds under the SEBI (Mutual Funds) Regulations, 1996, the Master Circular for Mutual Funds dated June 27, 2024 (‘MF Master Circular’), and any other circulars or guidelines issued thereunder, shall also apply to Specialized Investment Funds.

2.2. Compliance Test Report (‘CTR’)

2.2.1. The format for the CTR, as prescribed under Format No. 2.B of the MF Master Circular, shall stand modified to include an additional Part IV, as specified in Annexure A1 to this circular.

Page 1 of 62.2.2. All Asset Management Companies managing SIF shall additionally report compliance under Part IV as part of the CTR submitted for Mutual Funds.

2.3. Half-Yearly Trustee Report (HYTR)

2.3.1. The format for the HYTR, as prescribed under Format No. 2.C of the MF Master Circular, shall stand modified to include Clause 72A, as specified in Annexure A2 to this circular.

2.3.2. The Trustees/Trustee Companies of Mutual Funds managing SIF shall additionally report compliance under Clause 72A as part of the HYTR submitted for Mutual Funds.

3. The provisions of this circular shall come into force with effect from the date of this

circular.

4. This circular is issued in exercise of the powers conferred under Section 11(1) of the Securities and Exchange Board of India Act, 1992 read with Chapter VI-C of the SEBI (Mutual Funds) Regulations 1996 to protect the interest of investors in securities and to promote the development of, and to regulate the securities market.

5. This circular is available at www.sebi.gov.in under the link “Legal ->Circulars”.

Yours faithfully, Peter Mardi Deputy General Manager Investment Management Department +91-22-26449233 peterm@sebi.gov.in Page 2 of 6Annexure A1 Part-IV of Compliance Test Report (CTR) Sl. Regulations Particulars Remarks No 1 Sub – regulation (1) of Compliance with respect to minimum Regulation 49X investment threshold across all investment strategies as stipulated under Clause 4 of Annexure A of

Circular No.: SEBI/HO/IMD/IMD-IPOD- 1/P/CIR/2025/26 dated Feb 27, 2025 2 Sub – regulation (2) of Compliance with respect to provisions Regulation 49X* related to NISM Certification Programme for fund manager of SIF.

3 Sub – regulation (1) of Investment strategies launched by SIF Regulation 49Y are in compliance with the characteristics stipulated under the regulations./ Clause 3 of Annexure A of

Circular No.: SEBI/HO/IMD/IMD-IPOD- 1/P/CIR/2025/26 dated Feb 27, 2025 4 Sub – regulation (3) of Compliance with respect to provisions Regulation 49Y related to limitation on fees and expenses 5 Sub – regulation (1) of Restrictions with respect to single issuer Regulation 49AA limit – debt instruments.

6 Sub – regulation (1) of Restrictions with respect to investments Regulation 49AA as per Clause 5 of Annexure A of

Circular No.: SEBI/HO/IMD/IMD-IPOD- 1/P/CIR/2025/26 dated Feb 27, 2025 7 Sub – regulation (2) of Restrictions with respect to owning of Regulation 49AA paid up capital of any company.

8 Sub – regulation (3) of Restrictions with respect to single issuer Regulation 49AA limit – equity and equity-related instruments.

9 Sub – regulation (4) of Restrictions with respect to investments Regulation 49AA** in INVITs.

Page 3 of 610 Sub – regulation (1) of Restrictions with respect to investments Regulation 49AA in derivatives as per Clause 6 of Annexure A of Circular No.:

SEBI/HO/IMD/IMD-IPOD- 1/P/CIR/2025/26 dated Feb 27, 2025 11 Sub – regulation (1) of Maintenance of clear product Regulation 49AB differentiation 12 Sub – regulation (2) of Compliance with provisions relating to Regulation 49AB branding, advertising (Clause 2 of Annexure A of Circular No.:

SEBI/HO/IMD/IMD-IPOD- 1/P/CIR/2025/26 dated Feb 27, 2025) 13 Sub – regulation (1) of Disclosures in offer documents- Regulation 49AD Compliance with respect to Clause 11 of Annexure A of Circular No.:

SEBI/HO/IMD/IMD-IPOD- 1/P/CIR/2025/26 dated Feb 27, 2025 14 Sub – regulation (2) of Compliance with provisions relating to Regulation 49AD and Portfolio disclosures Clause 13 (1) of Annexure A of Circular No.:

SEBI/HO/IMD/IMD- IPOD-1/P/CIR/2025/26 dated Feb 27, 2025 15 Clause 7 of Annexure Compliance with respect to provisions A of Circular No.: relating to subscription and redemption SEBI/HO/IMD/IMD- of units of investment strategies and IPOD-1/P/CIR/2025/26 notice Period for redemption dated Feb 27, 2025 16 Clause 8.1 of Compliance with respect to listing of Annexure A of Circular units of investment strategies No.:

SEBI/HO/IMD/IMD- IPOD-1/P/CIR/2025/26 dated Feb 27, 2025 17 Clause 9 of Annexure Compliance with respect to A of Circular No.: benchmarking of investment strategies SEBI/HO/IMD/IMD- IPOD-1/P/CIR/2025/26 dated Feb 27, 2025 Page 4 of 618 Clause 10 of Annexure A of Circular No.: Compliance with respect to provisions SEBI/HO/IMD/IMD- for Distribution of Specialized IPOD-1/P/CIR/2025/26 Investment Funds dated Feb 27, 2025 19 Clause 12 of Annexure Compliance with respect to risk band A of Circular No.:

SEBI/HO/IMD/IMD- IPOD-1/P/CIR/2025/26 dated Feb 27, 2025 20 Clause 13 (2) of Compliance with respect to disclosure of Annexure A of Circular scenario analysis No.:

SEBI/HO/IMD/IMD- IPOD-1/P/CIR/2025/26 dated Feb 27, 2025 *Note1: This shall be applicable as and when specific certification requirement is specified by the Board. **Note 2: For the quarter ending December 2025, the compliance regarding restrictions on investments in REITs shall be provided.

Page 5 of 6Annexure A2 Clause 72A of HYTR 72A: Compliance with respect to Specialized Investment Fund:

1. Whether AMC has the necessary expertise, internal control systems and risk management mechanism to invest in and manage investments as a Specialized Investment Fund;

2. Compliance with respect to minimum investment threshold;

3. Compliance with respect to fees and expenses in accordance with provisions of Regulation 52;

4. Whether Investment strategies launched by SIF are in compliance with the characteristics stipulated in Regulations;

5. Compliance with investment restrictions as prescribed in Regulation and Circulars;

6. Compliance with respect to provisions concerning product differentiation;

7. Compliance with respect to disclosure requirements concerning SIF;

8. Compliance with respect to branding and advertising requirements;

9. Whether AMC has complied with other requirements related to risk management, investor protection, disclosures and reporting. ***** Page 6 of 6