**Executive Summary**
This circular, issued by SEBI on January 08, 2026, addresses compliance reporting formats for Specialized Investment Funds (SIFs). It modifies the existing reporting formats for both the Compliance Test Report (CTR) and the Half-Yearly Trustee Report (HYTR) to ensure uniformity and clarity. The provisions of this circular are effective from January 08, 2026.
**Key Points / Main Content**
* **Applicability:** All reporting requirements applicable to mutual funds under the SEBI (Mutual Funds) Regulations, 1996, the MF Master Circular dated June 27, 2024, and any other circulars or guidelines issued thereunder, also apply to SIFs.
* **Compliance Test Report (CTR):**
* The CTR format, as prescribed under Format No. 2.B of the MF Master Circular, is modified to include an additional Part IV, as specified in Annexure A1.
* All Asset Management Companies managing SIFs must additionally report compliance under Part IV as part of the CTR submitted for Mutual Funds.
* **Half-Yearly Trustee Report (HYTR):**
* The HYTR format, as prescribed under Format No. 2.C of the MF Master Circular, is modified to include Clause 72A, as specified in Annexure A2.
* Trustees/Trustee Companies of Mutual Funds managing SIFs must additionally report compliance under Clause 72A as part of the HYTR submitted for Mutual Funds.
* **Annexure A1 (Part-IV of Compliance Test Report (CTR)):**
* Details regulations, particulars and remarks based on the compliance test of the various clauses under the regulation 49X, 49Y, 49AA, 49AB, 49AD and certain clauses mentioned under Annexure A of various circulars.
* **Annexure A2 (Clause 72A of HYTR):**
* Outlines compliance requirements for Specialized Investment Funds, covering areas such as AMC expertise, investment thresholds, fees, investment strategies, product differentiation, disclosure, and investor protection.
**Impact Analysis**
**Stakeholder**: All Mutual Funds
**Impact**
Need to comply with revised compliance reporting formats for Specialized Investment Funds (SIFs).
**Action Required**
Update internal systems and processes to incorporate the changes in CTR and HYTR formats as outlined in Annexures A1 and A2.
**Stakeholder**: All Asset Management Companies (AMCs)
**Impact**
Need to comply with revised compliance reporting formats for Specialized Investment Funds (SIFs).
**Action Required**
* Incorporate Part IV into the Compliance Test Report (CTR) for SIFs.
* Ensure compliance reporting includes Clause 72A for the Half-Yearly Trustee Report (HYTR).
**Stakeholder**: All Registrar and Share Transfer Agents (RTAs)
**Impact**
Indirectly affected by the changes in reporting requirements for SIFs.
**Action Required**
Be prepared to assist Mutual Funds and AMCs with any data or information needed for the updated reporting formats.
**Stakeholder**: All Trustee Companies/ Board of Trustees of Mutual Funds
**Impact**
Need to comply with revised compliance reporting formats for Specialized Investment Funds (SIFs).
**Action Required**
Ensure compliance reporting includes Clause 72A for the Half-Yearly Trustee Report (HYTR).
**Stakeholder**: Association of Mutual Funds in India (AMFI)
**Impact**
Responsible for disseminating information about the new reporting requirements to its members.
**Action Required**
Inform members about the circular and its implications for SIF compliance reporting.
Key Entities Referenced
Securities and Exchange Board of India (SEBI): The regulator issuing the circular to specify compliance reporting formats for Specialized Investment Funds.
Specialized Investment Funds (SIF): The main subject of the policy regarding compliance and reporting formats.
SEBI (Mutual Funds) Regulations, 1996: Regulations referenced within the circular, which dictate the reporting requirements for mutual funds, also applicable to Specialized Investment Funds.
MF Master Circular: The Master Circular for Mutual Funds, which dictates the reporting requirements for mutual funds, as referenced by this policy.
Compliance Test Report (CTR): A specified form used to report compliance and is modified by this policy.
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.
*****
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