**Executive Summary**
The document is a consultation paper on a "Guidance Framework on sustainable deposits and sustainable lending and investments." It outlines the evolution of sustainable finance products, global regulatory developments, and the sustainable finance landscape in India, including GIFT IFSC. The paper seeks comments and suggestions on the proposed circular by February 10, 2026.
**Key Points / Main Content**
* **Sustainable Finance Overview:**
* Sustainable finance considers environmental, social, and governance (ESG) factors in investment decisions.
* A significant annual financing shortfall exists to achieve Sustainable Development Goals (SDGs).
* **Evolution of Sustainable Finance Products:**
* Includes sustainable lending and trade finance, sustainable debt markets, and sustainable investments and asset management.
* Key lending products: green loans, social loans, sustainability loans, and sustainability-linked loans.
* Sustainable trade finance supports sustainable supply chains.
* Debt markets cover green, social, sustainability, and sustainability-linked instruments.
* Sustainable finance is increasingly embedded in investment and asset management practices.
* **Global Regulatory and Policy Developments:**
* Regulatory frameworks are shaping sustainable lending globally.
* Examples: Singapore's focus on climate risk disclosures and the Sustainable Loan Grant Scheme, Hong Kong's Taxonomy for Sustainable Finance, and Dubai's Sustainable Finance Framework.
* **Sustainable Finance Landscape in India:**
* India's sustainable finance market has expanded significantly.
* ESG-focused mutual funds and responsible investment practices are increasing.
* **Key Policy and Regulatory Developments in India:**
* SEBI's Business Responsibility and Sustainability Reporting (BRSR) framework.
* RBI initiatives to integrate climate-related financial risks.
* SEBI's frameworks for green, social, sustainability, and sustainability-linked debt instruments.
* **Regulatory Ecosystem for Sustainable Finance in GIFT IFSC:**
* IFSCA initiatives include becoming a member of Financial Centres of Sustainability (FC4S) Network, forming a committee for GIFT IFSC as a Sustainable Finance Hub, and issuing a 'Master Circular for ESG Ratings and Data Products Providers'.
* The fund management ecosystem has expanded to include dedicated ESG Schemes.
* IFSCA issued a 'Framework for Transition Bonds’ and a report on Alternate Risk Transfer (ART).
* **Sustainable Finance Trends in GIFT IFSC:**
* ESG-labelled debt listings on IFSC exchanges reached USD 15.73 billion.
* IFSC Banking Units (IBUs) disbursed sustainable financing amounting to USD 3.38 billion.
* **IFSCA 'Guidance Framework on sustainable deposits and sustainable lending and investments':**
* The modified Circular titled 'Framework for sustainable deposits and sustainable lending and investments' is placed at Annexure to this consultation paper.
* Enables IBUs to offer 'sustainable deposits' as a distinct product offering.
* Provides guidelines for IBUs and FC/FUs for undertaking sustainable investment activities in addition to sustainable lending and sustainable trade finance.
* Provides guidelines for undertaking 'Sustainable Trade Finance' in accordance with the 'Principles of Sustainable Trade Finance'.
* Provides guidelines for investment in 'sustainable products' such as ESG-labelled debt securities, Transition Bonds and ESG Schemes of Fund Management Entities (Funds').
* Introduces a revised target under which IBUs are required to ensure that at least 5 percent of the aggregate loans disbursed and investments made is deployed towards sustainable lending and/or sustainable investments.
* **Applicability of Draft Circular:**
* Circular applies to all IBUs and FC/FUs in IFSC.
* Encourages voluntary adoption of sustainable lending and investment practices.
* **Guidelines on Sustainable Lending:**
* Includes Green/Social and Sustainability-linked lending.
* Loans must align with Green Loan Principles, Social Loan Principles, or Sustainability-Linked Loan Principles.
* **Guidelines on Sustainable Deposits:**
* IBUs may offer 'sustainable deposits' as a distinct product offering.
* IBUs must adhere to the Accepting Deposits (ACDE) module.
* **Guidelines on Sustainable Investments:**
* IBUS/FC/FU must invest in sustainable financial products, including ESG labelled debt securities, Transition Bonds, and ESG Funds/ Schemes.
* **Target for IBUs:**
* Each IBU should deploy at least 5% of aggregate loans disbursed and investments towards sustainable lending/investments.
* **External Review:**
* IBU/FC/FU to arrange an external review of its policy on sustainable lending/investment.
* **Third Party Verification / Assurance:**
* Allocation of funds to be subject to annual independent third-party verification/assurance.
* **Impact assessment**
*IBU/FC/FU with the assistance of external firms to assess annually the impact associated of the funds lent or invested through Impact Assessment report.
* **Reporting and Disclosures:**
* IBUs/FC/FUs to report information on sustainable deposits, green trade finance, and sustainable investments.
* To disclose policies, verification reports, and impact assessments on their websites.
* **Repeal and Saving:**
* Supersedes the circular dated April 26, 2022.
**Impact Analysis**
**Stakeholder:** International Financial Services Centres Authority (IFSCA)
* **Impact:** Implementing and overseeing the guidance framework for sustainable deposits and lending. Revising and broadening the scope of the Framework.
* **Action Required:** Issue and enforce the circular. Review and amend targets, as necessary.
**Stakeholder:** IFSC Banking Units (IBUs) and Finance Company/Finance Units (FC/FUs)
* **Impact:** Requires adherence to the guidelines on sustainable lending, deposits, and investments.
* **Action Required:** Offer sustainable deposits, invest in sustainable financial products, put in place policies, ensure compliance with targets, arrange for external reviews and third-party verifications, conduct impact assessments, and adhere to reporting and disclosure requirements. Ensure that 5% of disbursed loans are deployed towards sustainable lending.
**Stakeholder:** Public and Stakeholders
* **Impact:** Invited to provide comments and suggestions.
* **Action Required:** Submit comments/suggestions on the proposed circular to IFSCA by February 10, 2026.
Key Entities Referenced
IFSCA 'Guidance Framework on sustainable deposits and sustainable lending and investments': Proposed revision and broadening of the scope of the existing guidance framework related to sustainable lending and investments.
International Financial Services Centres Authority (IFSCA): The regulatory body issuing the consultation paper and the guidance framework for sustainable finance in GIFT IFSC.
International Financial Services Centre (IFSC): The location in India to which the consultation paper primarily applies to.
Securities and Exchange Board of India (SEBI): Indian regulator of the securities market that mandates the Business Responsibility and Sustainability Reporting (BRSR) framework.
Reserve Bank of India (RBI): India's central bank encouraging financial institutions to integrate climate-related financial risks.
Consultation paper on “Guidance Framework on sustainable deposits
and sustainable lending and investments”
A. Introduction:
1. Sustainable finance refers to the process of taking environmental, social and governance
(ESG) considerations into account when making investment decisions in the financial sector,
leading to more long-term investments in sustainable economic activities and projects1.
2. The United Nations Development Programme (UNDP) while highlighting the critical
importance of the sustainable finance ecosystem, notes that despite global wealth exceeding
USD 450 trillion, there remains an annual financing shortfall of approximately USD 4.2 trillion
required to achieve the Sustainable Development Goals (SDGs). Consequently, channeling
capital toward sustainable and climate-resilient activities via various financial products is a
global imperative2.
B. Evolution of Sustainable Finance Products
3. Over the past decade, global financial markets have witnessed the emergence of a diverse
range of sustainable finance products across lending, debt and capital markets. An overview
of these products is as below:
a. Sustainable Lending and Trade Finance:
(i) Key products in lending space include green loans, social loans, sustainability loans
(GSS) and sustainability-linked loans (SLLs). Frameworks issued by organisations
such as the Loan Market Association (LMA) in collaboration with Loan Syndications
and Trading Association (LSTA) and the Asia Pacific Loan Market Association
(APLMA) prescribe voluntary, market-based principles for the origination and
management of these instruments, which are widely referenced and increasingly
adopted across international loan markets.3
(ii) Sustainable trade finance has emerged as an important sub-segment within
sustainable lending. The International Chamber of Commerce (ICC) has, in October
20244, issued ‘Principles for Sustainable Trade Finance’, for voluntary, market led
adoption, reflecting growing recognition of the role of trade finance in supporting
sustainable supply chains5.
(iii) Transition finance has also gained momentum, marked by the publication of the Draft
Transition Loans Guide by the LSTA in October 2025, in collaboration with the LMA
1 Overview of sustainable finance - Finance - European Commission
2 UNDP leverages every dollar to promote investments of nearly $60 for Sustainable Development, shows
new report | United Nations Development Programme
3 https://www.lsta.org/content/sustainable-lending-library/
4 ICC Unveils New Principles for Sustainable Trade Finance to Combat Greenwashing - ESG News
5 2025-ICC-Principles-for-Sustainable-Trade-Finance.pdf
Page 1 of 7and APLMA. This development reflects increased focus on financing credible
decarbonisation pathways for emissions-intensive sectors.6
(iv) The GSS syndicated loan market has reached a significant scale with an aggregate
issuance of SLLs, Social Loans and Green Loans reaching over USD 600 billion7 as
on December 2024.
(v) Regionally, the EMEA (Europe, Middle East, and Africa) remains the market leader
accounting for around 49% of the global issuance. The EMEA and the Americas
together accounted for 84% of total sustainable loan issuance in 2024. Further, the
Asia Pacific (APAC) region continues to register steady growth8.
b. Sustainable Debt Markets
(i) Debt markets represent the most mature segment of sustainable finance globally.
By mid-2025, the sustainable debt market, covering green, social, sustainability
and sustainability-linked instruments, exceeded USD 6 trillion9.
(ii) In 2025, market estimates from Climate Bonds Initiative indicate that over USD 550
billion of GSS+10 bonds raised in the first half of the year. Green bonds continue to
dominate this market, accounting for largest share of sustainable debt issuance,
followed by sustainability and social bonds11. Sustainability-linked bonds have also
gained momentum, enabling issuers to embed sustainability performance targets
(SPT) directly into bond structures rather than restricting proceeds to specific
projects.
(iii) Recent global issuance trends across sustainability themes (January–July 2025)
demonstrate continued uptake across both lending and debt markets, reflecting
growing market acceptance of various products in this space12.
c. Sustainable Investments and Asset Management
(i) Beyond lending and debt markets, sustainable finance has also become
increasingly embedded in investment and asset management practices as
evidenced by the UN World Investment Report 2025 which outlines the growth of
sustainable funds across the world.
(ii) As per this report, ESG integration is widely being adopted by global asset
managers and institutional investors, who increasingly recognise ESG risks as
financially material. The growth of thematic and impact funds focused on clean
energy, climate solutions, water, and social infrastructure reflects strong investor
6 Transition Loans Guide - LSTA
7 Sustainable Debt in Focus: 2024 Summary and 2025 Outlook
8 Green and Sustainability-Linked Loan Newsletter - BBVA CIB
9 Sustainable Debt Global State of the Market Q1 2025 | Climate Bonds
10 Green, Social, Sustainability and Sustainability linked debt and transition bonds
11 Green Bonds Drive USD555bn Surge as Development Banks… | Climate Bonds
12 Global sustainable finance 2025: mixed results highlight regional differences | articles | ING Think
Page 2 of 7demand for investments that deliver measurable sustainability outcomes alongside
financial returns.
(iii) Additionally, passive investment products, such as ESG indices and exchange-
traded funds, have further accelerated capital allocation toward sustainability-
screened assets.
C. Global regulatory and policy developments:
4. Regulatory frameworks and policy initiatives are shaping how sustainable lending is
promoted and governed. Since 2021, sustainable finance policymaking has gained
momentum globally, with regulators increasingly adopting an enabling role alongside
prudential oversight. The key policy focus areas include sustainability disclosures,
development of taxonomies and sector and product specific measures across banking and
capital markets.13.
5. International experience demonstrates that financial regulators play an increasingly
important enabling role in scaling sustainable finance markets. The key developments in
this context are as below:
a. Singapore: The Monetary Authority of Singapore (MAS) has focused on climate
risk disclosures, data comparability, credible transition planning, carbon markets
and blended finance14. Notably, MAS launched the Sustainable Loan Grant
Scheme in 202115 which supports corporates to obtain sustainable and transition
financing by defraying the expenses of engaging independent service providers to
validate the sustainability credentials of the loan. Singapore has recorded over
SGD 48 billion in green, social, sustainability, and sustainability-linked (GSSSL)
loans issued in 202416.
b. Hong Kong: The Hong Kong Monetary Authority (HKMA) has published the Hong
Kong Taxonomy for Sustainable Finance in May 2024. The taxonomy is intended
to provide finance professionals with consistent and internationally recognised
definition of “green” and “environmentally sustainable” economic activities. It has
also introduced supervisory expectations for green and sustainable banking and
supports market development through capacity-building initiatives and
international regulatory cooperation17. The HKMA via its Sustainable Finance
Action Agenda18 aims to support the growth of deep and liquid green and
sustainable debt markets, complemented by capacity building, data infrastructure,
and the establishment of dedicated sustainable finance institutions19.
c. Dubai: The Dubai International Financial Centre (DIFC) has implemented
principles-based sustainability expectations, notably through its Sustainable
Finance Framework launched in 2023, requiring entities to manage climate-related
risks, report on environmental and social impacts, and align with UAE-wide
13 World Investment Report 2025: International investment in the digital economy
14 https://www.mas.gov.sg/development/sustainable-finance/regulatory-and-supervisory-approach
15 https://www.mas.gov.sg/schemes-and-initiatives/sustainable-loan-grant-scheme
16 Singapore sustainable bond issuances jump 80 per cent to S$13.3 billion in 2024: MAS | Singapore EDB
17 HKMA Published Hong Kong Taxonomy for Sustainable Finance - HK Green Finance Association
18 Hong Kong Monetary Authority - HKMA unveils Sustainable Finance Action Agenda
19 Hong Kong Monetary Authority - HKMA unveils Sustainable Finance Action Agenda
Page 3 of 7initiatives for green finance and ESG disclosures, aiming to channel capital into
sustainable projects with clear governance and transparent reporting.
D. Sustainable Finance landscape in India:
6. India’s sustainable finance market has expanded significantly in recent years. As per the
India Sustainable Debt State of the Market 2024 report published by the Climate Bonds
Initiative20, India’s cumulative aligned GSS+ debt reached USD 55.9 billion as of
December 2024, reflecting a 186% increase since the last Climate Bonds Report on India
in 2021. Further, Green debt dominates the market, accounting for 83% of total issuance.
7. On the investment side, ESG-focused mutual funds, sustainability indices, and responsible
investment practices are also gradually expanding, supported by rising institutional and
retail investor awareness21.
E. Key Policy and Regulatory Developments in India
8. Regulatory and policy initiatives have played a critical role in shaping India’s sustainable
finance ecosystem. Enhanced ESG disclosure norms for listed companies, most notably
the mandatory Business Responsibility and Sustainability Reporting (BRSR) framework
introduced by the Securities and Exchange Board of India (SEBI)22 have strengthened
transparency, comparability, and market discipline by requiring standardised reporting on
environmental, social, and governance performance.
9. The Reserve Bank of India (RBI) has also encouraged financial institutions to integrate
climate-related financial risks into their risk management frameworks23 and has introduced
initiatives such as the Sovereign Green Bonds framework24 and ‘Directions on Climate
Finance and Management of Climate Change Risks’, applicable to commercial banks25
and Non-Banking Financial Companies26, to mobilise savings/ investments toward
environmentally sustainable activities. Consequently, ‘Green deposits’ have witnessed
encouraging uptake across public and private sector banks. Notably, in FY 2024-25, Bank
of Baroda mobilised over INR 1000 crore27 and SBI mobilised over INR 120 crore28 of
green deposits, with other banks also reporting growing participation.
10. In the capital markets space, SEBI has developed and implemented frameworks for green,
social, sustainability, and sustainability-linked debt instruments that are aligned with
internationally recognised standards, with enhanced disclosure, reporting, and third-party
review requirements to promote transparency, credibility and investor confidence.
20 Climate-Bonds_India_Sustainable_Debt_SotM_2024_Jun-2025.pdf
21 ESG Investing in India: Navigating Key Factors | IBEF
22 SEBI | BRSR Core - Framework for assurance and ESG disclosures for value chain
23 How RBI is looking to tackle climate-related financial risks, ETBFSI
24 https://rbidocs.rbi.org.in/rdocs/content/pdfs/FSGB06012023.pdf
25 Reserve Bank of India (Commercial Banks - Climate Finance and Management of Climate Change Risks)
Directions, 2025 (Master Directions - Reserve Bank of India)
26 Master Directions - Reserve Bank of India
27 BOB AR 2024-25.pdf
28 https://sbi.bank.in/documents/17826/35696/Annual+Report+FY2025.pdf/1b6a1b79-a16d-b9d1-d28f-
be8d7edf60d5?t=1745556744202
Page 4 of 7F. Regulatory ecosystem for Sustainable Finance in GIFT IFSC:
11. The International Financial Services Centres Authority (IFSCA) has transitioned to
implementing structured frameworks that meet international standards. Some of the recent
initiatives in this context are29:
• IFSCA became a member of Financial Centres of Sustainability (FC4S) Network in
202230.
• A dedicated committee was formed to recommend an approach towards development
of GIFT IFSC as a Sustainable Finance Hub and provide a road map for the same.
The committee report was published in October 2022.31.
• IFSCA issued a ‘Master Circular for ESG Ratings and Data Products Providers’ in
the IFSC’ under the IFSCA (Capital Market Intermediaries) Regulations, 202532.
• The fund management ecosystem of GIFT IFSC has expanded to include dedicated
ESG Schemes as part of the IFSCA (Fund Management) Regulations, 202533.
• Transition Finance: Based on ‘Report on Transition Finance’ by the Expert
Committee on Climate Finance, the ‘Framework for Transition Bonds’34 was issued
by IFSCA in July 2025, providing a pathway for high-carbon industries to access
sustainable capital.
• Alternate Risk Transfer (ART): In July 2025, a dedicated Working Group released a
report on the feasibility of issuing insurance-linked securities, such as catastrophe
bonds, to manage growing climate change and urbanisation risks35.
G. Sustainable Finance – Trends in GIFT IFSC:
12. GIFT IFSC has rapidly emerged as a key hub for green and sustainable capital. As of
September 30, 2025, the ecosystem has achieved significant scale across debt and credit
segments as below36:
• ESG-Labelled Debt: Cumulative ESG-labelled debt listings on IFSC exchanges
reached USD 15.73 billion, as on September 202537.
• Sustainable Lending: IFSC Banking Units (IBUs) disbursed sustainable financing
amounting to USD 3.38 billion in FY 2024–25. Further, as of September 2025, the
29 IFSCA Annual Reports and Bulletin (https://ifsca.gov.in/ReportPublication/index/zcGvy-Iqfcg=)
30 The Financial Centres for Sustainability (FC4S) Network is a growing collective of the world’s financial centres
which is supported by UNDP Secretariat. It consists of 39 members and the entities representing financial
centres include regulators, public‐private agencies, and market associations. (IFSCA Annual Report 2022-23-
https://ifsca.gov.in/ReportPublication/index/zcGvy-Iqfcg=)
31 https://ifsca.gov.in/ReportPublication/index/aadg9ruDI%20M=
32 International Financial Services Centres Authority
33https://www.ifsca.gov.in/CommonDirect/ViewFile?id=21626bde60601ef44a0ed022017f9e07&fileName=IFS
CA__Fund_Management__Regulations__2025__Amended_up_to_July_30__2025__20250818_0105.pdf
34https://ifsca.gov.in/CommonDirect/GetFileView?id=21626bde60601ef44a0ed022015b43b6&fileName=Circul
ar_on_Framework_for_Transition_Bonds_290725__1__20250729_0655.pdf&TitleName=Legal
35 Report of the Expert Committee on Development of Pension Products at GIFT IFSC submitted to IFSCA
36 IFSCA Annual Reports and Bulletin (https://ifsca.gov.in/ReportPublication/index/zcGvy-Iqfcg=)
37 IFSCA Bulletin: Q2 -2025-26.
Page 5 of 7cumulative sustainable lending facilitated through IFSC stands at approximately USD
4 billion38.
H. IFSCA ‘Guidance Framework on sustainable deposits and sustainable lending and
investments’
13. IFSCA had issued the “Guidance framework on Sustainable and Sustainability linked
lending by financial institutions (Guidance framework)” on April 26, 2022, which provided
guidance to entities (IBUs and FC/FUs) in IFSC for lending towards green/ social/
sustainable projects/purposes including short-term financing in such areas.
14. Taking into account the increasing momentum seen in the sustainable lending sector (refer
above) stakeholder feedback and alignment with international best practices, it is proposed
to revise and broaden the scope of the Framework. Accordingly, the modified Circular titled
‘Framework for sustainable deposits and sustainable lending and investments’ is placed
at Annexure to this consultation paper.
15. Key features of the modified circular are as below:
(i) Enables IBUs to offer ‘sustainable deposits’ as a distinct product offering. The funds
raised from these deposits may be used by IBUs to invest in eligible sustainable products
(such as ESG labelled debt securities among others) and to provide loans for such
activities/projects classified under the green or social category under the framework.
(ii) Provides guidelines to IBUs and FC/FUs for undertaking sustainable investment
activities in addition to sustainable lending and sustainable trade finance.
(iii) Provides guidelines for undertaking ‘Sustainable Trade Finance’ in accordance with
the ‘Principles of Sustainable Trade Finance’ issued by the International Chamber of
Commerce (ICC) in October 2024.
(iv) Provides guidelines for investment in ‘sustainable products’ such as ESG-labelled
debt securities, Transition Bonds and ESG Schemes of Fund Management Entities
(Funds’).
(v) Introduces a revised target under which IBUs are required to ensure that, in each
financial year, an amount equivalent to at least 5 per cent of the aggregate loans disbursed
and investments made (in debt securities and funds), in the immediately preceding
financial year is deployed towards sustainable lending and/ or sustainable investments, in
accordance with the directions of the circular.
I. Comments/ Feedback:
16. Comments/ suggestions are invited from the public and stakeholders on the proposed
circular through email to Mr. Lobhas Khairnar, Manager, IFSCA at
lobhas.khairnar@ifsca.gov.in and Mr. Nishil Patel, Consultant, IFSCA at
nishil.patel@govcontractor.nic.in on or before February 10, 2026, in the format provided
below. The comments may be provided in MS Word and MS Excel only.
38 IFSCA Annual Reports and Bulletins.
Page 6 of 7J. Format for providing comments/ suggestions:
Name, Designation of the person
Contact No.
Name of Organisation
Page Paragraph/ Sub- Comments / Rationale
no. of Clause No. Clause Suggestions
draft No.
Circular
*****
Page 7 of 7Annexure
DRAFT CIRCULAR
File No. ____________ Date: __________
To,
All IFSC Banking Units (IBUs) and Finance Company/Finance Units (FC/FUs) in the
International Financial Services Centre (IFSC)
Guidance Framework on sustainable deposits and sustainable lending and investments
1. The International Financial Services Centers Authority (“the Authority”) had issued the
‘Guidance Framework on Sustainable and Sustainability linked lending by financial
institutions (Guidance Framework)’ on April 26, 2022.
2. Based on input received from the stakeholders and keeping view of the evolving international
best practices, the Authority in supersession of the Guidance Framework, hereby issues the
“Framework for sustainable deposits and sustainable lending and investments”
3. Applicability: This Circular shall apply to
i. all IBUs and
ii. FC/FUs undertaking core activity as specified under regulation 5(1)(i)(a) of the ‘Finance
Company Regulations’ are encouraged to voluntarily adopt sustainable lending and
investment practices in-line with the directions of this circular.
The directions under Part B shall not apply to the FC/FUs given that acceptance of
deposits is not permitted for such entities under the IFSCA (Finance Company)
Regulations, 2021.
4. Part A: Guidelines on sustainable lending
A.1 - Green/Social and Sustainability-linked lending
(i) Green/Social lending refers to any type of loan instrument and/or contingent facility where
the proceeds are exclusively applied to finance, refinance, or guarantee, in whole or in part,
new and/or existing eligible green or social projects/activities39, which are aligned with the
39 An indicative list of eligible green/ social projects/ activities has been provided in Appendix I for reference.
Page 1 of 12principles and directions outlined in these guidelines.
(ii) Sustainability-linked lending refers to any loan facility or contingent facility which incentivize
borrower's achievement of predetermined sustainability performance targets (SPTs),
measured using credible key performance indicators (KPIs). As an example - the margin under
the relevant loan agreement may be reduced where the borrower satisfies a pre-determined
SPT threshold, or increased if the target is not met, thereby incentivizing material
improvements in the borrower’s sustainability profile.
(iii) For the purpose of this framework, the term “sustainable lending” shall include both
Green/Social lending and Sustainability-linked lending including Sustainable Trade Finance.
(iv) The loans offered by IBUs and specified FC/ FUs shall be labelled as ‘green loans’, ‘social
loans’, ‘sustainability-linked loans’ (as applicable) only if such loans are aligned with the
following principles (as applicable):
a) ‘Green Loans Principles’ jointly developed by Loan Market Association (LMA), Asia
Pacific Loan Market Association (APLMA) and Loan Syndication and Trading
Association (LSTA);
b) ‘Social Loan Principles’ jointly developed by LMA, APLMA and LSTA;
c) ‘Sustainability Linked Loan Principles’ jointly developed by LMA, APLMA and LSTA;
d) Any other globally recognized standards or any framework or methodology
specified by a Competent Authority in India or financial sector regulator in India;
e) Other international standards, as may be specified by the Authority from time to
time.
(v) The IBU/ FC/ FU (as the case may be) shall put in place a policy approved by its Board /
Governing body (as applicable) and such policy shall incorporate the principles laid down in at
least one of the aforementioned international standards / principles.
(vi) The core components of such policy shall cover, inter-alia, the following aspects:
Core components for policy on Green/ Core components for policy on
Social lending: Sustainability- linked lending:
Page 2 of 12a) Borrower assessment process;
a) Borrower assessment process;
b) Manner of selection of Key
b) The eligible green / social projects that
Performance Indicators (KPI);
may be financed (refer Annex I for
c) Setting the Sustainability
illustrative list of such projects) and
Performance Targets (SPT) (to be set
appropriate description of the same in
in mutual agreement between
the legal documentation of the loan
borrower and lender) and examining
facility;
appropriateness of the SPT;
c) Process to be adopted for project
d) Financial and/or structural
evaluation and selection;
characteristics to incentivise the
d) Process for monitoring and validating achievement of the SPT;
the performance of the borrower; e) Process for monitoring and validating
the performance of the borrower;
e) Process of review to ensure alignment
f) Process of review to ensure the
of the loan facility with the
alignment of the lending facility with
internationally acceptable principles
internationally acceptable principles
(to be negotiated and agreed between
(to be negotiated and agreed between
the lender and the borrower);
the lender and borrower on a
f) Reporting.
transaction-by-transaction basis);
g) Reporting.
(vii) The IBU/ FC / FU may choose to adopt the relevant policy of its parent for the purpose of
compliance with the requirements at (iv) above, provided such policy is consistent with the
aforementioned principles and encompasses the key components outlined above.
A.2 - Guidelines on sustainable trade finance
(i) The International Chamber of Commerce (ICC) has issued the ‘Principles for Sustainable
Trade Finance’40 in October 2024 which provides, inter-alia, detailed ‘Principles for Green
Trade Finance’. The IBU/ FC/ FU may provide ‘green trade finance’ as a product aligned
with the aforementioned principles.
(ii) Entities to have policy on Sustainable Trade Finance: For the purpose of such financing,
the IBU/ FC/ FU (as the case may be) shall put in place a policy approved by its Board/
Governing body (as applicable) and such policy shall duly factor in the principles laid down
40 https://iccwbo.org/publication/icc-standards-for-sustainable-trade-and-sustainable-trade-finance/
Page 3 of 12in aforementioned principles of ICC.
(iii) The IBU/ FU may choose to adopt the relevant policy of its parent for the purpose of such
lending, as long as the adopted policy is consistent with the principles mentioned above.
5. Part B: Guidelines on Sustainable Deposits :
(i) For purpose of undertaking sustainable lending/ financing/ investments, as outlined in this
circular, IBUs may offer ‘sustainable deposits’ as a distinct product offering to its customers.
(ii) IBUs may accept Sustainable Deposits (by whatever name called) as a ‘term deposit’.
The IBU shall adhere to the applicable provisions of the module on ‘Accepting Deposits
(ACDE)’ as specified in the IFSCA Banking Handbook on Conduct of Business with respect
to such deposits.
(iii) Policy: IBUs shall put in place policy for ‘acceptance and allocation of sustainable deposits’
approved by its Governing Body, laying down therein, all aspects for the issuance and
allocation of sustainable deposits. The allocation of proceeds raised from such deposits
shall be aligned to guidelines provided this circular. Deposits raised under the policy may
be temporarily invested for upto one (1) year from the date of raising the deposit in liquid
instruments\, as specified in the IBU’s policy, pending their deployment or allocation for the
purposes of sustainable lending and sustainable investment as outlined in this circular.
6. Part C: Guidelines on sustainable investments.
(i) IBUs/FC/FU shall put in place a policy, approved by its Board/ Governing Body, to
invest in sustainable financial products, both inside and outside IFSC which may
include, inter alia:
a. Debt Securities: Such investment may include -
(i) ‘ESG labelled debt securities’: such as those meeting the standards and
requirements outlined in the IFSCA (Listing) Regulations, 2024;
(ii) ‘Transition Bonds’: such as those which meet the requirements outlined
under the ‘IFSCA Framework for Transition Bonds’
b. ESG Funds/ ESG scheme: such as ESG fund/ scheme in IFSC as outlined in
IFSCA (Fund Management) Regulations, 2025;
c. Any other forms of investment as may be specified by the Authority.
Page 4 of 127. Part D: Target for IBUs:
(i) Each IBU shall ensure that, in each financial year, an amount equivalent to at least five
(5) per cent of the aggregate loans disbursed and investments made (in debt securities
and funds) in the immediately preceding financial year is deployed towards sustainable
lending and/ or sustainable investments, in accordance with the directions of this circular.
(ii) The target at 7(i) above shall apply as follows:
a. IBUs licensed and commenced business prior to issuance of circular shall ensure
compliance with the framework effective from the subsequent quarter on a pro-
rata basis of the annual target, as applicable.
b. IBUs commencing business post issuance of this circular shall be required to
comply with the framework from the financial year subsequent to commencement
of its operations.
8. The Authority may, as suitable, review and amend this target, from time to time. In case, the
IBU is unable to meet the above targets it shall report the same to the Authority explaining
the reasons for such non-compliance along with an action plan towards ensuring compliance
with this framework.
9. External review:
The IBU/ FC/FU (as applicable) shall arrange to carry out an external review of its policy on
sustainable lending and / or investment ensuring, inter-alia, that such policy meets the
requirements prescribed under the applicable international standards.
Provided that such external review shall not be required where the IBU/FU has adopted
the policy of its parent entity and the said policy has already been subjected to an external
review.
10. Third party verification / Assurance
(i) The allocation of funds raised through ‘sustainable deposits’ or otherwise towards
sustainable lending/ investments by the IBU or FC/FU (as applicable) during a financial
year shall be subject to an annual independent third-party verification / assurance. The
third-party verification / assurance shall not absolve the IBU/ FC/ FU of its responsibility
regarding the end-use of funds, for which it shall follow the laid down procedures of
internal checks and balances.
Page 5 of 12(ii) The IBU/ FC/ FU may engage any appropriate and reputed domestic / international
agency for undertaking third-party verification / assurance of the allocation of funds.
(iii) The third-party verification / assurance report shall, at minimum, cover the following
aspects:
a. Use of proceeds of sustainable deposits by the IBU in accordance with the
requirements of this circular.
b. It shall monitor the end-use of funds allocated towards sustainable lending/
investment.
c. Policies and internal controls of the IBU/ FC/FU (as applicable) towards raising of
funds via ‘sustainable deposits’ and allocation of funds for purposes mentioned in
this circular.
11. Impact assessment
(i) An IBU/ FC/ FU, as applicable, shall, with the assistance of external firms, assess annually
the impact associated of the funds lent or invested towards sustainable lending/
investment during a financial year through an Impact Assessment report.
(ii) In case an IBU/ FC/FU is unable to quantify the impact of their lending / investment, it
shall disclose, at the minimum, the reasons, the difficulties encountered, and the time-
bound plans to address the same.
12. Part E: Reporting and Disclosures:
(i) The IBUs/ FU/ FUs shall report to such information on its sustainable deposits, green trade
finance and sustainable investments as per the format prescribed by the Authority.
(ii) The IBUs/ FC/FUs shall also disclose information on its website pertaining to its sustainable
lending and investment which shall include the below, as applicable:
a) Policy on sustainable deposits and its allocation;
b) Policy on green/ social / sustainability-linked lending;
c) Policy on green trade finance.
d) the Third-Party Verification / Assurance Report and Impact Assessment Report.
Page 6 of 1213. This circular is issued in exercise of powers conferred by Section 12 and 13 of the
International Financial Services Centres Authority Act, 2019, and shall come into force from
April 01, 2026.
14. Repeal and Saving:
(i) With the issuance of this circular, the circular titled ‘Guidance framework on Sustainable
and Sustainability linked lending by financial institutions’ dated April 26, 2022, issued by
the Authority shall stand repealed.
(ii) Any reference in other Circulars/ Guidelines/Notifications containing reference to the said
repealed Circular, shall mean the reference to this Circular.
15. A copy of this circular is available on the website of the International Financial Services
Centres Authority at www.ifsca.gov.in
***
Page 7 of 12Appendix I
Indicative List (examples only) of Eligible Green and Social categories
(I) Examples of eligible green categories:
No Eligible Illustrative Eligible Green Projects
. Green
Categories
1. Renewable • Generation of electricity from Renewable Energy (RE)
Energy sources such as wind (onshore & offshore), solar,
hydropower <25 MW or >25MW which have either a
lifecycle carbon intensity of ≤100gCO2/kWh or power
density ≥5W/m2 (4), waste to energy, geothermal
energy or production of biofuels from waste sources.
• Development and/or manufacture of renewable
energy technologies, including equipment for
renewable energy generation and energy storage.
• Construction/ maintenance/ expansion of RE-
associated distribution networks.
(4) – Climate Bonds Initiative - Hydropower sector guide
(https://www.climatebonds.net)
2. Energy • Promotion of energy efficiency in industrial and
Efficiency commercial sectors through development,
manufacture and/or installation of technologies for
increasing operational energy efficiency of utilities and
reducing GHG emissions.
• Retrofit of renewable energy power plants.
• Energy efficiency in municipal projects – Street
Lighting projects.
• Energy efficiency in residential building, agricultural
equipment and transportation.
3. Pollution • Projects addressing reduction of pollution and waste
Prevention (e.g. air emissions, greenhouse gas control, soil
and Control remediation, waste prevention, waste reduction,
waste recycling and energy/ emission-efficient, waste
to energy etc.)
4. Sustainable • Activities that provide access to adequate sanitation
Water and facilities.
Wastewater • Activities that improve water quality (e.g. water
Management treatment facilities and upgrades to waste water
treatment plants to remove excess nutrients).
• Activities that increase water-use efficiency (e.g.
water recycling and reuse, water saving systems,
technologies and water metering).
• Water management/ treatment projects, distribution,
desalination and other projects that ensure
accessibility,
drinkability and security of water
• Sanitation infrastructure projects
• Projects, products and services to provide basic
sanitation and safe drinking water to society.
Page 8 of 125. Environment • Programs encouraging sustainable land use and
ally sustainable agriculture, including climate-smart
Sustainable agriculture which take into account climate mitigation
Management and adaptation measures.
of Living • Projects that promote a low carbon economy around
Natural sustainable agriculture and food security;
Resources
• Rehabilitation of sensitive and degraded ecosystems
and Land Use
through sound management practices and land use
planning.
• Projects that promote climate smart animal
husbandry,
sustainable aquaculture and fisheries, sustainable
management of natural resources and land use –
products, services and technologies.
6. Terrestrial • Conservation and enrichment of carbon pools in
and Aquatic natural ecosystems.
Biodiversity • Programs that encourage environmental
Conservation conservation and sustainable use of natural
resources.
7. Clean • Technology to replace or reduce the direct use of fossil
Transportatio fuels, which generate GHG.
n • Development of an effective, efficient, integrated
affordable and eco-friendly public transportation
system.
• Programs encouraging land use planning which
allows movement by cycling, walking and public
transport.
• R&D programs focusing on higher fuel efficiency and
alternative fuel.
• Incorporating green technology in transportation
infrastructure.
8. Climate • Activities that increase resilience of ecosystems such
Change as integrated watershed management.
Adaptation • Climate change adaptation infrastructure such as
flood defense systems.
9. Eco-efficient • Projects which focus on development of
and/or environmentally sustainable products, with an eco-
circular label or environmental certification and/or resource-
economy efficient packaging and distribution.
adapted • Production technologies and processes may relate to
products, design and introduction of reusable, recyclable and
production refurbished materials, components, circular tools and
technologies • services.
and
processes
10. Green • Construction of green buildings or retrofit of existing
Buildings buildings which meet regional, national or
internationally recognized standards or certifications
• (e.g. EDGE, BREEAM, LEED, Green Mark, GRIHA).
Page 9 of 12Exclusions:
(i) Projects involving new or existing extraction, production, and distribution of fossil
fuels, including improvements and upgrades; or where the core energy source is
fossil-fuel based.
(ii) Nuclear energy generation.
(iii) Direct waste incineration
(iv) Alcohol, weapons, tobacco, gaming, or palm oil industries.
(v) Renewable energy projects generating energy from biomass using feedstock
originating from protected areas. For the purpose of these Directions, feedstock
primarily includes sewage, manure, wastewater, bagasse, biomass, wood
pellets, etc.
(vi) Landfill projects.
Page 10 of 12(II) Examples of eligible social categories:
N Eligible Social Illustrative Eligible Social Projects
o Categories
.
1 Employment • Financing microfinance institutions and financing
. generation, and of SMEs that are often unable to gain access to
programs financial products and services, e.g.:
designed to • Rural populations focusing on agricultural
prevent and/or production and agricultural value chains.
alleviate • Small businesses that demonstrate gender
Unemployment equality at the board and/or ownership
stemming from level.
socio- economic • Provision of financing to businesses run by
crises, including
economically excluded individuals.
through the
• Financial inclusion through ease of access to
potential effect of
financial services and promoting financial literacy
SME financing and
• Commercial Vehicle Lending (for livelihood
Microfinance
purpose only)
2 Affordable Basic • Clean drinking water, sanitation, transport and
. Infrastructure energy (e.g. projects under the National Energy
Policy addressing access to electricity for all
households, including in rural areas).
• Construction, maintenance and equipment
for water supply infrastructure.
• Development of roads (including road
infrastructure with a goal to improve rural/
remote connectivity.
3 Access to • Access to health, education, vocational training,
. Essential Services healthcare, financing and financial services (e.g.
ramping up of health and wellness centers in rural
and urban areas)
• Infrastructure for the provision of emergency
medical response and disease control services.
• Supporting health-care related products and
services such as provision/ distribution of
healthcare equipment and R&D and manufacturing
for equipment for the provision of emergency
medical response and disease control services.
• Construction of public schools
• Training for educational professionals that is
accessible to the public/ low-income individuals.
4 Affordable • Access to adequate, safe and affordable housing
. Housing for excluded and/or marginalized populations.
Page 11 of 125 Food Security and • Physical social and economic access to safe,
. Sustainable Food nutritious and sufficient food, that meets the
Systems dietary needs and requirements;
• Resilient agricultural practices
• Reduction of food loss and waste
• Improved productivity of small scale producers
******
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