Extension of timeline for complying with the certification requirement for the key investment team of the Manager of AIF

## Report on SEBI Circular SEBI/HO/AFD/DPoD/CIR/2025/066 Regarding AIF Manager Certification **1. Executive Summary:** This report analyzes SEBI Circular SEBI/HO/AFD/DPoD/CIR/2025/066, issued on May 13, 2025. This circular is an *amendment* to existing regulations concerning the certification requirements for key investment teams of Alternative Investment Fund (AIF) managers. The core purpose of the amendment is to extend the deadline for compliance with the NISM Series XIX-C certification requirement from May 9, 2025, to July 31, 2025. The key finding is that this extension aims to provide ease of compliance to the AIF industry, based on industry representation. **2. Introduction:** This report aims to provide a comprehensive overview of SEBI Circular SEBI/HO/AFD/DPoD/CIR/2025/066, focusing on the amendment it introduces to the existing regulations regarding the certification of key investment teams of AIF managers. The analysis is based solely on the information provided in the circular's text. **3. Policy Overview:** * This circular amends the existing regulations regarding Alternative Investment Funds, specifically relating to Regulation 4(g)(i) of the SEBI Alternative Investment Funds Regulations, 2012 ("AIF Regulations"). * **Core Objective (Inferred):** To provide ease of compliance for the AIF industry regarding the certification requirements for key investment team members. **4. Background and Rationale:** This circular amends a previous timeline. The original policy required key investment teams of AIF managers to have at least one key personnel with relevant certification, as specified by SEBI. The notification issued on May 10, 2024, prescribed the NISM Series XIX-C: Alternative Investment Fund Managers Certification Examination for compliance. A subsequent circular on May 13, 2024, provided a compliance deadline of May 9, 2025, for existing AIF schemes and those with pending applications. The *rationale for this amendment* is based on representations received from the AIF industry. The extension of the deadline suggests that the industry likely faced challenges in meeting the original compliance date. **5. Key Provisions / Changes:** This circular *amends* the timeline for complying with the certification requirement. * **Specific Part of Original Policy Changed:** The timeline for complying with the certification requirement as specified in the circular dated May 13, 2024 (related to schemes of AIFs as on May 13, 2024, and schemes with pending applications as of May 10, 2024). * **New Rule/Provision:** The new deadline for obtaining the requisite NISM certification is July 31, 2025, instead of May 9, 2025. * **Difference/Effect of Change:** The change provides AIF managers with an additional two months and 22 days to ensure their key investment teams obtain the necessary NISM certification. This allows the AIF industry additional time to manage resources, schedule examinations, and achieve compliance. **6. Target Audience and Stakeholders:** The primary target audience and stakeholders directly affected by this amendment are: * Alternative Investment Funds (AIFs) * Managers of Alternative Investment Funds (AIFs) * Key investment teams of the Manager of AIF * Associated persons in the securities markets. **7. Implementation Aspects (Inferred):** * **Responsible Agency/Bodies:** The Securities and Exchange Board of India (SEBI) is the responsible agency, as evidenced by the issuance of the circular under the powers conferred by the Securities and Exchange Board of India Act, 1992. * **Timelines:** The key timeline specified is the extended deadline of **July 31, 2025**, for obtaining the NISM certification. The provisions of this circular came into force with immediate effect (May 13, 2025). * **Implementation Specifically related to the change:** AIF managers need to adjust their compliance plans to align with the new deadline. SEBI will likely monitor compliance with the extended deadline. **8. Expected Outcomes / Impact of Changes:** The likely intended outcome of this amendment is to: * Facilitate smoother compliance for AIFs with the certification requirements. * Reduce the potential for disruption or non-compliance due to the original deadline. * The AIF industry may see increased participation and a lower risk of regulatory penalties during the extended compliance window. * Contribute to the orderly development of the AIF market by ensuring adequate time for compliance with regulatory requirements. **9. Conclusion:** SEBI Circular SEBI/HO/AFD/DPoD/CIR/2025/066 extends the deadline for AIF managers to comply with NISM certification requirements for their key investment teams to July 31, 2025. This amendment, driven by industry feedback, aims to ease the burden of compliance and ensure a smoother transition to the new certification standards. This extension reflects SEBI's responsiveness to industry concerns and its commitment to fostering a healthy and compliant AIF market.

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