**Executive Summary**
This circular, issued by the International Financial Services Centres Authority (IFSCA) on January 16, 2026, outlines the procedure and clarifies the requirements for Registered Fund Management Entities (FMEs) filing scheme applications under Third-Party Fund Management Arrangements. It refers to the IFSCA (Fund Management) Regulations, 2025, and aims to streamline the application process. The circular takes immediate effect.
**Key Points / Main Content**
* **Application Filing Procedure:**
* Registered FMEs must submit documents as per the circular "Ease of doing business - Filing of Schemes or funds under IFSCA (Fund Management) Regulations 2022" dated April 05, 2024.
* All scheme applications must be filed via the IFSCA Single Window IT System (https://swit.ifsca.gov.in/).
* **Additional Required Documents/Information for Registered FMEs:**
* Full legal name, registered office, and proof of registration/license of the third-party fund manager from its home jurisdiction.
* A "look-through" chart showing the ultimate beneficial owners (UBOs) of the third-party fund manager.
* Names and profiles of the Board members/designated partners and key managerial personnel of the third-party fund manager.
* Complete details of Assets Under Management (AUM) and past investment strategies adopted by the third-party fund manager.
* A Declaration cum Undertaking confirming compliance with obligations and requirements specified under regulation 107 H and 107K of the FM Regulations.
* The document evidencing the third-party fund management arrangement between the Registered FME and the third-party fund manager.
* Outline of deal execution, disclosure of Conflict of Interest, if any, and remuneration policies of the third-party fund manager.
* Details related to the appointment or change of KMP(s) as specified under the FM Regulations.
**Impact Analysis**
**Registered Fund Management Entities (FMEs) authorised to provide Third-Party Fund Management Services**
* **Impact**
* Need to adhere to the specified procedure and documentation requirements for filing scheme applications under Third-Party Fund Management Arrangement.
* **Action Required**
* Update their application filing processes to comply with the circular's guidelines.
* Gather and submit all required documents/information as outlined in the circular when filing scheme applications.
* Ensure applications are filed through the IFSCA Single Window IT System.
Key Entities Referenced
International Financial Services Centres Authority (IFSCA): The regulatory authority issuing the circular and overseeing fund management in International Financial Services Centres.
Fund Management Entities (FMEs): Entities authorized to provide Third-Party Fund Management Services, the primary subject of this circular.
International Financial Services Centres Authority (Fund Management) Regulations, 2025 (‘FM Regulations'): Regulations governing Fund Management Entities and their activities, heavily referenced in the circular.
International Financial Services Centres Authority Act, 2019: The Act empowering IFSCA, cited as the basis for the circular's authority.
CIRCULAR
IFSCA/AIF/218/2025-Capital Markets January 16, 2026
To,
The Fund Management Entities (FMEs) authorised to provide Third-Party Fund
Management Services
Dear Sir/Madam,
Sub: Procedure and clarification on filing of scheme application under Third-Party
Fund Management Arrangement
1. Reference may be drawn to the International Financial Services Centres Authority
(Fund Management) Regulations, 2025 (‘FM Regulations’), in particular PART D of
Chapter VI pertaining to 'THIRD-PARTY FUND MANAGEMENT SERVICES’.
2. In order to streamline the process of filing of applications by the Registered FMEs
authorised to launch schemes on behalf of third parties, the Authority hereby
specifies and clarifies as follows:
i. Such Registered FMEs shall submit the format and documents as per the
circular titled ‘Ease of doing business - Filing of Schemes or funds under
IFSCA (Fund Management) Regulations 2022’ dated April 05, 2024.
ii. In addition to the above, such Registered FMEs shall provide the following
documents / information:
a. Full legal name, registered office of the third-party fund manager and
proof of its registration/license with regulatory authority of its home
jurisdiction;
b. A "look-through" chart showing the ultimate beneficial owners (UBOs) of
the third-party fund manager;
c. Names and Profile of the members of the Board or designated partners,
as applicable, and key managerial personnel or equivalent of the third-
party fund manager;d. Complete details of the Assets Under Management along with past
records of investment strategies adopted by third party fund manager,
similar to the proposed scheme to be launched by such Registered FME;
e. Furnish a Declaration cum Undertaking confirming, declaring and
undertaking the compliance of the obligations, criteria and the
requirements specified under regulation 107 H and 107K of the FM
Regulations
f. The document evidencing the third-party fund management arrangement
between such Registered FME and the third-party fund manager;
g. Outline of the deal execution, disclosure of Conflict of Interest, if any, and
remuneration policies of third-party fund manager; and
h. Details related to the appointment or change of KMP(s) as specified under
the FM Regulations or any circular issued thereunder in this regard.
3. All scheme applications shall be filed via the IFSCA Single Window IT System
(https://swit.ifsca.gov.in/).
4. This circular is issued in exercise of the powers conferred by Sections 12 and 13
of the International Financial Services Centres Authority Act, 2019, read with sub-
regulation (1) of regulation 146 of the FM Regulations, and shall come into force
with immediate effect.
5. A copy of this circular is available on the website of the International Financial
Services Centres Authority at www.ifsca.gov.in.
-Sd-
Mihir Upadhyay
(General Manager)
mihir.upadhyay@ifsca.gov.in