IFSCA circular · 05 Aug 2025
Page 1 of 21 MASTER CIRCULAR e.File No. IFSCA-PLNP/80/2024-Capital Markets August 05, 2025 To, All Investment Advisers in the International Financial Services Centre (IFSC) Madam/Sir, Sub: Master Circular for Investment Advisers in the IFSC 1. The IFSCA has notified International Financial Services Centres Authority (C…
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e.File No. IFSCA-PLNP/80/2024-Capital Markets August 05, 2025
To,
All Investment Advisers in the International Financial Services Centre (IFSC)
Madam/Sir,
Sub: Master Circular for Investment Advisers in the IFSC
The IFSCA has notified International Financial Services Centres Authority (Capital Market Intermediaries) Regulations, 2025 (“CMI Regulations”) with the objective of providing the regulatory framework for registration, regulation and supervision of capital market intermediaries, operating in the international financial services centres in India.
The Authority hereby issues this Master Circular to specify the requirements or directions on various provisions pertaining to Investment Adviser under the CMI Regulations.
This Master Circular is being issued in exercise of powers conferred by Sections 12 and 13 of the International Financial Services Centres Authority Act, 2019 read with regulation 45 of the CMI Regulations and shall come into force from the date of its issuance.
A copy of this circular is available on the website of the International Financial Services Centres Authority at www.ifsca.gov.in.
Yours faithfully,
Arjun Prasad General Manager arjun.pd@ifsca.gov.in
CHAPTER - I: REGISTRATION PROCESS ................................................................................... 4
CHAPTER - II: VALIDITY OF REGISTRATION .......................................................................... 7
CHAPTER - III: PERMISSIBLE ACTIVITIES ............................................................................... 8
CHAPTER - IV: GOVERNANCE....................................................................................................... 9
CHAPTER - V: CODE OF CONDUCT............................................................................................10
CHAPTER - VI: KYC AML & CFT GUIDELINES ........................................................................11
CHAPTER - VII: GENERAL GUIDELINES FOR INVESTMENT ADVISERS.........................12
CHAPTER - VIII: DEALING WITH CONFLICTS OF INTEREST............................................14
CHAPTER - IX: OUTSOURCING OF ACTIVITIES.....................................................................15
CHAPTER - X: COMPLAINT HANDLING AND GRIEVANCE REDRESSAL ........................16
CHAPTER - XI: CHANGE IN CONTROL......................................................................................17
CHAPTER - XII: PERIODIC REPORTING ..................................................................................18
CHAPTER - XIII: CYBER SECURITY AND CYBER RESILIENCE ..........................................19
CHAPTER - XIV: SURRENDER OF REGISTRATION...............................................................20
1.1. The Hon’ble Finance Minister, in the Union Budget for FY 2023-24 announced - “Implementation of a single window IT-enabled system for application processing of entities desirous of setting up operations in GIFT IFSC to improve the Ease of Doing Business (EoDB)."
1.2. Towards this end, IFSCA has operationalised a Single Window IT System (SWIT System/ SWITS), which, inter-alia, contains a Common Application Form (CAF), created by merging several existing forms including business-specific Annexure Forms. The SWITS aims to harmonise and simplify the process of submission of application under the Acts specified under the First Schedule of the IFSCA Act, 2019, including any regulations or framework issued thereunder, in addition to the Special Economic Zones (SEZ) Act, 2005. The Application Form (Form-FA) for seeking Letter of Approval (LoA) from the Administrator (IFSCA) under the SEZ Act, 2005 is also the part of the SWITS and is integrated with the SEZ Online System.
1.3. Apart from this, the SWITS also integrates within itself a No objection Certificate (NoC) processing module that will ease the process of obtaining NOCs, wherever necessary, from the appropriate regulators viz. RBI, SEBI or IRDAI. In addition, SWITS also provides the facility for an entity to apply for Goods and Services Tax Number (GSTN), thereby simplifying the tax registration for businesses. Further, SWITS also enables the online payment of fees in USD for entities desirous of setting up operations in IFSC.
1.4. The link for accessing the SWITS platform is https://swit.ifsca.gov.in.
1.5. An entity desirous of seeking registration as an Investment Adviser with the Authority shall submit/file its applications exclusively through SWITS1 for seeking-
1.6. For more details, please refer to the circular titled “Single Window IT System inter-alia for registration and approval from IFSCA, SEZ authorities, GSTN, RBI, SEBI and IRDAI” issued by IFSCA on September 30, 2024 in this regard.
2.1. An applicant seeking registration as Investment Adviser under the CMI Regulations shall pay the application fee, as specified in Schedule-I of the circular titled “Fee structure for the entities undertaking or intending to undertake permissible activities in IFSC or seeking guidance under the Informal Guidance Scheme” (“IFSCA Fee Circular”) dated April 08, 2025, read with circular titled “Clarifications on the Fee structure for the entities undertaking or intending to undertake permissible activities in IFSC or seeking guidance under the Informal Guidance Scheme” dated April 23, 2025, at the time of making an application to the Authority. If an application is not accompanied by the mandated application fee, such an application shall not be considered by the Authority.
2.2. On intimation of the decision by the Authority to grant in-principle approval, the applicant shall, within 15 days of such an intimation, pay the applicable registration fees as specified in Schedule-I of the IFSCA Fee Circular.
2.3. In those cases where the applicant fails to pay the requisite registration fees within the specified time, it shall be presumed that the applicant does not wish to continue the process. In such a case, the Authority may at its discretion reject the application. An application once rejected, shall be treated as non-est. The rejection of the application, however, shall not render the entity ineligible for making a fresh application.
2.4. In case the Authority decides not to grant a registration to an applicant to whom a provisional / in-principle approval has been granted, the fees paid by the applicant towards obtaining licence, registration, recognition or authorization fee shall not be refunded.
2.5. The fees as specified in the Schedule-I of the IFSCA Fee Circular shall be paid to the following account of the Authority in USD:
Account Name: International Financial Services Centres Authority Account Number: 970105000174 Type of Account: USD Current Account Bank Name: ICICI Bank Limited SWIFT Code: ICICINAAXXX NOSTRO Details: CHASUS33XXX JP MORGAN CHASE BANK NA, NEWYORK, USA Account no: 833999532
2.6. An applicant from India (other than an entity already set up in IFSC) desirous of getting registration from the Authority shall have the option to pay only the application fee and registration fee, as specified in the Schedule-I of the IFSCA Fee Circular, in INR into the following account of the Authority:
Account Name: IFSCA FUND 2 Account Number: 39907189884 Name of the Bank: State Bank of India Type of Account: INR Current Account IFSC Code: SBIN0060228
Regulation 5 of IFSCA (Capital Market Intermediaries) Regulations, 2025. ↩
