Unified Registration and Master Key for Capital Market Intermediaries in GIFT-IFSC

On January 7, 2026, the International Financial Services Centres Authority (IFSCA) modified the IFSCA (Capital Market Intermediaries) Regulations, 2025 (CMI Regulations) via the International Financial Services Centres Authority (Capital Market Intermediaries) (Amendment) Regulations, 2026 (Notification No. IFSCA/GN/2026/005) to introduce a unified registration framework for units in an International Financial Services Centre (IFSC) undertaking multiple capital market intermediary activities. The key legal change is the insertion of a proviso to Regulation 4(1) of the CMI Regulations. While the principal framework required a separate certificate of registration for each capital market activity, the new proviso now permits a unit in IFSC that is desirous of undertaking multiple activities to obtain a single, unified registration, referred to as the Master Key (MKY), covering those activities, in such manner as may be specified by IFSCA. This enables a consolidated authorisation instead of multiple, activity-wise registrations.

Pursuant to this enabling amendment, IFSCA has issued a circular on February 13, 2026 (IFSCA Circular) introducing the Master Key mechanism.

Under this framework, the eligible capital market intermediaries are:

• Broker Dealer;
• Clearing Member;
• Credit Rating Agency;
• Custodian;
• Debenture Trustee;
• Depository Participant;
• Distributor;
• ESG Ratings and Data Products Provider;
• Investment Adviser;
• Investment Banker; and
• Research Entity.

The above-listed capital market intermediaries may file one common application through the Single Window IT System (SWIT) portal, selecting one or more activities they intend to undertake in the IFSC.

On approval, the entity will receive a single certificate of registration that will list all permitted activities instead of multiple separate certificates. However, the amendment and the accompanying circular preserve IFSCA’s activity-wise risk and supervisory framework by requiring the applicant to continue paying application, registration, annual and other recurring fees separately for each activity, in accordance with the applicable fee circular.

The International Financial Services Centres Authority (Capital Market Intermediaries) (Amendment) Regulations, 2026 (Notification No. IFSCA/GN/2026/005) can be found here.

IFSCA’s Circular dated February 13, 2026, can be found here.

We hope you have found this information useful. For any queries/clarifications, please write to us at insights@elp-in.com  or write to our authors:

Vinod Joseph, Partner – Email – vinodjoseph@elp-in.com

Paridhi Jain, Associate – Email – paridhijain@elp-in.com