Alerts & Updates 12th Jan 2026

GICs Re-Engineered: IFSCA’s 2025 Reset and What It Unlocks

Authors

Vinod JosephPartner | Mumbai
Saloni KhaitaniAssociate | GIFT City

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  • On December 24, 2025, the International Financial Services Centres Authority (IFSCA) notified the IFSCA (Global In-House Centres) Regulations, 2025 (“2025 GIC Regulations”), which replaces and repeals the earlier IFSCA (Global In-House Centres) Regulations, 2020 (“2020 GIC Regulations”). The 2025 GIC Regulations came into force on the day it was notified with a 90-day transition period for existing units.

    The overarching objective of the 2025 GIC Regulations is to position India’s International Financial Services Centres (IFSCs), notably Gujarat International Finance Tech-City (GIFT City), as a globally competitive hubs for high-value financial services and related activities, and to onshore financial services and support functions currently undertaken in offshore jurisdictions.

    Please find below the key differences between the 2025 GIC Regulations and the 2020 GIC Regulations.

    Subject 2020 GIC Regulations 2025 GIC Regulations
    Eligible Entities The member of any ‘Financial Services Group’ was eligible to register as a GIC.
    Any group in which one entity was regulated by a financial services regulator/other competent body in its home jurisdiction qualified as a Financial Services Group.
    The member of any ‘Financial Institution Group’ is eligible to register as a GIC.
    A Financial Institution Group has been defined to mean a group in which one or more entities are involved in providing financial services or carrying out financial activities. The requirement under the 2020 GIC Regulations for one entity in the group to be regulated by a financial services regulator/other competent body in its home jurisdiction has been removed.
    The 2025 GIC Regulations has provided an inclusive list of arrangements/ relationships to determine the group entities of a Financial Institution Group, which are (i) parent–subsidiary (ii) joint venture ; (iii) associate; (iv) common brand name; (v) investment in equity shares or capital contribution of 20 per cent and above; (vi) being part of a network.
    Services to Indian Residents GICs could provide services only to non-resident entities GICs can also provide services to Indian entities, subject to a revenue cap of 10% of the GIC’s total annual income.
    However, the migration of existing Indian contracts into an IFSC GIC is expressly prohibited.
    Scope of services GICs were permitted to provide support services to any financial services group for “carrying out financial services in respect of a financial product”. GICs are permitted to provide services relating to financial products and financial services to any Financial Institution Group.
    Operating Model Did not mandate any operating models. Each GIC needs to operate under one of the operating models mentioned in the 2025 GIC Regulations, viz Captive Centre, Build-Operate-Transfer, Joint Venture, Hybrid or any other model as may be permitted by the Authority.
    Relocation of Indian employees Only supervisory personnel can be relocated to IFSC GIC from Indian entity with prior IFSCA approval, subject to a limit of 20% of the total strength in such category. Silent on relocation.
    Minimum number of local employees None specified Every GIC should have a principal officer and compliance officer as full-time employees of the GIC, in the IFSC.
    ELP Comments
    • While the 2020 GIC Regulations were largely enabling in nature i.e., focused on attracting captive centres into GIFT IFSC, the 2025 GIC Regulations reflect IFSCA’s intent to scale complexity, governance and strategic relevance of GICs. The new regime specifies the operating models that can be adopted by a GIC, tightens governance expectations, permits measured India-linked activity, and squarely positions IFSCs as hubs for high-value financial and financial-adjacent services, rather than mere offshore support functions.
    • The scope of permitted services for GICs has been modified, but it does not appear to have changed substantially. Under the 2020 GIC Regulations, GICs were permitted to provide support services to any financial services group for “carrying out financial services in respect of a financial product”. Under the 2025 GIC Regulations, GICs are permitted to provide services relating to financial products and financial services to any Financial Institution Group.
    • Under the 2020 GIC Regulations, a “financial services group” had to be regulated by a financial services regulator or any other competent body regulating financial services activities in its home jurisdiction. Under the 2025 GIC Regulations, a Financial Institution Group need not be regulated by any financial services regulator other competent body in its home jurisdiction has been removed. This change has widened the universe of entities eligible to set up a GIC in GIFT-IFSC.
    • It appears that IFSCA does not want GICs to be set up in GIFT-IFSC to cater to Indian clients. However, the total ban under the 2025 GIC Regulations has been replaced with a semi-prohibition since a GIC can have some Indian clients, provided not more than 10% of the GICs revenue is from Indian clients. On the other hand, the restrictions in the 2020 GIC Regulations on relocation of employees from an existing Indian entity to a GIC have been removed and Financial Institution Groups which have an existing presence in India can freely relocate their employees to their GIC Units in the IFSC. This clearly signals a regulatory intent to encourage Indian businesses to set up GICs in GIFT-IFSC, albeit to cater to foreign clients.
    • The 90-day transition period for existing GIC units to adhere to the requirements under 2025 GIC Regulations appears to be intended to give existing GICs some time to hire a PO and CO.

    The 2020 GIC Regulations can be found here.

    We trust you will find this an interesting read. For any queries or clarifications please write to us at insights@elp-in.com or write to our authors:
    Vinod Joseph, Partner – Email- Emailvinodjoseph@elp-in.com
    Saloni Khaitani, Associate – Email- Emailsalonikhaitan@elp-in.com

Disclaimer: The information provided in this update is intended for informational purposes only and does not constitute legal opinion or advice.

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