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Alerts & Updates 10th Mar 2026

SEBI operationalizes the SWAGAT-FI framework for FPIs and FVCIs

Authors

Vinod JosephPartner | Mumbai
Zaynali BadamiAssociate | GIFT City

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  • In December, SEBI amended the SEBI (Foreign Portfolio Investors) Regulations, 2019 (FPI Regulations) vide the SEBI (Foreign Portfolio Investors) (Second Amendment) Regulations, 2025 in order to introduce a “Single Window Automatic and Generalized Access for Trusted Foreign Investor” (SWAGAT-FI) framework for Foreign Portfolio Investors (FPI). SEBI also amended the SEBI (Foreign Venture Capital Investors) Regulations, 2000 (FVCI Regulations) vide the SEBI (Foreign Venture Capital Investors) (Amendment) Regulations, 2025, in order to introduce the SWAGAT-FI framework for Foreign Venture Capital Investors (FVCI).

    SEBI has now operationalized the SWAGAT-FI framework for FPIs through a circular dated January 16, 2026, bearing reference number HO/19/34/14(5)2025-AFD-POD2/I/2703/2026 (Jan 2026 FPI Circular). Vide yet another circular issued on the same day, bearing reference number HO/19/34/14(5)2025-AFD-POD2/I/199/2025 (Jan 2026 FVCI Circular), the SWAGAT-FI framework has been operationalized for FVCIs too.

    The Jan 2026 FVCI Circular modifies the Operational Guidelines for Foreign Venture Capital Investors and Designated Depository Participants dated September 26, 2024 (Operational Guidelines for FVCI’s). The Jan 2026 FPI Circular modifies the Master Circular for Foreign Portfolio Investors, Designated Depository Participants and Eligible Foreign Investors” No. SEBI/HO/AFD/AFDPoD2/P/CIR/P/2024/70 dated May 30, 2024 (FPI Master Circular).

    The principal relaxations that have been operationalized vide the Jan 2026 FPI Circular and the Jan 2026 FVCI Circular are:

    • Sub-para (i) of Para 4 of Part A of the FPI Master Circular, and sub-paras 1.5.1 and 1.5.2 of Chapter 1 of the Operation Guidelines for FVCI’s have been modified to allow SWAGAT-FI FPIs and SWAGAT-FI FVCIs to continue their registration for an extended block of ten years.
    • A sub-para has been added after sub-para (ii) of Para 5 of Part B of the FPI Master Circular, and a sub-para has been added after Para 2.6.2 of Chapter 2 of the Operational Guidelines for FVCIs, which has extended the periodic KYC review for SWAGAT-FI FPIs and SWAGAT-FI FVCIs to once every ten years.
    • A sub-para has been added after sub-para (ii)(da) under Para 1 of Part A of the FPI Master Circular, which has given effect to the exemption from aggregate contribution limits applicable to non-resident Indians, overseas citizens of India and resident Indian individuals investing through SWAGAT-FI structures.

    The January 2026 FVCI Circular and the January 2026 FPI Circular have also clarified that existing FPIs and FVCIs that satisfy the prescribed eligibility criteria for SWAGAT-FI may seek reclassification as SWAGAT-FI FPI or FVCI by submitting an application to their Designated Depository Participant.

    ELP Comments
    • SEBI’s SWAGAT FI framework explicitly identifies “trusted” FPIs/FVCIs using objective criteria (such as being government-related or appropriately regulated in FATF-compliant jurisdictions) and then offers them longer registration validity, less frequent KYC reviews and streamlined onboarding, which reduces friction and costs for these investors while preserving SEBI’s ability to obtain information and intervene if risk indicators change. Lowering the compliance threshold for objectively low-risk foreign institutional investors is rational because it aligns regulatory burden with actual risk, allowing SEBI to concentrate its supervisory and enforcement resources on higher risk investors and complex structures rather than on well-regulated sovereigns, pensions and broad based funds.

    The Jan 2026 FPI Circular can be found here.

    The Jan 2026 FVCI Circular 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 author:

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

    Zaynali Badami, Associate – Email – zaynalibadami@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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