Regulation 28 of the SEBI (Alternative Investment Funds) Regulations, 2012 (AIF Regulations) gives SEBI the power to call upon Alternative Investment Funds (AIF) to file such reports, as SEBI may desire, with respect to the activities carried on by the AIF. By virtue of this power, Paragraph 15.1.1. of SEBI’s Master Circular for AIFs dated May 07, 2024 (AIF Master Circular), requires AIFs to submit activity reports to SEBI in a specified format on a quarterly basis within 15 calendar days from the end of each quarter. The reporting format is posted on Indian Venture and Alternate Capital Association’s (IVCA) website.
On March 4, 2026, SEBI issued a circular (March Circular) which eases the reporting burden on AIFs in the following manner:
AIFs shall submit a comprehensive Annual Activity Report once a year, within 30 calendar days from the end of March of every financial year. The first such Annual Activity Report shall be submitted for the year ending March 2026 latest by May 31, 2026.
A limited Quarterly Activity Report shall be submitted by all AIFs online in a revised format within 15 calendar days from the end of each such quarter. The first such report shall be submitted for the quarter ending June 2026. For the quarter ending on March 31st, a Quarterly Activity Report will not be required since the Annual Activity Report includes the data points of the Quarterly Activity Report.
ELP Comments
Even though AIFs are required to a comprehensive Annual Activity Report within one month after the end of the relevant financial year, for the year 2026, AIFs have been given two months to do so.
The March Circular modernises and strengthens the supervisory framework for AIFs by overhauling the way regulatory data is collected from AIFs. Building on the earlier 2021 reporting framework, which had already rationalised periodic filings and mandated quarterly activity and leverage reports through SEBI’s intermediary portal, the March Circular makes AIF reporting more granular, standardised and technology‑driven so that SEBI can better monitor risks (including leverage, valuation practices and investor concentration), spot stress early, and use comparable datasets across the AIF industry.
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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