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SEBI AIF Compliance: Ongoing Obligations for Fund Managers

Keeping an AIF compliant after registration.
23 September 2026 by
SEBI AIF Compliance: Ongoing Obligations for Fund Managers
Gaurav Kumar
MCA & Secretarial ComplianceComplete Guide3 min read
The short answer

Registered AIFs must file periodic reports with SEBI, get an annual audit of compliance with the private placement memorandum, value investments through independent valuers, appoint a custodian, hold units in dematerialised form, conduct investor due diligence, report to performance benchmarking agencies and follow category-specific investment conditions.

RegulatorSEBI
AuditAnnual PPM compliance audit
ValuationIndependent valuer
UnitsDematerialised

Reporting

  • Quarterly activity reports to SEBI
  • Compliance test reports
  • Investor reporting

Governance

  • Custodian appointment
  • Investment committee norms
  • Conflict of interest policies

Due diligence on investors and investments to prevent regulatory circumvention, and adherence to minimum investment norms.

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Penalties

SEBI can impose penalties, restrict operations or cancel registration for violations.

Frequently asked questions

Is AIF unit dematerialisation mandatory?

SEBI requires AIF units to be held in dematerialised form, with timelines for existing schemes.

Who audits PPM compliance?

An independent auditor as specified by SEBI.

Do Category III AIFs have extra rules?

Yes, including leverage and risk management requirements.

Is performance benchmarking mandatory?

Reporting to benchmarking agencies is required for applicable AIFs.

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Keep reading

Form AOC-4: Filing Financial Statements with ROC
Annual filing of audited accounts with the ROC.