Introduction
The Alternative Investment Fund (AIF) Compliance Calendar serves as a structured and time-bound reference tool to help Alternative Investment Fund (AIF) and related intermediaries, ensure timely adherence to regulatory obligations as prescribed under the Securities and Exchange Board of India (Alternative Investment Funds) Regulations, 2012, and various Master Circulars issued by Securities and Exchange Board of India (SEBI) from time to time.
These regulations, supplemented by circulars and operational guidelines, lay down the compliance framework governing the activities of Alternative Investment Fund (AIF) in India, covering areas such as fundraising and private placement disclosures, investment concentration limits and diversification norms, valuation of portfolio investments, periodic reporting to SEBI and performance benchmarking, stewardship and risk management, as well as governance standards including conflict of interest mitigation and investor grievance redressal. The Calendar is designed to:
- Track periodic compliance requirements (daily, weekly, monthly, quarterly, half-yearly, and annual)
- Ensure timely submissions to SEBI and other regulatory bodies
- Promote accountability among compliance officers and relevant departments.
| S.NO. | Compliance Description | Forms and Formats | Submitted By | Submitted To | Filing Dates | Regulating Document |
|---|---|---|---|---|---|---|
| Yearly Filings/ Intimations | ||||||
| 1 | Annual Report | NA | Investment Manager | Investors | 27th September | Securities and Exchange Board of India (Alternative Investment Funds) Regulations, 2012 |
| 2 | Compliance Test Report | Compliance Test Reports (CTRs) Format | Investment Manager |
|
30th April | Master Circular for Alternative Investment Funds (AIFs) |
| 3 | Audit Findings along with Corrective Steps | NA | Investment Manager |
|
30th September | Master Circular for Alternative Investment Funds (AIFs) |
| 4 | No Funds Raised Certificate | NA | Investment Manager | SEBI | 30th September | Master Circular for Alternative Investment Funds (AIFs) |
| 5 | Change in Terms of PPM or Fund Documents | NA | Investment Manager |
|
30th April | Master Circular for Alternative Investment Funds (AIFs) |
| 6 | Valuation Portfolio Report | NA | Investment Manager | Performance Benchmarking Agencies | 30th September | Master Circular for Alternative Investment Funds (AIFs) |
| 7 | Digital Accesibilty Compliance | NA | Investment Manager | SEBI | 30th April | SEBI Circular on Compliance Guidelines for Digital Accessibility Circular - Rights of Persons with Disabilities Act, 2016 (Dated: 31st July, 2025) |
| Half-Yearly Filings/ Intimations | ||||||
| 8 | Valuation Methodology and Procedures for AIFs | NA | Investment Manager | Investors | Once in 6 Months | Securities and Exchange Board of India (Alternative Investment Funds) Regulations, 2012 |
| 9 | Report on Scheme-Wise Valuation and Cash Flow Data | NA | Investment Manager | Performance Benchmarking Agencies | 15th November (Within 45 days from the end of every half-year ending on 30th September) 30th October (within 7 months for half-year ending March 31) |
|
| Quarterly Filings/ Intimations | ||||||
| 10 | Quarterly Compliance Report | NA | Category III AIF | Investors |
|
Securities and Exchange Board of India (Alternative Investment Funds) Regulations, 2012 |
| 11 | Quarterly Reporting on AIF Business Activity | NA | Investment Manager | SEBI |
|
Master Circular for Alternative Investment Funds (AIFs) |
| 12 | Maintain Data of Investor's Complaints | NA | Investment Manager | NA |
|
Master Circular for Alternative Investment Funds (AIFs) |
| 13 | Cyber Security Incident | NA | Investment Manager | SEBI |
|
SEBI Circular on Cybersecurity and Cyber Resilience Framework (CSCRF) (Dated: 20th August, 2024) |
| Monthly Filings/ Intimations | ||||||
| 14 | Investor Details of Units in Aggregate Escrow Demat Account | NA | Investment Manager |
|
End of Each Month | Master Circular for Alternative Investment Funds (AIFs) |
| Daily Filings/ Intimations | ||||||
| 15 | Daily Report on Amount of Leverage | NA | Category III AIF | Custodian | By the End of Next Working Day | Master Circular for Alternative Investment Funds (AIFs) |
| Event-Based Filings/ Intimations | ||||||
| 16 | Disclosure of Material Changes and Rectification of Registration Information | NA | Investment Manager | SEBI | Immediately | Securities and Exchange Board of India (Alternative Investment Funds) Regulations, 2012 |
| 17 | Change in AIF Category | NA | Investment Manager | SEBI | Immediately | Securities and Exchange Board of India (Alternative Investment Funds) Regulations, 2012 |
| 18 | Revised PM on Change in Category | NA | Investment Manager | Investors | Post SEBI Approval on Category Change | Securities and Exchange Board of India (Alternative Investment Funds) Regulations, 2012 |
| 19 | Open-Ended Scheme Corpus Breach (< Rs. 20 Cr) | NA | Investment Manager | SEBI | Within 2 Days of Receiving Redemption Request from Client |
|
| 20 | Rectification of Passive Breach of Concentration Norm | NA | Category III AIF | NA | Within 30 Days from Date of Breach |
|
| 21 | Change in Control of AIF | NA | Investment Manager |
|
Immediately | Securities and Exchange Board of India (Alternative Investment Funds) Regulations, 2012 |
| 22 | Report Investments Data of AIFs under Custody | NA | Custodian | SEBI | As and When Required |
|
| 23 | Material Non-Compliance under AIF Regulations | NA | Compliance Officer | SEBI | Within 7 Working Days from Date of Observing Non-Compliance | Securities and Exchange Board of India (Alternative Investment Funds) Regulations, 2012 |
| 24 | Disclosure of All Conflicts of Interests | NA | Investment Manager | Investors | As and When Required | Securities and Exchange Board of India (Alternative Investment Funds) Regulations, 2012 |
| 25 | Material Liabilities, Fees, and Compliance Breaches (Refer Note) | NA | Investment Manager/ Sponsor | Investors | As and When Required | Securities and Exchange Board of India (Alternative Investment Funds) Regulations, 2012 |
| 26 | Disclosure of Change in KMP | NA | Investment Manager |
|
Immediately |
|
| 27 | Report on AIF Systemic Risk and Mitigation Framework | NA | Investment Manager | SEBI | As and When Required | Securities and Exchange Board of India (Alternative Investment Funds) Regulations, 2012 |
| 28 | Disclosure of NAV | NA | Category III AIF | Investors |
|
Securities and Exchange Board of India (Alternative Investment Funds) Regulations, 2012 |
| 29 | Details of Valuation Methology in PPM | NA | Investment Manager |
|
|
|
| 30 | Redressal of Investor Grievances | NA | Investment Manager | Investors | Within 21 Calendar Days from Receipt Date of Grievance | Securities and Exchange Board of India (Alternative Investment Funds) Regulations, 2012 |
| 31 | Utilisation of Overseas Investment Limits | NA | Investment Manager | SEBI | Within 5 Working Days of Utilisation of Overseas Investment Limits | Master Circular for Alternative Investment Funds (AIFs) |
| 32 | Unutilized or Partly Utilized AIF Overseas Investment Limits | NA | Investment Manager | SEBI | Within 2 Working Days after Expiry of Validity Period | Master Circular for Alternative Investment Funds (AIFs) |
| 33 | Voluntary Surrender of AIF Overseas Investment Limits | NA | Investment Manager | SEBI | Within 2 Working Days from Decision Date to Surrender Limit | Master Circular for Alternative Investment Funds (AIFs) |
| 34 | Sale or Transfer Details of Overseas Investment | Annexure 7 (Information with respect to sale or divestment of overseas investment) | Investment Manager | SEBI | Within 3 Working Days of Divestment | Master Circular for Alternative Investment Funds (AIFs) |
| 35 | Report Breach of CDS Exposure | NA | Investment Manager | Custodian | Next Working Day | Master Circular for Alternative Investment Funds (AIFs) |
| 36 | Unhedged CDS Positions Exceeding 25% of Investable Funds | NA | Investment Manager | Unitholders | As and When Occurs | Master Circular for Alternative Investment Funds (AIFs) |
| 37 | Intimate any Violations of AIF Regulations | NA | Trustee/ Sponsor | SEBI | As Soon As Possible | Master Circular for Alternative Investment Funds (AIFs) |
| 38 | Details of Unliquidated Investment Distribution under Liquidation Schemes | NA | Investment Manager | SEBI | Quarterly | Master Circular for Alternative Investment Funds (AIFs) |
| 39 | Details of Investor-Specific Investment Exclusions in AIFs | NA | Investment Manager | AIF | Within 15 Days of Change | Master Circular for Alternative Investment Funds (AIFs) |
| 40 | VAPT Report | NA | Investment Manager | SEBI | Within 1 Month of VAPT Completion | SEBI Circular on Cybersecurity and Cyber Resilience Framework (CSCRF) (Dated: 20th August, 2024) |
| 41 | Revalidation of VAPT | NA | Investment Manager | SEBI | Within 5 Months of VAPT Completion | SEBI Circular on Cybersecurity and Cyber Resilience Framework (CSCRF) (Dated: 20th August, 2024) |
| 42 | Report on Cyber Audit | Annexure-B (Cyber Audit Report Format) | Investment Manager | SEBI | Within 1 Month of Cyber Audit Completion | SEBI Circular on Cybersecurity and Cyber Resilience Framework (CSCRF) (Dated: 20th August, 2024) |
| 43 | Follow-On Cyber Audit | NA | Investment Manager | SEBI | Within 5 Months of Cyber Audit Completion | SEBI Circular on Cybersecurity and Cyber Resilience Framework (CSCRF) (Dated: 20th August, 2024) |
| 44 | Evidence for Self-Assessment of Cyber Resilience | Annexure-K (Cyber Capability Index (CCI)) | Investment Manager | SEBI | Within 15 Days of CCI Assessment Completion | SEBI Circular on Cybersecurity and Cyber Resilience Framework (CSCRF) (Dated: 20th August, 2024) |
| 45 | Addition/ Deletion or Change in Existing Asset in Asset Inventory | NA | Investment Manager | NA | Within 3 Working Days of Change | SEBI Circular on Cybersecurity and Cyber Resilience Framework (CSCRF) (Dated: 20th August, 2024) |
| 46 | Interim Report | NA | Investment Manager | SEBI | Within 3 Working Days from Reporting of Incident | SEBI Circular on Cybersecurity and Cyber Resilience Framework (CSCRF) (Dated: 20th August, 2024) |
| 47 | Mitigation Measure Report | NA | Investment Manager | SEBI | Within 7 Days from Reporting of Incident | SEBI Circular on Cybersecurity and Cyber Resilience Framework (CSCRF) (Dated: 20th August, 2024) |
| 48 | RCA Report | NA | Investment Manager | SEBI | Within 30 Days from Reporting of Incident | SEBI Circular on Cybersecurity and Cyber Resilience Framework (CSCRF) (Dated: 20th August, 2024) |
| 49 | Forensic Audit Report | NA | Investment Manager | SEBI | Within 75 Days from Reporting of Incident | SEBI Circular on Cybersecurity and Cyber Resilience Framework (CSCRF) (Dated: 20th August, 2024) |
| 50 | Post-Cyber Incident VAPT | NA | Investment Manager | SEBI | Within 45 Days from Reporting of Incident | SEBI Circular on Cybersecurity and Cyber Resilience Framework (CSCRF) (Dated: 20th August, 2024) |
Note: Disclosure of the following information:
- Financial, risk management, operational, portfolio, and transactional information regarding fund investments
- Any fees ascribed to the Manager or Sponsor
- Any fees charged to the AIF or any investee company by an associate of the Manager or Sponsor
- Any inquiries or legal actions by legal or regulatory bodies in any jurisdiction
- Any material liability arising during the AIF’s tenure
- Any breach of a provision of the placement memorandum or agreement made with the investor or any other fund documents.
Abbreviations
| S.NO. | Particular | Description |
|---|---|---|
| 1 | AIF | Alternative Investment Fund |
| 2 | SEBI | Securities and Exchange Board of India (SEBI) |
| 3 | DP | Designated Partner |
| 4 | VAPT | Vulnerability Assessment and Penetration Testing |
| 5 | RCA | Root Cause Analysis |
| 6 | CCI | Cyber Capability Index |
| 7 | PPM | Private Placement Memorandum |
| 8 | PM | Placement Memorandum |
| 9 | KMP | Key Management Personnel |
| 10 | AIF Regulations | Securities and Exchange Board of India (Alternative Investment Funds) Regulations, 2012 |
| 11 | NAV | Net Asset Value |
| 12 | CDS | Credit Default Swaps |
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Disclaimer
The information provided in this article is intended for general informational purposes only and should not be construed as legal advice. The content of this article is not intended to create and receipt of it does not constitute any relationship. Readers should not act upon this information without seeking professional legal counsel.
