Circular eF.No. IFSCA-DSI/12/2025-Capital Markets, Dated: 26.11.2025
1. Overview
The International Financial Services Centres Authority (IFSCA) has issued a directive requiring Global Access Providers (GAPs) and Introducing Brokers (IBs) to display key risk disclosures to clients at every login.
This mandate aims to strengthen investor awareness and ensure that clients are fully informed of the risks associated with accessing global markets through IFSC intermediaries.
2. Mandatory Display of Key Risks
As per the circular, the following key risks listed in Annexure I must be prominently displayed to clients at each login session:
2.1 Market and Interest Rate Risks
- Volatility in global markets
- Fluctuations in interest rates affecting asset values
2.2 Currency Movement Risks
- Forex fluctuations impacting returns
- Exposure to currency conversion losses
2.3 Custody and Settlement Risks
- Risks arising from foreign custodians
- Settlement delays, failures, or cross-border operational constraints
2.4 Technology and Cybersecurity Risks
- Potential system outages
- Cyber-attacks, data breaches, and platform vulnerabilities
2.5 Regulatory and Taxation Risks
- Changes in foreign regulations
- Divergent tax rules that may impact investor obligations and returns
These disclosures are intended to ensure that clients understand the inherent risks associated with international market access and cross-border products.
3. Compliance Requirements for GAPs and IBs
3.1 Display Format and Placement
GAPs and IBs must:
- Display risk disclosures exactly in the manner prescribed under Clause 39 of the circular,
- Ensure they appear prominently and unavoidably upon each client login,
- Implement the disclosure mechanism across all platforms, including mobile apps and web portals.
4. Implementation Timeline
IFSCA has stipulated that full compliance must be ensured by December 31, 2025.
Entities are expected to upgrade systems, interfaces, and investor communication modules to meet this deadline.
5. Significance
This directive aims to:
- Enhance transparency and investor protection,
- Promote informed decision-making by clients accessing global markets,
- Reduce the likelihood of disputes by setting clear expectations on risks,
- Strengthen IFSC market infrastructure in line with global best practices.
Click Here To Read The Full Circular
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