IFSCA Prescribes Additional Disclosures For Third-Party Funds

IFSCA Third-Party Fund Management Disclosures

Circular No. IFSCA/AIF/218/2025-Capital Markets, Dated 16.01.2026

1. Introduction

International Financial Services Centres Authority (IFSCA) has prescribed additional disclosures and procedural requirements for scheme filings by Registered Fund Management Entities (FMEs) authorised for Third-Party Fund Management.

2. Applicability To Registered FMEs

IFSCA has clarified that FMEs undertaking Third-Party Fund Management must file scheme applications in the format and with the documents prescribed under the IFSCA circular on “Ease of Doing Business, Filing of Schemes or Funds” dated April 5, 2024.

3. Additional Third-Party Manager Disclosures

In addition to the standard filing requirements, FMEs are required to submit specific details of the third-party fund manager, including its legal name, registered office address, and proof of regulatory registration or licence in its home jurisdiction.

4. UBO And Key Personnel Information

The circular also mandates submission of a Ultimate Beneficial Owner (UBO) “look-through” chart. Further, profiles of board members or designated partners, along with key managerial personnel (KMPs) of the third-party fund manager, must be disclosed.

5. Conclusion

The additional disclosure and process requirements aim to enhance transparency, regulatory oversight, and governance in Third-Party Fund Management structures. These measures are expected to strengthen compliance standards while supporting IFSCA’s ease-of-doing-business framework.

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