SEBI’s Master Circular 2023: Comprehensive Guide to AIF Regulations in India

Insights by: Sumit Kochar, Anjali Dawar, Shivam Gera and Sarthak Kasliwal

In India, Alternative Investment Funds (AIFs) are outlined in Regulation 2(1)(b) of the Securities and Exchange Board of India (Alternative Investment Funds) Regulations, 2012. They pertain to privately pooled investment funds, regardless of their origin from India or abroad, structured as trusts, companies, bodies corporate, or Limited Liability Partnerships (LLPs).

On July 31, 2023, the Securities and Exchange Board of India (SEBI) released a Master Circular No. SEBI/HO/AFD/PoD1/P/CIR/2023/130 for AIFs (Master Circular). The Master Circular consolidates various previous circulars issued by SEBI with the aim of establishing an effective regulatory framework for AIFs. The provisions of all relevant circulars issued by SEBI until March 31, 2023, that are currently in operation, have been included in the Master Circular for AIFs. However, circulars that offered temporary relaxations for certain compliance requirements for AIFs have not been incorporated into the Master Circular.

A total of 26 circulars have been rescinded by the Master Circular. The Master Circular has divided all the guidelines into 19 chapters, which include online filing system for funds, PPM and related compliance, registration related clarifications, investment in units of AIFs, reporting in AIFs, obligations of sponsor, manager and trustee, constitution of investment committee.

Chapter 1 – Online Filing System for AIFs:

All applicants intending to seek registration as an AIF must compulsorily utilize the SEBI Intermediary Portal at https://siportal.sebi.gov.in for online applications. Similarly, SEBI registered AIFs are obligated to exclusively file compliance reports and submit applications related to the AIF Regulations through the same portal. Any queries or clarifications regarding the online filing process can be addressed by referring to the manual provided within the SEBI Intermediary Portal or by contacting the Portal Helpline as specified. Adherence to the prescribed online filing procedure is deemed mandatory for all AIFs, and failure to comply may result in necessary legal consequences in accordance with SEBI regulations.

Chapter 2 – Filing of PPM and Related Compliance Requirements:

Template(s) for PPM[1] and disclosures in PPM[2]

In order to ensure transparent disclosure of information to potential investors, a template has been prescribed for the PPM of AIFs. The PPM is a primary document that provides essential information about the AIF to prospective investors. The template is designed to offer a minimum standard of disclosure in a simple and comparable format, while also allowing AIFs the flexibility to provide additional information as they deem fit. It consists of two parts: Part A, which contains the minimum disclosures required, and Part B, which provides supplementary sections for additional information.

AIFs raising funds under different categories have specific templates for their PPMs. The template for all the category of AIFs is provided in Annexures of the Master Circular. Additionally, every AIF must provide a detailed tabular example of how the fees and charges will be applicable to investors, including the distribution waterfall.

Regulation 11(2) of the AIF Regulations requires AIFs to include the disciplinary history of the AIF, its sponsor, manager, director or partners or promoters, and associates in the PPM. This history should cover details of outstanding and past cases, litigations, criminal or civil prosecutions, disputed tax liabilities, penalties levied, and any other disciplinary action taken by the Board or any other regulatory authority. Any further litigations or cases arising during the AIF’s activities should also be appropriately incorporated in the PPM and intimated to the investors.

The disclosure of disciplinary history in the PPM shall be applicable for the last five years, and where monetary penalties are involved, it applies to cases where the penalty is greater than rupees five lakh. Disputed tax liabilities shall not apply to liabilities in the personal capacity of an individual, and contingent liabilities shall be disclosed as per the books of accounts of the entity.

Modalities for filing of PPM through a Merchant Banker[3]

In terms of Regulation 12(2) of the AIF Regulations, the filing of the PPM with SEBI is subject to the due diligence of a SEBI registered Merchant Banker. The Merchant Banker must independently exercise due diligence of all the disclosures in the PPM, ensuring the veracity and adequacy of the information provided. Specific format of due diligence is provided in Annexures of the Master Circular. While filing the draft PPM, the due diligence certificate provided by the Merchant Banker shall also be submitted along with other necessary documents. The details of the Merchant Banker shall be disclosed in the PPM.

Audit of terms of PPM[4]

AIFs are also required to carry out an annual audit of compliance with the terms of the PPM. This audit can be conducted by an internal or external auditor/legal professional, and it must be done at the end of each financial year. The findings of the audit, along with any corrective steps taken, must be communicated to the Trustee or Board of Directors or Designated Partners of the AIF and SEBI within six months from the end of the financial year. However, sections of the PPM relating to ‘Risk Factors,’ ‘Legal, Regulatory, and Tax Considerations,’ and ‘Track Record of First Time Managers’ shall be subject to optional audit.

The requirement of the audit of compliance with the PPM terms shall not apply to AIFs that have not raised any funds from their investors. Such AIFs shall submit a Certificate from a Chartered Accountant stating that no funds have been raised, within six months from the end of the financial year.

Certain AIFs, including Angel Funds and those where each investor commits to a minimum capital contribution of rupees seventy (70) crore and provides a waiver to the fund from the requirement of PPM in the SEBI specified template, and annual audit of terms of PPM, are exempted from specific requirements.

Changes in PPM[5]

AIFs are required to list any changes made to the PPM vis-à-vis the draft PPM submitted to SEBI at the time of application in the covering letter and highlight these changes in the final placement memorandum. Any changes in terms of PPM and the fund/scheme documents shall be intimated to investors and SEBI on a consolidated basis within one month of the end of each financial year. A SEBI registered Merchant Banker must submit the intimation along with the due diligence certificate provided by the Merchant Banker. The format of due diligence certificate for intimation of changes is given at Annexures of Master Circular. Material changes that significantly influence investor decisions shall provide an exit option for dissenting investors, subject to certain conditions.

Chapter 3 – Registration Related Clarifications

In-principle approval

Regarding the in-principal approval granted to an applicant, it is important to note that if the registered trust deed or duly filed partnership deed is not submitted within the specified time period, the applicant will be required to file a fresh application for registration under the AIF Regulations. Timely submission of the necessary documents is essential for the continuation of the registration process.

Change in category of AIF

Regulation 7(2) of the AIF Regulations explicitly states that an AIF that has been granted registration under a particular category cannot change its category without obtaining the approval of the Board. However, certain conditions and procedures have been laid out to allow AIFs to change their category:

Only AIFs that have not made any investments under their registered category are eligible to make an application for a change in category. An AIF seeking to change its category must submit an application to SEBI, along with an application fee of 1 lakh rupees. The application should include updated Form A, as per the First Schedule of the AIF Regulations, along with other updated supporting documents, if applicable, and a rationale for the proposed change. Importantly, no registration fees will be charged for such applications.

Further, if the AIF has already received commitments or raised funds before applying for a change in category, it must provide its investors with the option to withdraw their commitments or funds without incurring any penalties or charges. Any fees collected from investors seeking to withdraw their commitments or funds shall be promptly returned to them. Partial withdrawal may also be allowed, provided it complies with the minimum investment amount required under the AIF Regulations. Until SEBI grants approval for the change in category, the AIF is restricted from making any investments other than in liquid funds or bank deposits. This ensures that investments are put on hold until the change is officially approved.

Upon receiving approval from SEBI, the AIF must promptly furnish a copy of the revised PPM and other relevant information to all its investors. This step ensures transparency and clarity for the investors regarding the changes made in the AIF.

These clarifications provide a structured framework for AIFs seeking to change their category, while also safeguarding the interests of investors and adhering to the regulatory requirements set forth by SEBI.

Chapter 4 – Investment in AIFs[6]

According to Regulation 10(a) of the AIF Regulations, AIFs are allowed to raise funds from various types of investors, including Indian, foreign, and non-resident Indians, by issuing units. Managers of AIFs must ensure the following when onboarding investors:

Chapter 5 – Operational and Prudential Norms for Category III AIFs

Calculation of Investment Concentration Norm[7]

Regulation 15(1)(d) of AIF Regulations the Category III AIFs, including large value funds for accredited investors, have the flexibility to calculate their investment concentration norm based on either investable funds or the net asset value (NAV) of the scheme when investing in listed equity of an investee company, subject to SEBI’s specified conditions. The condition includes all Category III AIFs must disclose the basis for calculating the investment concentration norm in the PPM of their schemes and the basis for calculating the investment concentration norm cannot be changed during the term of the scheme.

Category III AIFs opting to calculate investment concentration norm based on NAV must comply with the following:

Prudential Requirements with Respect to Leverage[8]

Category III AIFs employing leverage through derivatives, borrowing, or other means must adhere to the following prudential requirements:

Risk Management and Compliance[9]

Category III AIFs using leverage must have a comprehensive risk management framework and an independent risk management function appropriate to the size and complexity of the fund. A strong and independent compliance function must also be established, supported by sound operations and infrastructure.

Redemption Norms[10]

For open-ended Category III AIF schemes, the manager must ensure adequate liquidity and establish a liquidity management policy to meet redemption obligations and liabilities. The possibility of suspension of redemptions in exceptional circumstances should be disclosed in the PPM.

Breach in Corpus of Open-ended Scheme[11]

If the corpus of an open-ended scheme falls below twenty crore rupees, the AIF must intimate SEBI within 2 days of receiving a redemption request. The AIF must take necessary action to bring back the scheme size to twenty crore rupees within 3 months from the date of breach. Failure to do so may lead to the redemption of units and the winding up of the scheme in terms of Regulation 29 of AIF Regulations. Repeated violations may result in appropriate action by SEBI.

Chapter 6 – Norms for Special Situation Funds (SSF)[12]

Special Situation Funds (SSF) are subject to several important norms and requirements to ensure their proper functioning and compliance with regulations. Each scheme of SSF is required to have a minimum corpus of at least one hundred crore rupees. Additionally, SSFs must adhere to specific minimum investment requirements from investors, with regular investors needing to invest a minimum value of ten crore rupees, accredited investors at least five crore rupees, and employees or directors of the SSF or its manager a minimum of twenty-five lakh rupees.

If an SSF intends to act as a resolution applicant under the Insolvency and Bankruptcy Code, 2016, it must ensure compliance with the eligibility criteria specified therein. Furthermore, if an SSF seeks to acquire stressed loans according to Clause 58 of the Reserve Bank of India (RBI) Master Direction, certain conditions apply. The SSF can acquire such stressed loans only after being included in the respective Annex of the RBI Master Direction. The stressed loans acquired are subject to a mandatory lock-in period of six months, except in cases where the loan is recovered from the borrower.

Moreover, SSFs acquiring stressed loans under the RBI Master Direction must adhere to the same initial and continuous due diligence requirements imposed by RBI for investors in Asset Reconstruction Companies. These regulations and norms are designed to maintain transparency, accountability, and stability within the functioning of SSF.

Chapter 7 – Guidelines for overseas investments by AIFs and related reporting[13]

The AIF Regulations permit AIFs to invest in securities of companies incorporated outside India, subject to conditions issued by the RBI and SEBI. These guidelines aim to regulate overseas investments by AIFs and ensure compliance with relevant regulations.

Investment Conditions

AIFs are allowed to invest in equity and equity-linked instruments of offshore venture capital undertakings, with an overall limit of USD 1500 million for all AIFs and Venture Capital Funds. The offshore venture capital undertaking refers to a foreign company whose shares are not listed on any recognized stock exchange in India or abroad. The investment in such companies should not exceed 25% of the AIF’s investable funds for its scheme.

AIFs are required to invest in overseas investee companies incorporated in countries that are signatories to the International Organization of Securities Commission’s Multilateral Memorandum of Understanding or have bilateral Memorandums of Understanding with SEBI. However, investments in countries identified by the Financial Action Task Force with strategic Anti-Money Laundering or Combating the Financing of Terrorism deficiencies, to which countermeasures apply, are prohibited.

These investments must adhere to the Foreign Exchange Management (Overseas Investment) Regulations, 2022, along with related directions issued by RBI. AIFs cannot invest in joint ventures or wholly-owned subsidiaries as part of their overseas investments. Compliance with FEMA, 1999, and its rules and regulations is mandatory for all overseas investments.

 Allocation Of Overseas Investment Limits

AIFs need to apply to SEBI and submit an undertaking from the Trustee or Board or Designated Partners regarding the proposed overseas investment. The allocation will be on a “first come, first serve” basis, based on availability within the overall limit of USD 1500 million. If an AIF does not utilize the allocated limits within 6 months from SEBI approval, it must report this to SEBI within 2 working days after the expiry of the validity period. In case of liquidation of an overseas investee company, the sale proceeds will be available for reinvestment by all AIFs.

AIFs are required to report the utilization of overseas investment limits within 5 working days on the SEBI intermediary portal. They must also report cases of non-utilization or partial utilization of the limit within the validity period, and any decision to surrender the limit. Details of the sale/divestment of overseas investments must be furnished to SEBI within 3 working days of the divestment, for updating the overall limit available for overseas investments by AIFs. These reporting requirements ensure transparency and monitoring of AIFs’ overseas investments.


Chapter 8 – Investment in units of AIFs[14]

The AIF Regulations allow AIFs to invest in an investee company up to a specified limit, either directly or through investment in units of other AIFs. AIFs have the flexibility to invest in units of other AIFs without being classified as a Fund of AIFs.

Existing AIFs can simultaneously invest in securities of investee companies and units of other AIFs, provided they make appropriate disclosures in the PPM and obtain consent from at least two-thirds of unit holders by the value of their investment in the AIF, as per Regulation 9(2) of the AIF Regulations.

For AIFs intending to invest in units of other AIFs, their PPMs must include crucial information such as the proposed allocation of investments in other AIFs, the portion of fees and expenses attributed to such investments, the process followed by the Manager to ensure compliance with investment conditions specified in the AIF Regulations, and details of any proposed investments in units of AIFs managed or sponsored by the same Manager/Sponsor or their associates, including allocation, fees, expenses, etc.

Pooling vehicles, solely created for investing in an AIF, should not be established unless they are registered with SEBI as AIFs. This requirement ensures proper regulation and oversight of such vehicles and prevents any misuse or circumvention of AIF Regulations.

Chapter 9 – Participation of AIFs in Credit Default Swaps[15]

Circular provides detailed guidelines for AIFs participating in Credit Default Swaps (CDS). There are specific conditions applicable to different categories of AIFs for buying and selling CDS. Category I and Category II AIFs are allowed to buy CDS solely for hedging purposes, while Category III AIFs can buy CDS for hedging or other purposes as long as they stay within the permissible leverage limits specified in the circular. Category III AIFs may also sell CDS, ensuring compliance with permissible leverage limits, and Category II and III AIFs can also sell CDS by earmarking unencumbered government bonds or treasury bills. All CDS transactions must be reported to the custodian, and proper obligations and reporting mechanisms are in place for breaches of leverage limits or unhedged positions. Transparency is encouraged through transactions on regulated platforms, and compliance with RBI’s credit derivatives guidelines is required for AIFs participating in CDS.

Chapter 10 – Transaction in Corporate Bonds through Request for Quote (RFQ) platform by AIFs[16]

Circular pertains to the transaction in Corporate Bonds through the Request for Quote (RFQ) platform by AIFs.

According to the guidelines, AIFs are required to undertake at least 10% of their total secondary market trades in Corporate Bonds by value in a month using the RFQ platform. This platform facilitates the placing and seeking of quotes for Corporate Bonds transactions.

Furthermore, transactions executed through the RFQ platform can be in either ‘one-to-one’ mode or ‘one-to-many’ mode. If both sides of a Corporate Bonds trade involve AIFs, the transaction must be executed through the RFQ platform in ‘one-to-one’ mode. However, if an AIF places a quote in ‘one-to-many’ mode and it gets executed with another AIF, the transaction will be counted in ‘one-to-many’ mode and not in ‘one-to-one’ mode.

Chapter 11 – Other prudential and operational norms and related clarifications.

Master Circular provides important clarifications and norms related to investments and other operational aspects of AIFs.

The clarifications regarding investments highlight the importance of fair sharing of losses by the sponsor/manager, ensuring continuing interest in proportion to the funds raised from other investors, and specific conditions for investing in real estate or infrastructure projects. Additionally, the circular emphasizes the need for prior approval from investors before making certain investments, and it defines the scope and focus of Category II AIFs in terms of their investment portfolios.

The Master Circular also addresses schemes of AIFs that have adopted a priority distribution model, putting a temporary restriction on accepting fresh commitments or making new investments in investee companies until SEBI takes a decision on this matter.

Regarding the calculation of tenure for close-ended schemes of AIFs, the circular specifies that the tenure should be calculated from the date of the First Close and provides guidelines for modifying the tenure before the First Close. Existing schemes that declared their First Close on or before November 17, 2022, can continue calculating their tenure from the date of the Final Close, but they must adhere strictly to the timeline specified in the PPM for declaring the Final Close.

These clarifications and norms aim to enhance transparency, fairness, and investor protection in the functioning of AIFs while providing operational guidance for their effective management and functioning.

Chapter 12 – Framework for Accredited Investors[17]

The chapter introduces the framework for “Accredited Investors” (AIs) in the securities market. AIs are eligible to avail certain benefits, such as lower minimum investment amounts or concessions from specific regulatory requirements, subject to conditions applicable to investment products under SEBI (Alternative Investment Funds) Regulations, 2012, SEBI (Portfolio Managers) Regulations, 2020, and SEBI (Investment Advisers) Regulations, 2013.

Persons seeking to be recognized as AIs must approach an Accreditation Agency for accreditation. These agencies are responsible for verifying documents submitted by applicants, processing applications, issuing accreditation certificates, maintaining data of accredited investors, verifying accreditation status, maintaining confidentiality of investor information, and fulfilling any other responsibilities specified by SEBI. Accreditation Agencies must have the necessary infrastructure, including systems and manpower, to fulfill their responsibilities.

Entities eligible to carry out the accreditation process include subsidiaries of recognized Stock Exchanges and subsidiaries of Depositories. For Stock Exchanges to qualify, they must meet specific criteria, such as having a minimum presence of 20 years in the Indian securities market, a minimum net worth of 200 crore rupees, nationwide terminals, investor grievance redressal mechanisms, presence of Investor Service Centers (ISCs) in at least 20 cities, and other criteria specified by SEBI.

In conjunction with the introduction of the framework for AIs, the AIF Regulations were amended to provide certain relaxations for “Large Value Fund for Accredited Investors” (LVF). LVFs are exempt from filing their placement memorandum with SEBI through a Merchant Banker and can launch their scheme under intimation to SEBI. To extend the tenure of close-ended AIFs beyond two years, LVFs must lay down the terms and conditions for extension in their placement memorandum, contribution agreement, or other fund documents. LVFs must obtain approval from their Trustee or Board of Directors or Designated Partners (depending on the legal structure) for extending the tenure at least one month before the fund’s expiration. If the specified conditions for extension are not fulfilled, LVFs must liquidate and wind up in accordance with AIF Regulations and Circulars.

Chapter 13 – Obligations of manager, sponsor and trustee of AIFs

The Master Circular outlines the responsibilities and obligations of various entities involved in AIFs.

Appointment and Designation of Personnel

AIFs must designate a Compliance Officer, who is separate from the CEO or equivalent role, to ensure compliance with SEBI Act and AIF Regulations. Key Management Personnel, including key investment team members and decision-making employees, must be disclosed in the PPM, and any changes should be communicated to investors and the Board.

Code of Conduct

Managers of AIFs are required to operate in the best interest of unitholders, follow the placement memorandum, and provide it to investors before committing or investing. They must maintain separate bank and securities accounts for each scheme. Additionally, they should not make exaggerated statements about their qualifications or offer assured returns to investors.

Other Obligations

AIFs and managers must comply with circulars/guidelines issued by SEBI regarding KYC requirements, Anti-Money Laundering, and Outsourcing of activities.

These obligations aim to ensure ethical behavior, transparency, and protection of investors’ interests in the functioning of AIFs.

Chapter 14 – Constitution of investment committee[18]

The Master Circular focuses on the constitution of the investment committee in AIFs.

Investment Committee Formation and Waiver

A Manager of an AIF may establish an Investment Committee to approve decisions of the AIF, subject to certain conditions as per Regulation 20(7) of AIF Regulations. Investors may provide a waiver to the AIF regarding compliance with the Regulation related to the responsibility of the members of the Investment Committee.

Change in Ex-officio External Members

In the case of any change in ex-officio external members of the Investment Committee (representing the sponsor, sponsor group, manager group, or investors in their official capacity), the consent of the AIF’s investors may not be required as per Regulation 20(10) of AIF Regulations.

Clarity on Investment Committee with External Members

SEBI has sought clarification from the Government and RBI regarding the applicability of certain rules to AIFs whose Investment Committees approve investment decisions and include external members who are not ‘resident Indian citizens.’ Until a clarification is received on the matter, applications for the registration of AIFs and launch of new schemes will be processed based on the following:

Chapter 15 – Reporting by AIFs

Reporting of Investment Activities

All AIFs are required to submit reports on their activities to SEBI on a quarterly basis. The report should be submitted within ten (10) calendar days from the end of each quarter. Category III AIFs also need to submit reports on the leverage undertaken on a quarterly basis. The reports should be submitted online through the SEBI intermediary portal.

Compliance Test Report (CTR)

At the end of each financial year, the manager of an AIF must prepare a compliance test report on the AIF Regulations and circulars issued by SEBI. The report should be in the specified format and submitted within 30 days from the end of the financial year to the trustee and sponsor if the AIF is a trust, or to the sponsor if the AIF is set up in a form other than a trust. If there are any observations or comments on the CTR, the trustee or sponsor should inform the manager within thirty (30) days, and the manager must make necessary changes and submit a reply within fifteen (15) days.

Term Sheet – Angel Funds

Angel funds planning to launch schemes must file a Term Sheet containing material information about the scheme in the specified format with the Board within ten days of launching the scheme.

Chapter 16 – Performance Benchmarking of AIFs[19]

The Master Circular introduces a mandatory performance benchmarking framework for AIFs, including Venture Capital Funds. The purpose of this framework is to compare the performance of the AIF industry against other investment avenues and global investment opportunities. Key provisions of the framework are as follows:

Chapter 17 – Investor Charter and Disclosure of complaints by AIFs[20]

The Master Circular introduces an Investor Charter and disclosure requirements for complaints by AIFs. The aim is to provide relevant information to investors and enhance transparency in the grievance redressal mechanism. The key provisions are as follows:

The implementation of the Investor Charter and disclosure of complaints is aimed at providing investors with necessary information and fostering transparency in AIF operations.

Chapter 18 – Collection of stamp duty on issue, transfer[21]

The Master Circular pertains to the collection of stamp duty on the issue, transfer, and sale of units of AIFs. Key provisions are as follows:

Chapter 19 – Change in Sponsor and/or Manager or Change in control of Sponsor and/or Manager of AIF.

The Master Circular deals with the process of changes in the Sponsor and/or Manager of AIFs the associated fees and approvals required. The key provisions are as follows:

These provisions aim to ensure a smooth process for changes in the Sponsor and/or Manager of AIFs, while also addressing the associated fees and approvals required for such changes.

Concluding remarks

The issuance of the Master Circular for AIF by SEBI is a significant step towards promoting a well-regulated and investor-friendly AIF industry in India. The comprehensive guidelines and norms provided in the circular enhance transparency, investor protection, and overall market stability. By mandating the disclosure of investment concentration norms, prudential requirements for leverage, risk management frameworks, and compliance functions, the circular ensures that AIFs operate with accountability and adhere to best practices. Additionally, the introduction of the Accredited Investors framework offers certain benefits to eligible investors, fostering participation and growth in the alternative investment space.

Furthermore, the performance benchmarking framework for AIFs allows investors to compare the performance of different funds and provides insights into the AIF industry’s performance relative to other investment avenues. This benchmarking initiative promotes healthy competition, encourages fund managers to strive for excellence, and empowers investors to make more informed investment decisions.

Overall, the Master Circular establishes a strong regulatory foundation for AIFs in India, facilitating orderly growth, investor confidence, and safeguarding the interests of all stakeholders involved. As the AIF industry continues to evolve, the circular will play a crucial role in supporting India’s financial markets and fostering an environment conducive to innovation and sustainable growth in the alternative investment sector.

Top of Form

The SEBI Master Circular for Alternative Investment Funds (AIFs) in India establishes a comprehensive regulatory framework to enhance transparency, investor protection, and market stability. The circular encompasses various chapters addressing key aspects of the AIF industry. It covers investment in AIFs, credit default swaps, corporate bond transactions, investment committee composition, reporting obligations, performance benchmarking, and more. Notably, the circular introduces an Accredited Investors framework, providing eligible investors with benefits such as lower investment thresholds and exemptions from certain regulatory requirements.

Crucial provisions include the disclosure of investment concentration norms, prudential limits on leverage, risk management frameworks, and compliance functions. The circular promotes a balanced approach by allowing AIFs to invest in units of other AIFs without being classified as Funds of AIFs, provided specific conditions are met. The performance benchmarking framework empowers investors by enabling performance comparisons and facilitating more informed investment decisions.

[1] SEBI Circular No. SEBI/HO/IMD/DF6/CIR/P/2020/24 dated February 05, 2020

[2] SEBI circular No. CIR/IMD/DF/14/2014 dated June 19, 2014 and SEBI Circular No. CIR/IMD/DF/16/2014 dated July 18, 2014

[3] SEBI Circular No. SEBI/HO/IMD/IMD-I/DF6/P/CIR/2021/645 dated October 21, 2021

[4] SEBI Circular No. SEBI/HO/IMD/DF6/CIR/P/2020/24 dated February 05, 2020 and SEBI Circular No. SEBI/HO/IMD/DF6/CIR/P/2020/99 dated June 12, 2020

[5] SEBI circular No. CIR/IMD/DF/14/2014 dated June 19, 2014, SEBI Circular No. CIR/IMD/DF/16/2014 dated July 18, 2014

[6] SEBI circular No. CIR/IMD/DF/14/2014 dated June 19, 2014 and SEBI Circular No. CIR/IMD/DF/16/2014 dated July 18, 2014

[7] SEBI Circular No. SEBI/HO/IMD/IMD-I/DOF6/P/CIR/2022/0000000037 dated March 28, 2022

[8] SEBI Circular No. CIR/IMD/DF/10/2013 dated July 29, 2013

[9] SEBI Circular No. CIR/IMD/DF/10/2013 dated July 29, 2013

[10] SEBI Circular No. CIR/IMD/DF/10/2013 dated July 29, 2013

[11] SEBI circular No. CIR/IMD/DF/14/2014 dated June 19, 2014

[12] SEBI Circular No. SEBI/HO/IMD-I/DF6/P/CIR/2022/009 dated Jan 27, 2022

[13] SEBI Circular No. SEBI/HO/AFD-1/PoD/CIR/P/2022/108 dated August 17, 2022, SEBI Circular No. SEBI/HO/IMD/DF1/CIR/P/2018/103/2018 dated July 03, 2018 and  SEBI Circular No. CIR/IMD/DF/7/2015 dated October 1, 2015

[14] SEBI Circular No. SEBI/HO/IMD-I/DF6/P/CIR/2021/584 dated June 25, 2021

[15]  SEBI Circular No. SEBI/HO/AFD/PoD/CIR/2023/15 dated January 12, 2023

[16] SEBI Circular No. SEBI/HO/AFD/PoD/P/CIR/2023/017 dated February 01, 2023

[17] SEBI Circular No. SEBI/HO/IMD/IMD-I/DF9/P/CIR/2021/620 dated August 26, 2021

[18] SEBI Circular No. SEBI/HO/IMD-I/DF6/P/CIR/2021/584 dated June 25, 2021 and SEBI circular No. SEBI/HO/IMD/DF6/CIR/P/2020/209 dated October 22, 2020

[19]  SEBI Circular No. SEBI/HO/IMD/DF6/CIR/P/2020/24 dated Feb 05, 2020

[20] SEBI Circular No. SEBI/HO/IMD/IMD-I/DOF9/P/CIR/2021/682 dated December 10, 2021

[21]  SEBI Circular No. SEBI/HO/IMD/DF6/CIR/P/2020/113 dated June 30, 2020

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