The International Financial Services Centres Authority (IFSCA) has issued a circular clarifying the procedure and documentation requirements for filing scheme applications under the Third-Party Fund Management Arrangement.
The clarification applies to Fund Management Entities (FMEs) that are already authorised to provide third-party fund management services under the IFSCA (Fund Management) Regulations, 2025, and is intended to streamline the filing process and ensure regulatory consistency.
Regulatory Background
The circular draws reference to Part D of Chapter VI of the IFSCA (Fund Management) Regulations, 2025, which governs Third-Party Fund Management Services.
IFSCA noted that registered FMEs launching schemes on behalf of third-party fund managers require clearer procedural guidance to ensure uniformity in filings and disclosures.
Who Does the Circular Apply To?
The clarification is applicable to:
- Registered Fund Management Entities (FMEs)
- FMEs authorised to launch schemes on behalf of third-party fund managers
- FMEs operating under the IFSCA regulatory framework
It does not create a new category of entities but clarifies obligations for already authorised FMEs.
Scheme Filing Process: What Remains Unchanged
IFSCA has clarified that FMEs must continue to use the existing scheme filing framework prescribed under the circular:
“Ease of Doing Business – Filing of Schemes or Funds under IFSCA (Fund Management) Regulations, 2022”, dated April 5, 2024.
The current circular supplements this framework by specifying additional disclosures required for third-party fund management arrangements.
Additional Disclosures and Documents Required
In addition to the standard scheme filing documents, registered FMEs must now submit the following details relating to the third-party fund manager:
- Full legal name and registered office address
- Proof of registration or licence issued by the regulatory authority in the home jurisdiction
- A look-through ownership structure identifying the ultimate beneficial owners (UBOs)
- Names and profiles of board members or designated partners, and key managerial personnel (KMPs)
- Assets Under Management (AUM) details and past track record in investment strategies similar to the proposed scheme
- A Declaration-cum-Undertaking confirming compliance with Regulations 107H and 107K of the FM Regulations
- The document evidencing the third-party fund management arrangement between the FME and the third-party fund manager
- An outline covering deal execution, conflict of interest disclosures, and remuneration policies
- Details relating to appointment or change of KMPs, as required under the FM Regulations or related circulars
Mandatory Online Filing Through IFSCA Portal
IFSCA has reiterated that all scheme applications under the Third-Party Fund Management Arrangement must be submitted through the IFSCA Single Window IT System (SWIT):
No alternate mode of submission has been prescribed under the circular.
Legal Basis and Effective Date
- The circular has been issued under Sections 12 and 13 of the IFSCA Act, 2019
- Read with Regulation 146(1) of the IFSCA (Fund Management) Regulations, 2025
- The clarification is effective immediately from January 16, 2026
Why This Clarification Matters
The circular provides:
- Clear procedural certainty for FMEs handling third-party schemes
- Greater transparency in ownership, governance, and track record of third-party fund managers
- Reduced processing delays due to standardised disclosures
- Stronger regulatory oversight while supporting ease of doing business in IFSCs
This move reinforces IFSCA’s objective of positioning IFSCs as a credible and efficient hub for cross-border fund management.
Source: IFSCA Circular dated 16/01/2026