> **Legal basis:** SEBI Circular HO/19/28/(1)2026-AFD-SEC3/I/6176/2026 dated March 4, 2026, issued under Regulation 20(2)(d) of the SEBI (Alternative Investment Funds) Regulations, 2012 — Effective: June 2026 quarter onwards. Source: https://www.sebi.gov.in/legal/circulars/mar-2026/regulatory-reporting-by-aifs_100120.html. Last updated: September 2026. SEBI-registered Alternative Investment Funds face their second Quarterly Activity Report (QAR) deadline of the new reporting cycle on **October 15, 2026** — covering fund activity for the July–September 2026 quarter. This filing sits under a two-tier reporting framework SEBI put in place through its March 2026 circular, and it applies uniformly to Category I, II and III AIFs, regardless of corpus size. ## Why SEBI Restructured AIF Reporting Under the earlier regime, every AIF filed a detailed quarterly report covering investments, returns, expenses and investor details — every single quarter, at the same depth, regardless of fund size or complexity. With the AIF ecosystem expanding to nearly 2,000 registered funds by mid-2026, SEBI concluded that uniform heavy-duty quarterly reporting placed disproportionate compliance load on smaller managers without adding proportionate regulatory value. The March 2026 circular replaces that single-track system with two distinct filings: a lightweight quarterly touch-point (the QAR) and a comprehensive annual filing (the Annual Activity Report, or AAR). The intent is to reduce quarterly friction while concentrating deeper scrutiny into one annual filing. ## QAR vs AAR: What Each Filing Demands | Feature | Quarterly Activity Report (QAR) | Annual Activity Report (AAR) | | --- | --- | --- | | Applies to quarters | June, September, December only — no QAR for the March quarter | Once per financial year, as of March 31 | | Filing deadline | Within 15 calendar days of quarter-end | Within 30 calendar days of March 31 (by April 30) | | September 2026 quarter deadline | **October 15, 2026** | Not applicable | | Content depth | Fund-level activity summary — deployments, drawdowns, distributions, key events | Comprehensive — strategy, sector allocation, investor composition, IRR/DPI/TVPI, leverage, valuation practices, compliance certification, grievance redressal | | Submission channel | SEBI Intermediary Portal | SEBI Intermediary Portal | | First cycle transition deadline | June 2026 quarter onwards | May 31, 2026 for FY ending March 2026 | > **Key point:** Every SEBI-registered AIF — Category I, II or III, irrespective of corpus size — must file the QAR for the July–September 2026 quarter by October 15, 2026, with no exemption for nil activity. ## Who Must File All SEBI-registered AIFs — Category I, II and III — are covered. As of July 2026, 1,992 AIFs are registered with SEBI, and the circular carries no corpus or size threshold exemption. A ₹20 crore angel fund and a ₹5,000 crore Category III fund carry the identical QAR obligation for the same quarter. ## Consequences of Missing the Deadline Filing failures are actionable under **Regulation 20(2)(d) of the SEBI (AIF) Regulations, 2012**, which requires AIFs to submit reports as directed by SEBI. Depending on the facts, SEBI can: - Issue a show-cause notice to the manager or sponsor. - Levy a penalty under **Section 15HB of the SEBI Act, 1992**, which allows for penalties up to ₹1 crore for contraventions not specifically addressed elsewhere in the Act. - In cases of repeated non-compliance, move toward suspension or cancellation of the AIF's registration. ## Steps to Complete Before October 15 1. **Confirm portal access.** Log into the SEBI Intermediary Portal and verify that registration number, sponsor/manager details and scheme data are current. 2. **Gather the quarter's activity data.** Deployments and drawdowns for July–September 2026, any distributions made, new LP commitments, and portfolio-level events such as exits, write-offs or restructurings. 3. **Reconcile against fund accounts.** Cross-check the figures going into the QAR with the fund's trial balance for the quarter before submission. 4. **Use the post-March-2026 format.** The circular prescribes a revised QAR template — confirm the team isn't still working off the earlier format. 5. **Build in sign-off time.** Many fund structures require trustee or Investment Committee certification before the QAR goes out; factor this into the internal timeline well before October 15. 6. **Submit and retain the acknowledgement** generated by the portal as proof of timely filing. ## Illustrative Example *TechAlpha Capital LLP manages a Category II AIF with a ₹150 crore corpus. During the September 2026 quarter, it deployed ₹22 crore into three portfolio companies, received a ₹5 crore debt repayment, and distributed ₹3 crore to LPs. The QAR captures these transactions, the resulting NAV movement, and LP-level data, filed via the SEBI Intermediary Portal by October 15, 2026. (Illustrative only.)* A fund with zero activity in the quarter is not exempt — a nil-activity QAR still has to be filed to confirm dormancy to SEBI. I'm CA Harun Raaj, Visakhapatnam. If your AIF's manager or trustee needs help getting the September quarter QAR filed and certified before October 15, reach out to our team. --- ## See Also - [SEBI Angel Fund Accreditation Deadline Extended to March 2027](https://www.harunraaj.com/blog/sebi-angel-fund-accredited-investor-deadline-2027) - [SEBI's Semi-Annual Valuation Mandate for Category II AIFs](https://www.harunraaj.com/blog/sebi-semi-annual-valuation-category-ii-aifs) - [SEBI's Accredited Investor Overhaul: What It Means for HNIs, NRIs](https://www.harunraaj.com/blog/sebi-accredited-investor-overhaul-hnis-nris) Canonical: https://www.harunraaj.com/blog/aif-qar-september-2026-quarter-deadline-october-15