AIF Ongoing Compliance & Reporting

Quarterly AIF Business Activity Report to SEBI

15 January · 15 April · 15 July · 15 October

Within 15 calendar days of each quarter-end. SEBI simplified the format in March 2026.

Quarterly Compliance Report to Investors (Cat III)

30 May · 30 August · 30 November

Category III AIFs only. Covers leverage, risk, NAV, and strategy updates.

Annual Report to SEBI and Investors

Within 180 days of FY-end (by 30 September)

Covers Mar quarter — no separate quarterly report for March quarter.

Annual PPM Audit (Regulation 29)

Within 6 months from FY-end

Mandatory under Regulation 29 of SEBI (AIF) Regulations, 2012. Audit report filed with SEBI.

Compliance Test Report (CTR)

Annual — as per SEBI Master Circular

Covers fundraising, disclosures, valuation, stewardship, governance, conflict, and grievance redressal.

Daily Leverage Report (Cat III only)

Daily — within market hours

Each Category III AIF must maintain and report daily leverage data to SEBI.

1 — Data collection

Portfolio positions, transaction log, investor commitments, complaint register, leverage positions (Cat III)

2 — Report drafting

Quarterly AIF Business Activity Report (SEBI format), Investor Report (Cat III), compliance exception summary

3 — Review & sign-off

Manager review, trustee/sponsor notification, compliance officer sign-off before submission

4 — SEBI submission

Online filing via SEBI SCORE / AIF portal before the 15th of the relevant month

5 — Evidence archiving

Filing acknowledgement, submission timestamp, compliance folder update for annual audit trail

6 — Next-quarter preview

Updated compliance calendar, event-based filing watch list, PPM amendment flags if strategy or terms changed

What is the deadline for quarterly reporting to SEBI?

AIFs must submit a quarterly AIF Business Activity Report to SEBI within 15 calendar days of each quarter-end — by 15 January (Q3), 15 April (Q4), 15 July (Q1), and 15 October (Q2). No separate quarterly report is required for the March quarter as the Annual Report covers that period. SEBI revised the quarterly reporting framework through SEBI Circular SEBI/HO/AFD/.../CIR/2026/100120 dated March 2026, simplifying the format and reducing compliance burden for smaller AIFs.

What is the Compliance Test Report (CTR)?

The CTR is an annual SEBI filing that tests the AIF's compliance across the full set of obligations in the SEBI Master Circular — including fundraising disclosures, valuation methodology, benchmarking, stewardship code, risk management, governance, conflict of interest policies, and investor grievance redressal. It must be submitted to SEBI along with the Annual Report.

What does the annual PPM audit cover?

The PPM audit under Regulation 29 of the SEBI (AIF) Regulations, 2012 must be conducted by a Chartered Accountant or a firm of CAs. It verifies that the fund has operated in accordance with the disclosed PPM — investment strategy, concentration limits, fee structure, distribution waterfall, and governance. The audit report must be submitted to SEBI within 6 months of financial year-end.

Does a Category III AIF have additional compliance obligations?

Yes. Category III AIFs (hedge funds, PIPE funds) have daily leverage reporting obligations, must submit a Quarterly Compliance Report directly to investors (not just SEBI), and are subject to stricter SEBI CSCRF cybersecurity obligations due to the algorithmic and leveraged nature of their strategies. Continuing interest for Category III sponsors is also higher — 5% of corpus or ₹10 Cr, whichever is lower.

What happens if SEBI reporting deadlines are missed?

Missed quarterly reports and event-based filings can trigger SEBI show-cause notices, adjudication proceedings, and penalties under the SEBI Act, 1992. Repeated non-compliance can also affect the AIF's ability to raise subsequent closes and may impact the manager's registration. We track all deadlines proactively as part of our compliance retainer.

Do all AIFs have quarterly reporting obligations?

Yes. All registered AIFs must submit a quarterly AIF Business Activity Report to SEBI within 15 calendar days of each quarter-end. The Quarterly Compliance Report to investors is specifically required for Category III AIFs. Event-based filings apply to all AIFs when the triggering event occurs, regardless of category.

Is annual compliance enough after AIF registration?

No. The AIF compliance framework spans annual, quarterly, event-based, and in some cases daily obligations (Category III leverage reporting). Annual compliance alone — PPM audit and annual report — does not satisfy the quarterly business activity reports, investor communication requirements, or event-based filings. Missing quarterly reports is the most common compliance gap we see in newly registered AIFs.

What changed in March 2026 for AIF reporting?

SEBI issued a circular on Regulatory Reporting by AIFs in March 2026 (SEBI/HO/AFD/.../CIR/2026/100120), which introduced a revised quarterly activity report format. The updated format reduces the data points required for smaller AIFs and rationalises the disclosure framework. We update client compliance calendars proactively when SEBI amends the reporting format.

Can AIF compliance and regulatory reporting be outsourced?

Yes. SEBI explicitly permits outsourcing of non-critical functions including accounting and regulatory filings to service providers. Many AIF managers outsource their compliance calendar management, SEBI reporting, investor reporting preparation, and PPM audit coordination to a CA firm or compliance advisor, retaining the investment management function internally.