CIRCULAR
SEBI/HO/AFD/AFD-POD-1/P/CIR/2025/29 March 03, 2025
To,
All Alternative Investment Funds (AIFs)
Sir/Madam,
Sub: Relaxation in timeline for reporting of differential rights issued by AIFs
1. Securities and Exchange Board of India (Alternative Investment Funds)
Regulations, 2012 (“AIF Regulations”) have been amended and notified on
November 18, 2024, with respect to maintaining pro-rata and pari-passu rights
of investors in a scheme of an AIF.
2. Subsequently, SEBI Circular dated December 13, 2024 on ‘Pro-rata and pari-
passu rights of investors of AIFs’ prescribed, inter-alia, the framework with
respect to differential rights that may be offered by AIFs to select investors
without affecting the rights of other investors.
3. In terms of para 17.1. of the aforesaid SEBI circular, a one-time reporting
requirement has been mandated for AIFs/schemes of AIFs whose PPMs were
filed with SEBI on or after March 01, 2020, and have issued differential right(s)
which do not fall under the implementation standards formulated by Standard
Setting Forum for AIFs. Such information was to be submitted to SEBI in the
prescribed format, on or before February 28, 2025.
4. Based on representation received from the AIF industry requesting additional
time to meet the aforesaid reporting requirement, it has been decided to extend
the said timeline to March 31, 2025, for ease of compliance.
5. This circular shall come into force with immediate effect.
6. This circular is issued with the approval of the competent authority.
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7. This circular is issued in exercise of powers conferred under Section 11(1) of
the Securities and Exchange Board of India Act, 1992, read with Regulations
20(22) and 36 of AIF Regulations, to protect the interests of investors in
securities and to promote the development of, and to regulate the securities
market.
8. The circular is available on SEBI website at www.sebi.gov.in under the
categories "Legal framework - Circulars" and "Info for - Alternative Investment
Funds”.
Yours faithfully,
Sanjay Singh Bhati
Deputy General Manager
Tel no.: +91-22-26449222
ssbhati@sebi.gov.in
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