SEBI Simplifies AIF Reporting: New Annual Activity Report Framework from FY 2025-26
What Changed
The Securities and Exchange Board of India (SEBI) issued a circular on March 4, 2026, overhauling the regulatory reporting framework for Alternative Investment Funds (AIFs). Issued under Regulation 28 of the SEBI (Alternative Investment Funds) Regulations, 2012, the circular replaces the existing detailed quarterly reporting system with a comprehensive annual report supplemented by limited quarterly filings. The changes take effect immediately, with the first Annual Activity Report due by May 31, 2026 for FY 2025-26.
Key Changes in the New Framework
1. Annual Activity Report (New Requirement)
All AIFs, regardless of category (Category I, II, or III), must now submit a Comprehensive Annual Activity Report at the end of each financial year.
- Submission deadline: Within 30 calendar days from the end of March (i.e., by April 30 each year).
- First report: For FY ending March 2026, due by May 31, 2026 (extended deadline for the transition year).
- Submission mode: Online through the SEBI Intermediary Portal (SI Portal).
- Coverage: The annual report will capture all material data points that were previously spread across four quarterly submissions, providing SEBI with a consolidated year-end snapshot of fund activity, portfolio composition, and investor data.
2. Simplified Quarterly Reporting
The existing detailed quarterly activity report is being replaced with a Limited Quarterly Activity Report in a revised format.
- Submission deadline: Within 15 calendar days from the end of each quarter.
- First quarterly report under new format: For the quarter ending June 2026.
- March quarter exemption: No quarterly report is required for the March quarter of any year, since the Annual Activity Report already covers that period.
- Reduced scope: The quarterly report will contain only time-sensitive information that SEBI needs between annual filings, significantly cutting the data compilation effort for fund managers.
3. Superseded Provisions
The circular supersedes the reporting requirements under Clause 15.1 of the SEBI Master Circular for AIFs dated May 7, 2024. All previous quarterly reporting formats and timelines under that clause are now replaced by the new framework.
4. Revised Report Formats
The updated reporting templates have been published on the Indian Venture and Alternate Capital Association (IVCA) website within three days of the circular’s issuance. Fund managers should download and review these formats immediately to prepare their internal data collection processes for the first annual filing.
Why This Matters
India’s AIF industry has grown rapidly, with over 1,300 registered AIFs managing combined commitments exceeding Rs. 12 lakh crore. The previous quarterly reporting system imposed significant compliance costs, especially on smaller Category I and Category II funds with limited back-office resources. Four detailed quarterly reports required continuous data compilation, verification, and submission, often diverting resources away from core investment management activities.
By consolidating the primary reporting obligation into a single annual submission, SEBI has effectively reduced the reporting frequency by 75% while maintaining regulatory oversight through limited quarterly filings. The move also aligns with SEBI’s broader “ease of doing business” initiative for the fund management industry, following similar simplifications in mutual fund and portfolio management reporting in recent years.
Compliance Timeline
| Action | Deadline | Applicable From |
|---|---|---|
| First Annual Activity Report (FY 2025-26) | May 31, 2026 | FY ending March 2026 |
| First Limited Quarterly Report (new format) | July 15, 2026 | Quarter ending June 2026 |
| Annual Activity Report (FY 2026-27 onwards) | April 30 each year | FY ending March 2027 onwards |
| March Quarter: No quarterly report needed | N/A | Ongoing |
What Fund Managers Should Do Now
- Download the new templates from the IVCA website and compare them with your current data collection systems.
- Identify data gaps: The Annual Activity Report may require data points not captured in your existing quarterly process. Map the new template fields against your current records.
- Update internal timelines: Remove the March quarterly filing from your compliance calendar and replace it with the Annual Activity Report deadline (April 30, or May 31 for the first year).
- Coordinate with portfolio companies: If the annual report requires updated NAV, valuation, or performance data from investee companies, send data requests now. Do not wait until April.
- Register on SI Portal: Ensure your fund’s SI Portal access is active and updated. Test the submission process before the deadline.
Practical Implications
For CA Professionals
Advise AIF clients to begin compiling FY 2025-26 data now. The first Annual Activity Report is due May 31, 2026, and the format is entirely new. Review the IVCA-published templates and map them against existing internal records. Identify data gaps early, especially around portfolio company valuations, investor contribution schedules, and distribution waterfall details. This is also an opportunity to offer compliance advisory services to smaller AIFs that may not have in-house regulatory teams.
For Founders and Startups
If your startup has raised capital from AIFs, be prepared for information requests from your AIF investors. The Annual Activity Report requires fund managers to report on portfolio company performance and valuations. Ensure your financials and cap table data are up to date to facilitate smooth reporting by your investors. Delays in providing this data could strain the investor relationship.
For MSME Owners and Fund Managers
Smaller AIF managers will benefit the most from reduced quarterly compliance. Use the freed-up bandwidth to focus on investment management and investor relations. However, do not underestimate the first annual filing. The comprehensive format will require more data than any single quarterly report previously did. Start preparation early to avoid a last-minute rush before the May 31 deadline.
Next Steps
Download the revised reporting formats from the IVCA website. Map your existing data systems to the new Annual Activity Report template. Begin compiling FY 2025-26 data for the May 31 submission. For the quarter ending June 2026, prepare to file the limited quarterly report by July 15, 2026 in the new format. The shift from quarterly to annual reporting is a welcome simplification, but the first filing cycle will require extra preparation to get right.
Need help navigating SEBI’s new AIF reporting requirements? Get expert guidance from the regulatory team at TaxUpdate.in to ensure your fund is compliant before the May 31 deadline.
Disclaimer: This article is for informational purposes only and does not constitute legal or tax advice. Please consult a qualified professional for advice specific to your situation. Information is current as of March 22, 2026.