Modified reporting requirements for AIFs: applicability deferred to quarter ending September 30, 2022, per regulatory extension.
The circular postpones the commencement of the modified reporting requirements for Alternative Investment Funds to the quarter ending September 30, 2022, leaving the substance of the revised reporting obligations unchanged and directing AIFs to align compliance and reporting processes with the deferred timeline.

Continuous disclosure compliance: mandatory fines and issuance/listing restrictions until listed issuers rectify disclosures and report payment.
Recognized stock exchanges must impose specified fines and enforcement measures for listed issuers' failures to meet continuous disclosure obligations, with penalties and actions detailed in annexures, fines accruing until rectification and credited to the Investor Protection Fund. Exchanges shall issue notices, coordinate across listings, restrict issuance and further listing via Electronic Book Providers for non-compliance, publish actions and subsequent compliance, and may deviate or abate action only for recorded legal exemptions; SEBI retains its enforcement powers. The regime applies to due dates on or after February 1, 2022.

Validity of observation letters restored to six-month period, with existing letters permitted a one-year launch window.
SEBI has reinstated a six month validity period for observation letters to launch New Fund Offers, reversing the temporary one year extension. Observation letters already issued under the extended one year regime remain valid for launch up to one year from their date. The change is effective immediately and is issued under SEBI's regulatory powers to protect investors and regulate mutual funds.

Virtual meetings for REITs and InvITs extended to June 30, 2022, permitting annual and other unitholder meetings via VC/OAVM.
SEBI permits REITs and InvITs to conduct annual and other unitholder meetings through video conferencing or other audio visual means until June 30, 2022, subject to compliance with the procedure in Annexure I of the June 22, 2020 SEBI circular. The extension aligns with a similar MCA extension and is issued under SEBI's regulatory authority, requiring trustees, managers and other parties to follow prescribed procedural and technical safeguards when convening and conducting meetings via VC/OAVM.

Accredited investor fee flexibility: advisory fees may be bilaterally negotiated, overriding standard prescribed fee modes.
SEBI exempts accredited investors from the prescribed modes and limits on Investment Adviser fees in para 2(iii) of the earlier circular; fees for accredited investors shall instead be governed by bilaterally negotiated contractual terms, while other provisions of the circular remain applicable.

Accredited investor status permits bilateral negotiation of exit loads for large value accredited investors, exempting standard exit-load rules.
The circular confirms that "accredited investor" adopts the AIF Regulations' definition and provides that for "large value accredited investors" the quantum and manner of exit load shall be governed by bilaterally negotiated contractual terms between client and portfolio manager, rendering para 3(iv) of the February 13, 2020 Circular inapplicable to such clients while other provisions remain unchanged.

Investor charter requirement: custodians and DDPs must publish charters online and disclose monthly complaint data publicly.
Registered custodians and Designated Depository Participants must prominently publish the prescribed Investor Charter on their websites, which sets service timelines and investor guidance, and must disclose monthly complaint data and redressal statistics in the Annexure B format on their websites to increase transparency of grievance handling. The timelines apply where client submissions are complete and entities are required to publish monthly data by the prescribed deadline.

Commercial paper listing requirements tightened: enhanced tranche disclosure and issuers under three years limited to Qualified Institutional Buyers.
The circular tightens Commercial Paper listing and disclosure: tranche-level details (ISIN, amount, issue/maturity dates), all credit ratings including unaccepted ratings with dates, CRA name and validity, declaration of rating validity at issuance and listing, issuing/paying agent details; issues by issuers under three years must state subscription is limited to Qualified Institutional Buyers; financial information obligations vary by issuer age, requiring audited/limited review consolidated (where available) and standalone statements with auditor qualifications covering either the last three years or the years of existence. These amendments are effective immediately.

Merchant bankers must publish an Investor Charter and monthly complaints data on their websites for InvIT private placements.
Registered merchant bankers arranging private placements of units by InvITs must publish an Investor Charter on their websites detailing services, timelines, investor rights, application and allotment procedures, do's and don'ts, grievance redressal routes and investor responsibilities; and must disclose monthly investor complaint data in the prescribed Annexure format (by source, receipts, resolutions, pending items, average resolution time and trends), updated by the 7th of the succeeding month, effective January 1, 2022.

Margin collection timing updated: continuous use of risk parameter files and additional snapshot verification for extended trading hours.
The circular withdraws the prior 5:00 PM cut-off for determining client margin thresholds, directing clearing corporations to use Risk Parameter Files to generate margin obligations throughout trading hours. Clearing corporations must send additional snapshots-minimum two for contracts traded until later evening and minimum three for contracts traded into the night-with margins and end-of-day margins determined as per the relevant RPFs.

Mandatory PAN KYC and Nomination: RTAs must not process service requests until documents provided; payments via electronic mode.
SEBI prescribes that RTAs phase the issuance of Form SH13/ISR3 and make it downloadable; follow specified signature verification steps including banker attestation and acceptable bank documents; accept driving licence in smart/book/digital form for name mismatches; permit self-attestation of hard-copy documents except in transmission cases; update folios from Client Master List or demat records per investor authorisation and accept e-sign; and suspend processing of service requests or complaints for physical holders until PAN, KYC and nomination details are furnished, with payments to be made only electronically. RTAs must obtain a practicing Company Secretary's compliance certificate within the prescribed period.

Investor Charter requirement: investment advisers must publish charter, monthly complaint disclosures and complaint lodging links to enhance transparency.
Investment advisers must prominently publish the prescribed Investor Charter and provide a direct complaint lodging link and a link to SEBI SCORES on their websites/mobile apps; those without digital platforms must email the Charter and monthly complaint status to clients. Advisers must disclose monthly complaint data in the Annexure B format by the seventh day of the succeeding month, report pending counts including >3 months and average resolution time, and maintain an internal grievance resolution timeline of 30 days. The disclosure regime takes effect from January 1, 2022.

Investor transparency obligations require research analysts to publish charters and disclose monthly complaints online with direct complaint links.
SEBI requires registered Research Analysts to publish an Investor Charter on their websites/mobile apps or email it to clients if no digital presence exists, and to disclose monthly all investor complaints including SCORES complaints in the prescribed format by the seventh day of the succeeding month. RAs must display a direct complaint lodging option and link to the SCORES portal; those without digital platforms must provide monthly complaint status to investors via email.

Portfolio managers must publish an investor charter, disclose monthly complaint data by the 7th, and provide complaint links.
Portfolio managers must publish an Investor Charter on their websites detailing services, investor responsibilities, timelines, fees, account opening/termination procedures and grievance redressal, and must disclose monthly complaint data (including SCORES complaints) in the Annexure B format by the 7th of the succeeding month. They must provide website/mobile links for lodging complaints and links to SCORES, register on SCORES, include investor relations officer details and grievance mechanisms in the Disclosure Document, and adhere to specified operational timelines for onboarding, disclosures and complaint resolution.

Investor Charter requirement mandates AIFs to disclose grievance data and maintain quarterly complaint records for investor transparency.
AIFs must publish an Investor Charter (Annexure X) in the PPM for new schemes or send it by registered e mail for existing schemes, and disclose investor complaint data in the Annexure Y format-added as a PPM chapter for new schemes or by updating the PPM annually for existing schemes. AIFs shall maintain complaint records compiled within seven days from each quarter end and disclose quarterly and three year complaint statistics, including pending counts, average resolution time and complaints older than three months.

Co investment by AIF managers via portfolio management route now subject to registration, reporting, and modified fee/onboarding rules.
The amended framework permits AIF managers to offer Co investment via the portfolio management route subject to prior intimation if already registered as a Portfolio Manager, or subject to prior registration if not registered. Portfolio Managers must submit monthly reports to the regulator within seven working days (Annexure A) and quarterly client reports (Annexure B). Fee and direct on boarding provisions of earlier guidance do not apply to Co investment, while remaining applicable to other portfolio management services. Reporting formats apply from April 2022; other provisions from the notification date.

Segregation and ring fencing of scheme assets required when using pool accounts, with daily reconciliation and trustee oversight.
Mutual funds may use pool accounts only for mutual fund level transactions where AMCs have board and trustee approved policies and controls ensuring Segregation and Ring-fencing of each scheme's assets, liabilities, bank accounts and securities, with pool accounts reconciled to nil at end of day, unidentified funds allocated to scheme accounts by the next business day, trustee confirmation in half yearly reports, and half yearly audits by trustees' auditors.

Mutual funds must publish an Investor Charter and monthly complaint disclosures on websites within seven days.
SEBI mandates that all Mutual Funds publish an Investor Charter and disclose monthly investor complaint data (including SCORES complaints) on their websites and on AMFI's website in the prescribed format, with information to be posted within the 7th day of the succeeding month. Mutual funds must provide direct complaint-lodging links and a SCORES link/app, display the charter to existing and new unit holders, follow specified timelines for services and disclosures, and are subject to regulatory action for non-compliance.

PMS transactions in corporate bonds must use RFQ for at least 10% of secondary market trades.
PMS must execute at least 10% by value of their monthly secondary market corporate bond trades via the stock exchanges' RFQ platform in OTO or OTM modes, with compliance measured on a rolling three month basis; trades where a PMS is on both sides must use OTO, OTM trades executed with another PMS count as OTM, and PMS may accept contract notes from brokers for RFQ transactions.

Publishing Investor Charter and disclosure of investor complaints by stock brokers on their websites required from Jan 1, 2022.
SEBI mandates that stock brokers publish an Investor Charter and disclose monthly investor complaints data on their websites, make the Charter available to clients and provide complaint statistics in the prescribed format (including pending counts, ageing buckets and average resolution time) updated by the 7th of the succeeding month. Stock Exchanges must notify brokers of these obligations. These disclosure requirements supplement existing mandates and take effect from January 1, 2022.