A Pension Fund may engage distributors to market, solicit, or service Subscribers, but remains fully and solely responsible for each distributor's conduct, compliance, and activities. The Pension Fund must ensure that engaged distributors comply with applicable regulations and directions issued by the Authority.

Trustees and their directors, officers and governing-body members must act in a fiduciary capacity solely for Subscribers' benefit and protect and enhance superannuation benefits. They must apply reasonable care, diligence, skill and prudence, prioritise Subscribers' interests in actual or potential conflicts, and ensure that Scheme administration complies with the Scheme Information Document, trust deed, applicable pension regulations, subsidiary instructions and other applicable laws.

Trustee appointment eligibility requires independence from the Pension Fund, authorisation or registration to act as trustee, and adequate infrastructure, manpower and related resources. The proposed Trustee must have sufficient operational capacity to discharge its functions and obligations.

Trust creation requires settlement under applicable laws in force in India. The trust deed must expressly include the Trustee's roles and responsibilities in accordance with regulatory requirements. Lawful settlement and a deed-based specification of trustee functions are required components of the trust arrangement, ensuring that trustee duties are recorded in its governing instrument.

A Pension Fund must ensure that all Scheme assets are held in the safe custody of an independent Custodian. The Custodian is responsible, in accordance with applicable law and regulatory requirements, for safekeeping and settlement of Scheme assets and reporting of holdings.

Pension Funds must undergo annual financial audits by independent auditors under applicable law and submit the audit report to the Authority within thirty days of receipt. The Authority may also initiate special audits or appoint auditors for concurrent audits when considered necessary.

Every Pension Fund must take adequate steps to redress Subscriber grievances and handle them in conformity with the prescribed framework for complaint handling and grievance redressal by regulated entities in the IFSC. This obligation, governed by the relevant regulatory circular, forms part of the general responsibilities applicable to Pension Funds.

Pension Funds must submit prescribed reports on operations, financial performance, investment portfolios and compliance status within specified reporting timelines. At onboarding, Subscribers must receive the Scheme Information Document, fee details, grievance procedures, and terms for contributions, withdrawals and exit. Yearly performance reports and annual consolidated statements on transactions, investment performance and fees are required. Changes to core onboarding disclosures must be communicated to Subscribers immediately.

Pension Funds must maintain secure electronic systems for Subscriber data and transactions, ensuring data integrity, confidentiality and availability in accordance with applicable laws. Each Subscriber must be assigned a unique Pension Account number. Subscribers must receive online access to their account details, including transaction history, current valuation and investment allocation.

Pension Fund risk management requires comprehensive stress testing and scenario analysis at regular intervals to evaluate portfolio resilience under extreme conditions. Pension Funds must formulate, implement and maintain robust business continuity and disaster recovery plans, subject to regular testing to ensure uninterrupted operations as ongoing resilience and continuity controls.

Pension Funds must maintain a Board-level Risk Committee and implement a three lines of defence model. Investment management and operations own and control operational risks; compliance, legal and risk-management functions set risk appetite, monitor regulatory requirements and report deficiencies; and internal audit reports directly to the Board, providing independent assurance on governance, risk management and internal controls.

Pension Fund Boards must maintain and periodically review a documented risk appetite statement defining the overall risk accepted in Scheme management. The statement must be operationalised through specific, measurable and actionable quantitative and qualitative risk limits for the whole portfolio and its individual components.

Pension Fund risk management must cover the key risk categories identified in the Fourth Schedule. Detailed methodologies for managing those risks must be set out in internal risk management policies and conform to the prescribed requirements. Pension Funds must also implement a currency risk management policy that includes hedging strategies where appropriate.

Every Pension Fund must establish and maintain a comprehensive enterprise-wide risk management framework approved by its Board. The framework must identify, measure, monitor and mitigate all material risks arising from and associated with Scheme management, and must be integrated into all aspects of the Pension Fund's operations.

Pension funds must comply with concentration limits governing exposures to a single issuer and counterparty. The applicable limits are prescribed in Part B of the Third Schedule and form a mandatory component of investment management and asset allocation. Compliance requires pension fund investments to remain within the specified single-issuer and counterparty concentration parameters.

Pension Funds must observe geographic diversification limits across India and global markets. Investments in India may reach the entire Scheme AUM. Investments outside India are capped per country at 20% of Scheme AUM, except the United States of America, subject to a 50% ceiling. Both direct and indirect investments are included in calculating exposure.

Pension Funds may invest in listed equities, fixed income instruments, alternative investment funds, frequently traded commodities, and liquidity instruments, along with other specified financial products. Asset-class and sub-class investment limits must conform to Part A of the Third Schedule. Each Scheme's applicable limits must be determined accordingly and disclosed in its Scheme Information Document.

Pension Fund investment strategy must align with the long-term nature of pension liabilities, with the long-term safety of the Scheme as its primary objective. Investments must be diversified across asset classes, sectors, and geographies to reduce risk. Pension Funds must maintain sufficient liquidity for regular withdrawals and payments, establish a robust risk-management framework for investment decisions, exercise safety and prudence, and act as responsible stewards of Subscriber assets.

Healthcare benefit option permits a Pension Fund to enable a Subscriber to allocate part of pension contributions to a dedicated healthcare savings account. Information concerning the account must be included in the Scheme Information Document, and the option must comply with the requirements specified in the Second Schedule.

Expert valuers empanelled by Customs are to be consulted where specialist opinion is required for valuation or examination of precious and semi-precious stones. Referral for consignment valuation requires prior approval from the designated Assessment Group or Dock officer, and examination may be conducted under officer supervision. The Appraising Group must maintain a register recording Bills of Entry, valuer details, observations and remarks for each referral.