AIF Compliance: Ongoing SEBI Reporting and Audit Duties
AIF compliance starts the day your SEBI certificate arrives. Category I and II funds report to SEBI every quarter, and every fund faces annual audit, valuation and investor-disclosure duties. We build the calendar, prepare the reports and coordinate your auditor, valuer and trustee.
What it is
AIF compliance is everything a registered fund must do after getting its SEBI certificate. It covers periodic reports to SEBI, an annual audit of the Private Placement Memorandum (PPM) terms, audited accounts, independent valuation and disclosures to investors. It runs for the life of the fund.
The rulebook is the SEBI (Alternative Investment Funds) Regulations, 2012, as amended, plus SEBI circulars. Registration itself is a separate job, covered on our AIF registration page. This page is about what happens next, every quarter and every year.
Who it applies to
Category I and II funds
Venture, SME, infrastructure, private equity and debt funds. They report quarterly and value investments half-yearly.
Category III funds
Hedge-style and long-short funds. Funds that borrow to invest report monthly, and NAV reporting is quarterly for closed-end and monthly for open-end schemes.
Sponsors and managers
Think of a Gurugram venture fund with a March year-end. Its manager runs the filings. The sponsor and trustee receive the compliance test report, so they need the dates too.
Why it matters
It protects your certificate
Regulation 5 lets SEBI ask for information, and giving false or misleading information must be reported under Regulation 7(1)(c). Clean reporting keeps you in good standing.
Investors read your reports
Your investors are largely institutions and high-net-worth families. Timely NAV, valuation and portfolio disclosures are how they judge the manager.
It stops small slips growing
A missed quarterly report is simple to fix on day two. Found a year later, it shows up in the compliance test report and the audit.
Documents required
For SEBI reporting
- Portfolio and investment activity data for the quarter
- Investor and commitment details
- Investor complaint data
- Custodian records
For annual duties
- Audited financial statements (Regulation 20(14))
- PPM compliance audit report
- Compliance test report to sponsor and trustee
- Valuation reports from the independent valuer
For investors and tax
- NAV statements and valuation disclosures
- Material PPM change notices
- Tax pass-through statements for Category I and II funds (see tax planning)
- Updated KYC and key investment team details
AIF compliance calendar
| Frequency | Duty | When |
|---|---|---|
| Quarterly | Activity report to SEBI on the SI portal | 15 days after quarter-end: 15 October 2026, 15 January and 15 April 2027 |
| Quarterly | Investor complaint data | Within 7 days of quarter-end |
| Half-yearly | Independent valuation of investments (Regulation 23) | Every six months |
| Annual | Compliance test report to sponsor and trustee | Within 30 days of financial year-end |
| Annual | PPM compliance audit | Within 6 months of financial year-end |
| Annual | Audited accounts | Every financial year |
Category III funds that borrow report monthly instead of quarterly. SEBI has also asked AIFs to upload NAV to the depositories under its circular of 6 February 2026, within 30 days of the valuation date. Formats change, so we check the latest circular before each filing.
Rules that run all year
Some obligations are not dates but limits. Sponsor and manager must keep a continuing interest of 2.5% of the corpus or ₹5 crore, whichever is lower, in Category I and II, and 5% or ₹10 crore in Category III. A Category I or II fund cannot put more than 25% of investable funds in one investee company; Category III is capped at 10%. Units stay in dematerialised form. Borrowing by Category I and II funds is for temporary needs only: up to 30 days, four occasions a year, and 10% of investable funds.
Category I and II funds are close-ended with a minimum tenure of three years. SEBI allows an extension of up to two years for standard funds, and one year is allowed for liquidation after tenure ends.
How it works
Build the compliance calendar
We list every date for your category, from SEBI reports to the valuer and auditor deadlines. Each item gets an owner and a reminder two weeks ahead. In practice, this one sheet prevents most slips.
Collect the data each quarter
We pull investment, commitment and complaint data from your books and fund administrator. Our online bookkeeping team keeps those books current, and we check each report against the last one.
Prepare and file the reports
We prepare the SEBI activity report and file on the SI portal. The PPM audit, valuation and audited accounts are signed by the qualified auditor and the independent valuer we coordinate with you.
Review and fix
Each year we run a self-review against the compliance test report points. Slips are corrected and logged before the sponsor and trustee ask.
Timelines
Every quarter
SEBI activity report due 15 days after quarter-end. Next dates: 15 October 2026, 15 January 2027 and 15 April 2027.
Within 30 days of year-end
Compliance test report to the sponsor and trustee, covering the fund’s compliance with the Regulations for the year.
Within 6 months of year-end
PPM compliance audit. For the year ended 31 March 2026 this fell on 30 September 2026.
What happens if you miss AIF compliance
Questions from SEBI
SEBI can ask for explanations and information under Regulation 5. Repeated lapses make every later filing harder to defend.
Findings in your own reports
The compliance test report and PPM audit record breaches. Investors and the trustee see them, and so would a future due diligence team.
Questions when you raise the next fund
Institutional investors often ask for the last audit and compliance test report before they commit. Gaps in earlier reports invite awkward questions.
Frequently asked questions
What is AIF compliance?
It is the set of continuing duties a registered fund must meet under the SEBI (AIF) Regulations, 2012 and SEBI circulars. It covers quarterly reports to SEBI, annual audit of PPM terms, audited accounts, valuation and investor disclosures. It begins at registration and lasts until the fund is wound up. We turn it into a dated calendar for your fund.
How often must a Category II AIF report to SEBI?
Quarterly. Category I and II funds, and Category III funds that do not borrow, file an activity report on the SI portal every quarter, within 15 days of quarter-end. The next dates are 15 October 2026, 15 January and 15 April 2027. Category III funds that borrow report monthly. We prepare and file each report.
What is the PPM compliance audit?
It is an annual audit confirming that the fund has followed the terms of its Private Placement Memorandum. It is due within six months of the financial year-end, so by 30 September for the year ended 31 March. Certain funds, such as angel funds, are exempt. A qualified auditor signs the report, and we coordinate the data and timing.
What is the compliance test report?
It is a yearly report on how far the fund has complied with the Regulations, submitted to the sponsor and trustee within 30 days of financial year-end. The manager responds to comments within 15 days. It is an internal check, and we prepare it with you from the quarterly files.
How often must an AIF value its investments?
Category I and II funds value investments half-yearly through an independent valuer under Regulation 23. Category III funds report NAV quarterly for closed-end schemes and monthly for open-end schemes. SEBI also requires NAV to be uploaded to the depositories. A registered valuer signs the valuation, and we organise the process.
What limits apply to a Category I or II fund?
A fund cannot invest more than 25% of investable funds in a single investee company, and Category III is capped at 10%. Borrowing is temporary: up to 30 days, four times a year, within 10% of investable funds. Sponsor and manager must keep a continuing interest. We check proposed deals against these limits first.
Do AIFs have to keep units in demat form?
Yes. The Regulations require AIF units to be held in dematerialised form. This ties into the NAV upload to depositories, since the depository shows the latest NAV against each ISIN. If your fund is moving over, we coordinate with your registrar and transfer agent. It is a one-time setup, then routine.
Is tax reporting part of AIF compliance?
Yes. Category I and II funds enjoy pass-through treatment, so the fund reports income to the tax department and to investors, while Category III does not. The Income-tax Act, 2025 applies from tax year 2026-27 and renumbers sections and forms, so we check the current form names before each filing. A practising CA signs where required.
Can Taxhint act as trustee, valuer or auditor?
No. Trustees, auditors and independent valuers are separate qualified professionals who sign their own reports. Taxhint prepares data and documents, tracks every date, files on the SEBI SI portal and coordinates with them. You keep independence where the Regulations need it, and one team chases the dates.
What it costs
Our fee plus the government fee that applies to your case, quoted before you commit. Tell us the situation and we will price it exactly.
Government fees: SEBI charges a scheme fee of ₹1 lakh at least 30 days before launching a scheme, and the first scheme is exempt. Auditor and valuer fees are separate and depend on fund size.
Ready to begin?
Tell us your fund category and year-end, and we will send you the dated compliance calendar.