Extended timeline for IFSCA fund management certification: What FMEs must know
The International Financial Services Centres Authority has formally granted additional time to Key Managerial Personnel (KMPs) and employees of Fund Management Entities (FMEs) operating in International Financial Services Centres to complete the mandatory certification prescribed under the IFSCA (Fund Management) Regulations, 2025.
Through Circular No. F. No. IFSCA-AIF/127/2026-Capital Markets/1 dated September 29, 2026, the deadline for successfully passing the notified certification courses has been shifted from September 30, 2026 to December 31, 2026, while all other regulatory conditions remain intact.
This article explains the background of the requirement, the specific circulars involved, and the compliance implications for FMEs and their KMPs and employees.
Regulatory background to the certification requirement
Statutory foundation
The certification mandate flows from the International Financial Services Centres Authority Act, 2019 and the IFSCA (Fund Management) Regulations, 2025:
- The present circular has been issued by IFSCA by exercising its powers under:
Sections 12 and 13of the International Financial Services Centres Authority Act, 2019; andsub-regulation (6) of regulation 7andsub-regulation (1) of regulation 146of the FM Regulations.
These provisions collectively empower IFSCA to prescribe eligibility, qualification and certification norms for FMEs and to issue circulars governing operational and conduct requirements.
Role of sub-regulation (6) of regulation 7
Sub-regulation (6) of regulation 7 of the IFSCA (Fund Management) Regulations, 2025 sets out a framework enabling IFSCA to stipulate certification courses for certain personnel of FMEs. Under this enabling provision, IFSCA has been specifying mandatory certification programmes that KMPs and relevant employees must complete within specified timelines.
The new circular dated September 29, 2026 is a continuation of this regulatory exercise and deals exclusively with extending the time available for completion of such certification.
Earlier circulars specifying the certification courses
IFSCA had previously identified two specific certification courses qualifying under sub-regulation (6) of regulation 7, through separate circulars.
April 1, 2026 circular – ICSI course
The first circular, Circular No. IFSCA/13/2026-Capital Markets/1 dated April 01, 2026, introduced a course offered by the Institute of Company Secretaries of India. This circular specified the programme titled:
“Regulatory Framework for Fund Management in IFSC: AIFs and Retail Schemes”
Key features of the April 1, 2026 circular included:
- Identification of the above course as an eligible certification course for KMPs and employees of FMEs under
sub-regulation (6) of regulation 7. - Prescription of a timeline (now subsequently revised) within which the relevant personnel were required to successfully complete the course.
- Alignment of the course content with regulatory and compliance aspects specific to fund management activities in IFSCs, with a focus on AIFs and retail schemes.
August 10, 2026 circular – ICAI course
Subsequently, through Circular F. No. IFSCA-PLNP/80/2024-Capital Markets/10082026 dated August 10, 2026, IFSCA notified an additional certification pathway via a course conducted by the Institute of Chartered Accountants of India. The course specified is titled:
“Regulatory Framework for Fund Management in IFSC”
This circular:
- Recognised the ICAI programme as another qualifying course under the same
sub-regulation (6) of regulation 7. - Provided FMEs and their KMPs/employees with an alternate certification route, in addition to the ICSI course.
- Operated alongside the April 1, 2026 circular without displacing its provisions, thereby giving FMEs a choice between the two recognised courses.