SEBI refreshes its AIF master circular with four new circulars, including the Accredited Investor review
TaxByKK · Compliance News · taxbykk.com5 Nov 2026
In short
SEBI has updated its Master Circular for Alternative Investment Funds, first issued on 3 June 2026, with the date 'last updated' now 5 November 2026. The refresh folds in four later circulars, the newest being the review of the Accredited Investor framework, so AIFs can read all applicable circular requirements in one place.
- Authority
- SEBI, Alternative Investment Fund Department
- Document
- Master Circular for Alternative Investment Funds (AIFs), HO/19/34/11(6)2025-AFD-POD1/I/12928/2026
- Type
- Master circular (updated version)
- Issued
- 3 June 2026
- Last updated
- 5 November 2026
- Length
- 156 pages
What changed
| Item | Before | Now |
|---|---|---|
| Winding up of AIFs, retention of proceeds and 'Inoperative Fund' status | Circular of 16 June 2026 | Incorporated |
| GARUDA green-channel mechanism for placement memoranda | Circular of 30 July 2026 | Incorporated |
| Relaxed timeline of the Accredited Investor mandate for Angel Funds | Circular of 7 September 2026 | Incorporated; Angel Funds registered on or before 10 September 2025 must comply by 31 March 2027, with at most 200 non-accredited investors until then |
| Review of the framework for Accredited Investors | Circular of 5 November 2026 | Incorporated as the Manager-led accreditation chapter |
The master circular states that the circulars listed in its Annexure 24 stand rescinded to the extent they relate to AIFs, and that actions already taken, pending applications and accrued liabilities are preserved. Trustees, sponsors and managers must make sure the compliance test report covers all chapters of the master circular.
Who it applies to
- AIF managers, sponsors and trustees
- Custodians, depositories and registrars and transfer agents serving AIFs
- CAs, company secretaries and lawyers advising AIFs
What to do
- Use the updated master circular, not the superseded version, when preparing the compliance test report.
- Check the Accredited Investor chapter and the Angel Fund deadline of 31 March 2027 against fund onboarding practice.
- Read the winding-up and GARUDA provisions if the fund is closing or filing a placement memorandum.
Reference
SEBI Master Circular for AIFs HO/19/34/11(6)2025-AFD-POD1/I/12928/2026, issued 3 June 2026 and last updated 5 November 2026; issued under section 11(1) of the SEBI Act, 1992.
Read the official PDF: SEBI master circularWritten by TaxByKK from the official notification. Check the official text before you act on it.
Frequently asked questions
What is new in the 5 November 2026 version?
It adds the provisions of the circular of 5 November 2026 on the Accredited Investor framework, alongside three circulars from June, July and September 2026.
Does the master circular create new rules?
It compiles circular requirements in one place. The document does not itself state new rules beyond those in the circulars it lists.
What is the Angel Fund deadline?
Angel Funds registered on or before 10 September 2025 must on-board only Accredited Investors from 31 March 2027, as the master circular records.