Specialized Investment Fund Reporting Tightened as Uniformity Was Needed

SEBI has issued a circular dated January 8, 2026, prescribing standardized compliance reporting formats for Specialized Investment Funds (SIFs) to ensure uniformity and clarity in regulatory reporting. The circular provides that all reporting requirements applicable to mutual funds under the SEBI (Mutual Funds) Regulations, 1996, the MF Master Circular dated June 27, 2024, and related guidelines shall also apply to SIFs. It mandates modifications to two key reports: the Compliance Test Report (CTR) and the Half-Yearly Trustee Report (HYTR). The CTR format is amended to include an additional Part IV covering detailed compliance checks specific to SIF regulations, investment restrictions, disclosures, risk bands, and operational norms. Similarly, the HYTR format is expanded by inserting Clause 72A, requiring trustees to certify compliance with governance, risk management, fees, disclosures, and investor protection requirements for SIFs. The circular comes into force immediately and is issued under SEBI’s statutory powers to protect investors and regulate the securities market.

Securities and Exchange Board of India

Circular No. HO/24/13/12(4)2025-IMD-POD-1/I/2062/2026 | Dated: January 08, 2026

To,
All Mutual Funds
All Asset Management Companies (AMCs)
All Registrar and Share Transfer Agents (RTAs)
All Trustee Companies/ Board of Trustees of Mutual Funds
Association of Mutual Funds in India (AMFI)

Madam/ Sir,

Subject: Compliance reporting formats for Specialized Investment Funds (SIF)

1. SEBI vide circular dated February 27, 2025 and subsequent circulars issued thereunder, has specified the regulatory framework for Specialized Investment Funds (‘SIFs’).

2. In order to ensure uniformity and clarity in compliance reporting for SIFs, the compliance reporting formats applicable to SIFs shall be as follows:

2.1. In terms of Regulation 49V(2) of the SEBI (Mutual Funds) Regulations, 1996, all reporting requirements applicable to mutual funds under the SEBI (Mutual Funds) Regulations, 1996, the Master Circular for Mutual Funds dated June 27, 2024 (‘MF Master Circular’), and any other circulars or guidelines issued thereunder, shall also apply to Specialized Investment Funds.

2.2. Compliance Test Report (‘CTR’)

2.2.1. The format for the CTR, as prescribed under Format No. 2.B of the MF Master Circular, shall stand modified to include an additional Part IV, as specified in Annexure A1  to this circular.

2.2.2. All Asset Management Companies managing SIF shall additionally report compliance under Part IV as part of the CTR submitted for Mutual Funds.

2.3. Half-Yearly Trustee Report (HYTR)

2.3.1. The format for the HYTR, as prescribed under Format No. 2.C of the MF Master Circular, shall stand modified to include Clause 72A, as specified in Annexure A2 to this circular.

2.3.2. The Trustees/Trustee Companies of Mutual Funds managing SIF shall additionally report compliance under Clause 72A as part of the HYTR submitted for Mutual Funds.

3. The provisions of this circular shall come into force with effect from the date of this circular.

4. This circular is issued in exercise of the powers conferred under Section 11(1) of the Securities and Exchange Board of India Act, 1992 read with Chapter VI-C of the SEBI (Mutual Funds) Regulations 1996 to protect the interest of investors in securities and to promote the development of, and to regulate the securities market.

5. This circular is available at sebi.gov.in under the link “Legal ->Circulars”.

Yours faithfully,

Peter Mardi
Deputy General Manager
Investment Management Department
+91-22-26449233
peterm@sebi.gov.in

Annexure A1

Part-IV of Compliance Test Report (CTR)

*Note1: This shall be applicable as and when specific certification requirement is specified by the Board.

**Note 2: For the quarter ending December 2025, the compliance regarding restrictions on investments in REITs shall be provided.

Annexure A2

Clause 72A of HYTR

72A: Compliance with respect to Specialized Investment Fund:

1. Whether AMC has the necessary expertise, internal control systems and risk management mechanism to invest in and manage investments as a Specialized Investment Fund;

2. Compliance with respect to minimum investment threshold;

3. Compliance with respect to fees and expenses in accordance with provisions of Regulation 52;

4. Whether Investment strategies launched by SIF are in compliance with the characteristics stipulated in Regulations;

5. Compliance with investment restrictions as prescribed in Regulation and Circulars;

6. Compliance with respect to provisions concerning product differentiation;

7. Compliance with respect to disclosure requirements concerning SIF;

8. Compliance with respect to branding and advertising requirements;

9. Whether AMC has complied with other requirements related to risk management, investor protection, disclosures and reporting.

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