Quick answer: IFSCA's Consultation Paper: Guidelines for engaging Financial Solicitation Professionals (FSPs), dated 9 November 2026, proposes disclosure-based rules for individuals who solicit clients for GIFT IFSC financial institutions. FIs would stay liable for their solicitors' acts and must publish their names; comments are due by 30 November 2026.
The International Financial Services Centres Authority (IFSCA) has issued the Consultation Paper: Guidelines for engaging Financial Solicitation Professionals (FSPs) on 9 November 2026, proposing a disclosure-based framework for the individuals — other than employees — that financial institutions in GIFT IFSC engage to solicit clients and bring them to the IFSC's products and services. The paper carries a draft circular as Annexure-A and invites public comments by 30 November 2026. Nothing in the proposal is final yet: the draft circular is expressly marked as a draft, and the guidelines will take shape only after IFSCA considers the comments it receives.
In plain business-owner language, the change is about trust at the front door. If someone approaches you or your client claiming to represent a GIFT City bank, fund or insurer, this paper would make it possible to check — on the institution's own website — whether that person is genuinely engaged by it, and it would make the institution answerable for what that person says and does. The solicitor would have to name the institution, tell the truth about the product, promise no returns, and never touch your money.
⚠️ Read this first — it is a proposal, not a rule. The draft circular in Annexure-A is marked "DRAFT CIRCULAR" and carries placeholder references (eF.No. …, December XX, 2026). No financial institution is bound by these guidelines today, and no FSP has any duty under them until a final circular issues. The final circular, if issued, will state when it comes into force — the draft says it would take immediate effect on issuance. Do not advise a client that these rules already apply in the IFSC.
What IFSCA is proposing
The consultation paper's objective, in its own words, is to seek comments and suggestions from the public and stakeholders on the proposed guidelines for engaging Financial Solicitation Professionals by Financial Institutions in the IFSC. The proposal is built on a simple observation in the paper: the IFSC ecosystem has grown sharply across banking, capital markets, fund management and insurance, and as the range of products on offer expands, financial institutions want to reach more clients — including clients overseas — by engaging professionals who are not their employees to solicit business on their behalf.
That outreach, the paper says, needs two things at once: wider access and stronger consumer protection. A client approached by a stranger claiming to act for a GIFT City institution should be able to tell, quickly and reliably, whether the person is genuinely engaged by that institution. The paper's answer is disclosure: the institution must publish the names of the people it has engaged, and the solicitor must identify the institution at the first step of every conversation.
The proposal rests on sections 12 and 13 of the International Financial Services Centres Authority Act, 2019 — the same enabling provisions cited in the draft circular. It is a guidelines framework, not a registration regime: unlike the model portfolio consultation paper issued the same day, which works through the IFSCA (Capital Market Intermediaries) Regulations, 2025, this paper proposes a circular that would bind financial institutions directly.
Why a disclosure approach — and what happened to the February plan
This paper has a backstory that matters, because it changes the direction of travel. On 24 February 2026, IFSCA issued a consultation paper on the draft International Financial Services Centres Authority (IFSC Financial Advisers) Regulations, 2026, which would have created a full regulatory framework for financial advisers engaged by IFSC institutions — a registration-style regime with its own regulations.
Having considered that proposal further, IFSCA has now decided that a separate regulatory framework for Financial Advisers "may not be warranted at this stage". Instead, the Authority proposes a lighter, disclosure-based approach: no new registration category, no separate rulebook for advisers — just duties on the financial institution and on the individual solicitor, enforced through the institution's own accountability. That is a deliberate step back from regulation toward transparency, and it is the single most important policy signal in the paper: IFSCA is choosing to regulate the relationship, not to licence the person.
The distinction matters for anyone who followed the February paper. The February draft regulations are not being taken forward in that form. What is on the table now is a shorter, sharper instrument — a draft circular of eight clauses — and the consultation asks whether that is enough.
Old position vs proposed position
Who is a Financial Solicitation Professional?
The draft circular's definition is deliberately wide. It applies to all Financial Institutions registered, licensed, recognised, authorised, permitted or approved by the Authority which engage, or propose to engage, individuals — other than their employees — for soliciting or facilitating access to financial products or financial services on their behalf. Such an individual is a "Financial Solicitation Professional" or "FSP".
Three features of that definition deserve attention. First, it covers both current and proposed engagements — an FI planning to use solicitors is inside the framework from the start. Second, it is not limited to India: the consultation paper expressly contemplates FSPs operating in overseas jurisdictions, soliciting clients abroad for GIFT City products. Third, it is the individual who is the FSP, not a firm — the paper speaks of professionals, not agencies, and the duties in the draft circular are written for a person approaching a client.
What is NOT covered: the paper does not say whether any financial institution already engages such solicitors informally, and this article does not claim that any does. The paper also does not create any new product approval or change what products an FI may offer — it governs only how clients are approached.
The six duties every FSP would owe a client
Clause 3 of the draft circular requires the financial institution to undertake appropriate due diligence before engaging an FSP — and then sets out six requirements the FSP must meet while soliciting clients or facilitating their access to financial products or services. Each is a condition of the engagement, not a suggestion:
1. Name the institution — every time
The FSP must clearly disclose to the client the name of the Financial Institution whose financial product or financial service is being offered. The client should never have to guess whose product is on the table.
2. No false authority
The FSP must not claim to be an employee of the financial institution, or to be registered with or approved by the Authority. This is the anti-impersonation rule: the solicitor is an engaged outsider, and must present themselves as one.
3. Tell the truth — and promise nothing
The FSP must provide accurate information on the financial product or financial service, and must not make any false, misleading or exaggerated statement or give any assurance of returns. A guaranteed-return pitch from a solicitor would be a direct breach.
4. Stay inside your mandate and your jurisdiction
The FSP must solicit only the financial products or financial services offered by the FI, and only in the jurisdiction for which the FSP is engaged — in compliance with the laws of that jurisdiction. An FSP engaged for one market cannot freelance into another, and cannot sell products the FI does not offer.
5. Never touch client money
The FSP must not accept or hold any money, securities or other assets of a client. Money flows to the institution, never through the solicitor's hands.
6. Keep client information confidential
The FSP must keep the information of the client confidential. The requirements are stated to be in addition to any code of conduct applicable under the Regulations governing the Financial Institution — so an FI's own conduct rules continue to apply on top.
The institution stays on the hook
The sharpest clause in the draft is Clause 4: the Financial Institution "shall remain responsible for all acts and omissions of an FSP in the course of soliciting clients or facilitating their access to financial products or financial services on its behalf." That is the whole point of the disclosure-based model. IFSCA is not licensing the solicitor, so it holds the regulated institution accountable for the solicitor instead.
Clause 5 makes that accountability operational: the FI must take appropriate action, including termination of the engagement, against an FSP whose conduct is not in accordance with the Guidelines. And Clause 6 gives clients the tool to check: the FI must publish a list of all FSPs engaged by it on its website — or, as the case may be, on a dedicated webpage on the website of its parent entity — and must promptly update the list upon appointment, suspension, termination or cessation of engagement of any FSP.
Read together, the three clauses form a closed loop: the institution vets the person, owns what the person does, can remove the person, and must tell the public who the person is. A client who is approached can verify the name on the list; an institution that keeps a bad actor on its list after a breach would have no excuse.
Who is affected
- Financial institutions in GIFT IFSC — banks, capital market intermediaries, fund managers, insurers and other regulated FIs that use, or plan to use, non-employee solicitors. They would carry due-diligence, supervision, termination and public-listing duties.
- Individuals soliciting clients for IFSC institutions — in India and overseas. They would work under six express conduct duties, including no return assurances and no handling of client money.
- Clients approached by a solicitor — they would gain a verifiable check: the FI's published FSP list, and a right to be told the institution's name upfront.
- Compliance and legal teams at IFSC institutions — the due-diligence process, the website list and the prompt-update duty create new ongoing work, and the FI's responsibility for FSP acts raises the stakes of a weak engagement process.
- Parent entities of IFSC institutions — where the FSP list sits on a dedicated webpage on the parent's website, the parent's web and compliance teams are involved too.
What to do next
If you are a financial institution, a solicitor, or a client of the IFSC, the window to shape these guidelines is open now — and it is short.
1. Read the consultation paper and the draft circular (Annexure-A) from IFSCA's website before forming a view — the duties above are a summary, not a substitute.
2. Decide whether to comment. Comments are invited on the draft circular, not only on the concept — clause-wise suggestions carry more weight than general support or opposition. The biggest open questions are practical: what counts as "appropriate" due diligence, how quickly a public FSP list must be updated, and whether a disclosure-based model is enough without registration.
3. Use the paper's format. Comments should be provided in the format given in the paper — with your name and designation, contact number and email address, organisation name, and, for each clause, the serial number, clause number, text of the clause, comments or suggested modifications, and detailed rationale.
4. Send comments by 30 November 2026 by email to Shri Akash Boddeda, Manager, IFSCA ([email protected]) and Shri Nikhil, Assistant Manager, IFSCA ([email protected]), with a copy to Shri Arjun Prasad, Chief General Manager, IFSCA ([email protected]). Use the subject line: "Comments on the draft Circular on Guidelines for engaging of Financial Solicitation Professionals".
5. If you are a financial institution using solicitors today, start mapping the work now: a due-diligence checklist for each FSP, a page on your website (or your parent's) to publish the list, and a process to update it promptly on appointment, suspension, termination or cessation. If the final circular takes immediate effect on issuance, as the draft provides, there will be no grace period to build these.
6. If you are approached by someone claiming to act for a GIFT City institution, ask them to name the institution, and check the institution's website for the published FSP list once the framework is in force. Never hand money, securities or documents to a solicitor — under the proposed rules, an FSP must not accept or hold client assets at all.
7. Do not treat the guidelines as law yet. The draft circular is not in force. No FSP duty and no FI listing duty exists until IFSCA issues a final circular after considering comments.
What is NOT covered: the paper does not change anything for financial advisers or solicitors outside the IFSC — SEBI's onshore investment-adviser and research-analyst frameworks are untouched. It does not authorise any new financial product, and it does not say when a final circular will issue — the draft carries a placeholder date of December XX, 2026, which is part of the draft, not a commitment.
Related IFSCA coverage
- IFSCA Model Portfolio Consultation Paper 9 November 2026 — the second consultation paper IFSCA issued the same day, proposing model portfolios for GIFT IFSC research entities, comments also by 30 November 2026.
- All IFSCA updates on CorpLawUpdates.in — circulars, regulations, consultation papers and compliance updates for GIFT IFSC.
Frequently asked questions
What is IFSCA's Financial Solicitation Professionals consultation paper of 9 November 2026?
It is the Consultation Paper: Guidelines for engaging Financial Solicitation Professionals (FSPs), dated 9 November 2026, issued from Gandhinagar. It proposes disclosure-based guidelines for individuals engaged by GIFT IFSC financial institutions to solicit clients, and carries a draft circular as Annexure-A.
Who is a Financial Solicitation Professional under the proposed guidelines?
An individual, other than an employee, engaged by a financial institution in the IFSC to solicit clients or facilitate their access to the institution's financial products or services. The definition covers engagements in India and overseas, and FSPs the institution proposes to engage as well as those already engaged.
What must an FSP disclose to a client?
The FSP must clearly disclose the name of the financial institution whose product or service is being offered, and must not claim to be an employee of that institution or to be registered with or approved by IFSCA.
Is the financial institution liable for what its solicitor does?
Under the draft circular, yes. Clause 4 provides that the financial institution remains responsible for all acts and omissions of an FSP in the course of soliciting clients or facilitating their access to financial products or services on its behalf.
Can an FSP accept money from a client?
No. The draft circular expressly provides that an FSP must not accept or hold any money, securities or other assets of a client. Client money goes to the institution, never through the solicitor.
Can an FSP promise returns on a product?
No. The FSP must provide accurate information and must not make any false, misleading or exaggerated statement or give any assurance of returns.
How can I check whether a person soliciting me is genuinely engaged by an IFSC financial institution?
Under the proposal, every financial institution engaging FSPs must publish a list of all FSPs engaged by it on its website, or on a dedicated webpage on its parent entity's website, and update it promptly when an engagement starts, is suspended or ends. That list is the check — but it exists only once the final circular is in force.
When is the last date to comment on the FSP draft circular?
30 November 2026. Comments go by email to Akash Boddeda ([email protected]) and Nikhil ([email protected]), with a copy to Arjun Prasad ([email protected]), with the subject line "Comments on the draft Circular on Guidelines for engaging of Financial Solicitation Professionals".
Are the FSP guidelines in force now?
No. The circular in Annexure-A is a draft marked "DRAFT CIRCULAR" with placeholder references. It will come into force only if and when IFSCA issues a final circular after considering comments; the draft provides it would then take immediate effect.
What happened to IFSCA's February 2026 Financial Advisers Regulations proposal?
IFSCA consulted on draft IFSC Financial Advisers Regulations on 24 February 2026, but has now decided a separate regulatory framework for Financial Advisers may not be warranted at this stage. The FSP guidelines replace that approach with a lighter, disclosure-based model.
Sources
- IFSCA — Consultation Paper: Guidelines for engaging Financial Solicitation Professionals (FSPs) (official PDF, 9 November 2026): ifsca.gov.in
- IFSCA — Report and Publication listing (official): ifsca.gov.in
- IFSCA — Public Consultation listing (homepage): ifsca.gov.in
This article is based on the official IFSCA consultation paper dated 9 November 2026, read in full from IFSCA's website. The draft circular it carries is a proposal open for comment until 30 November 2026 and is not yet in force. Verify the final position from IFSCA's website before acting.
