Fund Management Entities in International Financial Services Centres (IFSCs) now have until 31 December 2026 for their key managerial personnel (KMPs) and employees to successfully complete the certification course specified by IFSCA under Regulation 7(6) of the IFSCA (Fund Management) Regulations, 2025. The International Financial Services Centres Authority (IFSCA) extended the timeline through Circular F. No. IFSCA-AIF/127/2026-Capital Markets/1 dated 29 September 2026, which came into force with immediate effect.
Quick Answer
IFSCA, by Circular F. No. IFSCA-AIF/127/2026-Capital Markets/1 dated 29 September 2026, has extended to 31 December 2026 the timeline for KMPs and employees of Fund Management Entities in IFSCs to successfully complete the certification course under Regulation 7(6) of the IFSCA (Fund Management) Regulations, 2025. The extension amends paragraph 3 of the 1 April 2026 circular and took effect immediately. All other provisions of the 1 April 2026 and 10 August 2026 circulars are unchanged.
Quick Reference
What Changed?
Only one parameter changed: the deadline for completing the certification course. The circular states that the timeline specified in paragraph 3 of the 1 April 2026 circular "has been extended to December 31, 2026."
Which Provision Underlies the Certification Courses?
Regulation 7(6) of the IFSCA (Fund Management) Regulations, 2025 is the provision under which IFSCA specifies certification courses for personnel of Fund Management Entities. The circular refers to this sub-regulation as the source of the two course-specifying circulars. It does not reproduce the text of Regulation 7(6). The full obligation, including which categories of personnel must certify, sits in the Regulations and the earlier circulars.
IFSCA has specified certification courses for KMPs and employees of Fund Management Entities in International Financial Services Centres (IFSCs). Its circular of 29 September 2026 gives them until 31 December 2026 to successfully complete the course. The circular does not state a reason for the extension, and it leaves all other provisions of the 1 April 2026 and 10 August 2026 circulars unchanged.
Which Certification Courses Are Covered?
The circular refers to two IFSCA circulars, each specifying a course offered by a professional institute.
What the circular does not settle. The extension is expressed as an amendment to the timeline "specified in paragraph 3 of the circular dated April 1, 2026." Paragraph 3 of the new circular says all other provisions of both the April and August circulars remain unchanged. The new circular does not say separately whether the 10 August 2026 circular carries its own completion timeline. In practice, this means entities relying on the ICAI course should read the 10 August 2026 circular alongside this one and, if any doubt remains, seek confirmation from IFSCA. This is a practical reading point, not a statement in the circular.
Who Is Affected?
When Does the Extension Apply?
The circular states that it "shall come into force with immediate effect." On that basis, the extension applies from 29 September 2026, the date of the circular. The circular prescribes no phased implementation.
Under What Legal Authority Was the Circular Issued?
IFSCA issued the circular under Sections 12 and 13 of the International Financial Services Centres Authority Act, 2019, read with Regulation 7(6) and Regulation 146(1) of the IFSCA (Fund Management) Regulations, 2025 ("FM Regulations"). The circular does not describe the content of these provisions, so this article does not characterise them.
What Is Not Addressed in the Circular?
The circular is short, and several points professionals may ask about are outside its text:
- the original deadline it replaces;
- any consequence or penalty for missing the 31 December 2026 date;
- the categories of KMPs or employees who must certify;
- any further extension mechanism.
Entities should not assume answers on these points. The Regulations and the two earlier circulars are the places to check.
Compliance Checklist
No form or filing is prescribed by this circular.
Frequently Asked Questions
What did IFSCA change in this circular?
IFSCA extended the deadline for successful completion of the certification course by KMPs and employees of Fund Management Entities to 31 December 2026. The change amends the timeline in paragraph 3 of the circular dated 1 April 2026.
What is the new deadline for the IFSCA fund management certification course?
IFSCA has extended to 31 December 2026 the deadline for KMPs and employees of Fund Management Entities in IFSCs to successfully complete the fund management certification course. The extension is made by Circular F. No. IFSCA-AIF/127/2026-Capital Markets/1 dated 29 September 2026.
Who must comply?
The circular is addressed to all Fund Management Entities in the IFSCs. It concerns certification by their KMPs and employees under Regulation 7(6) of the IFSCA (Fund Management) Regulations, 2025.
When did the extension take effect?
IFSCA's extension circular, dated 29 September 2026, came into force with immediate effect.
Which certification courses has IFSCA specified?
The 1 April 2026 and 10 August 2026 IFSCA circulars, both referred to in the 29 September 2026 circular, specify two courses: "Regulatory Framework for Fund Management in IFSC: AIFs and Retail Schemes" offered by the Institute of Company Secretaries of India (ICSI), and "Regulatory Framework for Fund Management in IFSC" offered by the Institute of Chartered Accountants of India (ICAI).
Have any other conditions in the earlier circulars changed?
No. IFSCA's circular of 29 September 2026 states that all other provisions of its circulars dated 1 April 2026 and 10 August 2026 remain unchanged.
What happens if the course is not completed by 31 December 2026?
The circular does not state any consequence. Entities should check Regulation 7(6) of the FM Regulations and the earlier circulars, and should not assume a grace period beyond 31 December 2026.
Was the earlier deadline mentioned in this circular?
No. The circular refers only to paragraph 3 of the 1 April 2026 circular, which contains the original timeline.
CorpLawUpdates Analysis
This section is editorial analysis, not a requirement of the circular.
For compliance teams, the immediate issue is the calendar. The circular gives roughly three months from issue to 31 December 2026, and IFSCA introduced the ICAI course only on 10 August 2026. Entities that were waiting on that course option should treat the extension as a working window, not a reason to defer enrolment.
The drafting leaves one point worth confirming: the extension is worded against paragraph 3 of the April circular, while the August circular is preserved as "unchanged." Firms whose people are on the ICAI route should read the August circular's own terms and, if needed, raise a query with IFSCA. Also watch the IFSCA website for any further clarification.
Source Note
Document: Circular — Extension of timeline for completion of Certification Course by KMPs and employees of Fund Management Entities under the IFSCA (Fund Management) Regulations, 2025
Issuing authority: International Financial Services Centres Authority
Reference: F. No. IFSCA-AIF/127/2026-Capital Markets/1
Date: 29 September 2026
Signatory: Mihir Upadhyay, Chief General Manager, Division of Funds Supervision
Primary source: The circular states that a copy is available on the IFSCA website, www.ifsca.gov.in. Search by the reference number above.
This article is for informational and educational purposes only and does not constitute legal or regulatory advice. Readers should verify the applicable primary regulatory source before taking action.
