The Securities and Exchange Board of India (SEBI) has reset the clock on Know Your Customer (KYC) reviews for Foreign Portfolio Investors (FPIs). Circular No. HO/19/34/14(10)2026-AFD-POD3/I/24814/2026, dated 30 October 2026 and titled “Rationalisation of periodicity of KYC review for FPIs”, replaces the existing review cycle with a new table of intervals: every two years or every eight years, depending on the FPI’s risk jurisdiction, category and regulated status. The new intervals take effect from 1 December 2026.
In plain business-owner language: the KYC clock for a foreign fund investing in India is being reset — from 1 December 2026 the review comes round every two or eight years instead of every year or every three years, and the renewal paperwork gets one item shorter. For custodians, Designated Depository Participants (DDPs) and the funds themselves, that means fewer KYC rounds to run, fewer document chases and less repeated paperwork over the life of an FPI registration.
💡 In one line: from 1 December 2026, FPI KYC reviews happen every 2 or 8 years under a new risk-based table, and FPIs no longer have to intimate changes in previously furnished information when they continue their registration — only the continuance fee remains.
What SEBI has changed
The circular amends the SEBI Master Circular for FPIs, DDPs and Eligible Foreign Investors dated 30 May 2024, as amended from time to time. It makes two substantive changes, and states its reason in one sentence: the decisions were taken “with a view to rationalise these requirements, reduce compliance burden and promote Ease of Doing Business”.
First, the KYC review cycle is stretched. Paragraph 5 of Part B of the Master Circular previously provided for KYC review of FPIs annually or every three years, depending on jurisdiction, category and regulated status. Paragraph 3.2 of the new circular substitutes Table 6 under sub-paragraph (i) of Para 5 with a new table (reproduced below). The circular is issued under Section 11(1) of the Securities and Exchange Board of India Act, 1992, read with Regulation 44 of the SEBI (Foreign Portfolio Investors) Regulations, 2019, and is signed by Deputy General Manager Manish Kumar Jha.
Second, one renewal-time formality is removed. Paragraph 4 of Part A of the Master Circular previously required an FPI (other than an FPI investing only in Government Securities) to intimate changes in previously furnished information or submit a no-change declaration at the time of continuance of registration. Paragraph 2.2 of the new circular dispenses with that requirement, and paragraph 3.1 rewrites Para 4 accordingly: sub-paragraph (ii) is omitted and the remaining sub-paragraphs are renumbered.
The new KYC review table (from 1 December 2026)
Two notes in the circular sit alongside that table. For GS-FPIs — FPIs investing only in Government Securities — the KYC review follows the periodicity applicable to their respective bank accounts, as prescribed by the Reserve Bank of India. For SWAGAT-FI FPIs, the period is 10 years. Both are unchanged by this circular (see “What stays the same” below).
The same new intervals are also written into the Investor Charter for Designated Depository Participants at Annexure-H of the Master Circular: the entry in the “Expected Timelines” column against serial number 4 (“KYC Review / Update”) is substituted with the same table. That matters in practice, because the Investor Charter is the document DDPs publish for their FPI clients — so the new timelines will show up in the service standards FPIs themselves see.
Old position vs new position
One honesty note on that comparison: the circular describes the old position only in the general terms quoted above — annually or every three years depending on jurisdiction, category and regulated status — and does not reproduce the old Table 6. This article therefore does not map old cell values one by one against the new table; any cell-by-cell old-to-new claim beyond the circular’s own general statement would be filling a gap the document does not fill, and is marked NOT CHECKED rather than asserted.
What stays the same
First, the two special categories are untouched. Paragraph 2.1 expressly preserves the KYC-review periodicity applicable to GS-FPIs and SWAGAT-FI FPIs. A government-securities-only FPI still follows the RBI-prescribed bank-account cycle, and a SWAGAT-FI FPI still sits on a 10-year cycle. The new 2- and 8-year intervals apply to FPIs generally, outside those two categories.
Second, continuance still costs a fee, and the deadline for it is now stated in the rewritten sub-paragraph. An FPI that wishes to continue its registration for the subsequent block of three years (10 years in the case of SWAGAT-FI) must pay the fees to its DDP, and must pay them at least 15 days prior to the current validity of its registration “in order to facilitate a smooth continuance process”. What has gone is only the accompanying change-intimation or no-change declaration — not the fee, and not the continuance itself.
Third, the circular does not remove KYC itself. It changes how often the review comes round and drops one renewal-time intimation. It does not say that other KYC obligations, documentation requirements or change-reporting duties outside the continuance moment disappear, and this article does not claim that they do — anything beyond the circular’s own text on that point is NOT CHECKED.
Who is affected
The circular is addressed to FPIs, to DDPs and custodians, to the depositories, and to the stock exchanges and clearing corporations — in other words, to the whole chain that onboards and services foreign portfolio investment in India. The practical effects fall in three places.
FPIs themselves get a longer, simpler calendar. A Category I FPI from a non-high-risk jurisdiction, or a regulated Category II entity from such a jurisdiction, moves to an eight-year review cycle. A Category I fund registered under Regulation 5(a)(i) from a high-risk jurisdiction also moves to eight years, while other high-risk-jurisdiction FPIs and non-regulated Category II entities elsewhere sit on a two-year cycle. Every FPI also loses one renewal formality: no more change-intimation or no-change declaration at continuance.
DDPs and custodians carry the implementation work. Paragraph 4 directs depositories, custodians and DDPs to make the necessary changes in their systems and processes to give effect to the circular, and to bring the changes to the notice of the FPIs concerned. Their published Investor Charter timelines change to the new table as well, so client-facing service standards have to be updated, not just back-office diaries.
Advisers and compliance teams — law firms, company secretaries, chartered accountants and consultants who run FPI onboarding and renewals — need to re-base their compliance calendars. Any diary entry that still assumes an annual or three-yearly KYC review for a client FPI will be wrong after 1 December 2026, and any continuance checklist that still includes the change-intimation step will be asking for a document SEBI no longer requires at that stage.
What to do next
Step 1 — Find your cell in the new table. Identify the FPI’s risk jurisdiction (high-risk or not), its category (I or II), and, where relevant, whether it is registered under Regulation 5(a)(i) or is a regulated entity. That combination fixes the new interval: 2 years or 8 years. GS-FPIs and SWAGAT-FI FPIs should confirm they are in the unchanged lane rather than applying the new table.
Step 2 — Re-diary the next review. Move the next KYC review date to the new cycle with effect from 1 December 2026, and confirm the revised date with the DDP or custodian in writing. Do not rely on a diary entry set under the old annual-or-three-yearly cycle once the new table is in force.
Step 3 — Strip the intimation from continuance checklists, but keep the fee deadline. At the next continuance, the change-intimation or no-change declaration is no longer required. The fee is: pay it to the DDP at least 15 days before the current registration validity ends, or the “smooth continuance” the circular promises will not happen.
Step 4 — DDPs and custodians: update systems and notify clients. Paragraph 4 makes this an express direction, not a suggestion. System changes, revised Investor Charter timelines and client notices should all be in place for the 1 December 2026 commencement, so that no FPI is chased for a review or a declaration the new framework no longer requires.
⚠️ Fee trap to avoid: the trap here is the 15-day fee deadline, not the review cycle. An FPI that treats “eased KYC” as “nothing to do at renewal” and misses the fee payment 15 days before validity ends risks a break in continuance. The relief removes paperwork; it does not remove the fee or its deadline.
What is NOT covered
This circular does not change the FPI registration framework itself, the eligibility conditions for Category I or Category II registration, or the investment conditions and restrictions that apply to FPIs. It does not change the GS-FPI or SWAGAT-FI review cycles. It does not announce any change to beneficial-ownership disclosure, to documentation at onboarding, or to reporting duties other than the single continuance-time intimation it removes — those questions are outside this circular and are NOT CHECKED here. It also does not change anything for domestic investors: the circular is addressed to the FPI chain only.
Frequently asked questions
From when do the new KYC review intervals apply?
From 1 December 2026. Paragraph 5 of the circular states that its provisions come into force with effect from that date.
How often will my FPI’s KYC be reviewed now?
Every 2 years or every 8 years, depending on the new Table 6: risk jurisdiction (high-risk or non-high-risk), FPI category (I or II), and, for some cells, regulated status or registration under Regulation 5(a)(i). The table in this article reproduces the circular’s intervals cell by cell.
Do I still have to intimate changes when I continue my FPI registration?
No — not at continuance. The circular dispenses with the requirement to intimate changes in previously furnished information (or submit a no-change declaration) at the time of continuance of registration, and omits the relevant sub-paragraph of the Master Circular.
Do I still have to pay the continuance fee?
Yes. The FPI must pay the fees to its DDP for the subsequent block of three years (10 years for SWAGAT-FI), at least 15 days before the current validity of its registration ends.
Does this change anything for FPIs investing only in Government Securities?
No. GS-FPIs are expressly unchanged: their KYC review continues to follow the periodicity applicable to their respective bank accounts, as prescribed by RBI.
Does this change anything for SWAGAT-FI FPIs?
No. SWAGAT-FI FPIs are expressly unchanged, and the circular’s note records their KYC review period as 10 years.
What must DDPs and custodians do?
Make the necessary changes in their systems and processes to give effect to the circular, and bring the changes to the notice of the FPIs concerned. Their Investor Charter timelines for “KYC Review / Update” change to the new table.
Sources
Primary source: SEBI Circular No. HO/19/34/14(10)2026-AFD-POD3/I/24814/2026 dated October 30, 2026, “Rationalisation of periodicity of KYC review for FPIs” (official SEBI PDF) — https://www.sebi.gov.in/sebi_data/attachdocs/oct-2026/1793358139677.pdf. Circular landing page on sebi.gov.in — https://www.sebi.gov.in/legal/circulars/oct-2026/rationalisation-of-periodicity-of-kyc-review-for-fpis_105504.html. Instrument amended, as cited in the circular: SEBI Master Circular for FPIs, DDPs and Eligible Foreign Investors dated May 30, 2024 (Para 4 of Part A; Para 5 of Part B, Table 6; Annexure-H Investor Charter for DDPs). Legal basis stated in the circular: Section 11(1) of the Securities and Exchange Board of India Act, 1992, read with Regulation 44 of the SEBI (Foreign Portfolio Investors) Regulations, 2019.
