SEBI Revises Mutual Fund Registration Application Form 2026 — Single Consolidated Format Replaces Forms A, C and D

SEBI Consolidates Mutual Fund Registration Form: Why This Circular Matters

If you've ever assembled a Mutual Fund registration application, you know the paperwork has always come in pieces — Form A to get in-principle approval, then Forms C and D to lock in the final registration of the Asset Management Company. As of August 17, 2026, SEBI has folded all three into a single, consolidated Mutual Fund registration application form, set out as Annexure A to circular HO/24/11/36(24)2026-IMD-RAC4/I/18849/2026.

This isn't a cosmetic relabeling exercise. It follows directly from the recent overhaul of the SEBI (Mutual Funds) Regulations, 2026 and the SEBI Intermediaries Regulations, both of which restructured the eligibility and governance framework that sponsors, AMCs and trustees must now satisfy. Rather than leaving practitioners to reconcile three separately-worded forms against the new regulations, SEBI has rebuilt the application into one document that walks through both stages of registration — in-principle approval and final registration — in a single continuous flow.

For a CS professional advising a prospective sponsor, or a compliance officer at an AMC preparing a fresh filing, the practical takeaway is simple: the old Form A, Form C and Form D templates are no longer the ones to use. Everything else under the Master Circular for Mutual Funds dated March 20, 2026 — the substantive eligibility thresholds, the net worth figures, the profitability tests — stays exactly as it was.

What Exactly Changed — One Form Instead of Three

Prior to this circular, registering a Mutual Fund was a two-stage process handled through three distinct forms:

• Form A — submitted by the sponsor to obtain in-principle approval to set up a Mutual Fund.
• Form C — submitted, together with Form D, when applying for final registration of the Asset Management Company.
• Form D — accompanying Form C for the final registration stage.

SEBI has now consolidated all three into a single application form, structured internally as Stage I (Application for In-Principle Approval) and Stage II (Application for Final Registration of the AMC) within the same document. The circular is explicit that this is a form-level change: "All other conditions specified in the Master Circular, shall remain unchanged." No net worth threshold, profitability test, or eligibility route has been altered — only how that information gets captured and submitted.

The Registration Journey: Stage I to Stage II

The new Form A is organised as a continuous two-stage journey. Here's the sequence a prospective sponsor now follows:

Stage I — Application for In-Principle Approval, Part by Part

Part A — Identification and Constitution of the Sponsor

This opening section establishes who the sponsor actually is. Applicants must state the sponsor's name and legal type, registered and operating addresses, and contact-person details.

The sponsor type declared here determines whether Part H (PIV/PE-specific requirements) later applies.

Part B — Shareholding and Capital Structure

Part B is where SEBI tests whether the sponsor can actually fund the AMC. It calls for the sponsor's shareholding pattern and Ultimate Beneficial Owner(s), its authorised/issued/subscribed/paid-up capital structure, the proposed net worth contribution to the AMC (as both an amount and a percentage), the sponsor's latest auditor-certified net worth, and five years of audited financial statements.

Part C — Which Eligibility Route Does the Sponsor Take? (Regulation 5)

Every sponsor must elect one of two routes under Regulation 5(a) of the SEBI (Mutual Funds) Regulations, 2026, and satisfy every item-wise condition applicable to that route.

Part D — Business Activities, Experience and Regulated Activities

Sponsors must describe their line of business and financial-services experience, and tabulate the regulated activities of the sponsor and its associates/subsidiaries — naming each entity, its business area, its regulator (if any), assets managed (in Rs crore), and number of customers or investors.

Part E — Management, Associates and Group Companies

This section calls for the sponsor's (and its associates'/subsidiaries') organisation structure, board of directors (with PAN for Indian entities or passport for non-Indian entities), names of Key Management Personnel, and the experience and qualifications of each board member.

Part F — Database Verification and Regulatory History

Applicants must verify the sponsor, its associates, subsidiaries, group companies and their directors against four specified databases, and provide an undertaking in respect of each:

Applicants must also file a self-certified "fit and proper person" declaration under Schedule II of the SEBI (Intermediaries) Regulations, 2008, covering the applicant, directors/managing partners, KMP, promoters or controlling persons, and Ultimate Beneficial Owners — plus details of any regulatory action taken against the sponsor or its associates by any Indian or foreign regulator in the preceding five years.

Part G — Procedures and Policies

Part G is essentially SEBI asking to see the sponsor's internal control systems on paper: a write-up on customer on-boarding and grievance handling, the organisational structure for query and grievance resolution, five years of complaints history (including any compensation paid), the compliance process and reporting hierarchy, the conflicts-of-interest policy, and the insider trading/employee trading policy along with its monitoring systems.

Part H — Additional Requirements Where the Sponsor Is a PIV or PE Fund

Where applicable, this part requires the certificate of incorporation of the sponsor entity; the AIF registration certificate (where the PE fund is registered in India); confirmation that a foreign sponsor is identified as a PE fund in its home jurisdiction; documentary proof of at least five years' experience as a fund/investment manager; and — the headline figure here — evidence of having managed committed and drawn-down capital of not less than ₹5,000 crore as on the date of application. An investment-activity report for the preceding one year and a self-certified declaration on committed and drawn-down capital are also required.

Part I — Annexures the Sponsor Must Provide at Stage I

• Write-up on the sponsor's financial-services activities and experience
• Memorandum and Articles of Association of the sponsor
• Self-certified declaration covering all clauses of Regulation 5(a)–(h)
• Declaration that the sponsor's stake in the AMC will remain encumbrance-free at all times
• Details of fines levied by any regulatory body in the preceding five financial years
• Details of court cases or litigation involving the sponsor(s) in the preceding three years

Stage I closes with a signed sponsor declaration confirming the information is true, complete and correct, and compliant with the SEBI (Mutual Funds) Regulations, 2026. For corporate sponsors, this must be signed by the company's authorised signatory — and where a pooled fund's control lies with its investment manager, by the investment manager, since it is the entity actually exercising control over the pooled funds.

Stage II — Application for Final Registration of the AMC, Part by Part

Before filing the Stage II form, applicants must first submit draft Articles and Memorandum of Association of the AMC and Trustee Company for SEBI's approval.

Part A — Particulars of the AMC

This part covers the AMC's name, registered and correspondence addresses, compliance officer contact details, an extract of the main object clause permitting AMC activity, the proposed capital structure and shareholding pattern, the AMC's latest auditor-certified net worth, names of associate organisations/group companies/subsidiaries, board composition (with experience and qualifications), Key Management Personnel, and a list of internal controls and policy manuals.

Part B — Additional Particulars Where an Existing AMC Is Proposed

In addition to Part A, applicants must state the date and place of incorporation of the existing AMC, provide details of any court cases, litigation or regulatory actions involving the AMC in the preceding three years, and furnish the AMC's existing registration details.

Part C — Annexures the AMC Must Provide

This is the most operationally detailed part of Stage II. It requires:

• A detailed business plan for the AMC
• Confirmation of adequate infrastructure, including KMPs, capital and related resources
• Details of physical infrastructure — access controls, order management system, and risk management framework
• The investor services framework, including customer on-boarding and investor servicing processes
• IT infrastructure details — system audit report, network architecture, cybersecurity measures, and the policy for monitoring KMP social-media activity
• The Business Continuity Plan (BCP) and Disaster Recovery (DR) framework
• The compliance process and reporting hierarchy
• The conflict-of-interest policy
• The insider trading and employee trading policy, with monitoring systems

Stage II closes with a signed AMC declaration confirming compliance with the SEBI (Mutual Funds) Regulations, 2026 and the SEBI (Intermediaries) Regulations, 2008.

Compliance Checklist — What to Do Before Your Next Filing

Frequently Asked Questions

CorpLawUpdates Analysis

The most significant thing about this circular is what it deliberately doesn't do: it doesn't move a single threshold. The ₹150 crore net worth figure for Route 2, the ₹10 crore average-profit bar for Route 1, and the Rs 5,000 cror₹5,000 crore committed-capital test for PE/PIV sponsors are all carried over unchanged from the SEBI (Mutual Funds) Regulations, 2026. What SEBI has done instead is rationalize the paperwork architecture around those thresholds — collapsing a fragmented, three-form process into one document that mirrors the regulator's own two-stage approval logic.

The practical compliance challenge is less about eligibility and more about internal process discipline. Firms that have built standard operating procedures, checklists, or automated document-assembly workflows around the old Form A / Form C / Form D structure will need to rebuild those workflows around the new Parts A–I (Stage I) and Parts A–C (Stage II) architecture — particularly since Part H (PIV/PE sponsors) and the database-verification requirements in Part F are now presented as integrated steps within the same form rather than standalone annexures.

One area worth flagging for practitioners: the circular gives no transition window. Any application already in the pipeline using the legacy forms should be reviewed against the new Annexure A structure without delay, since the circular reads as effective from the date of issue with no grandfathering language.

Looking ahead, this kind of form-consolidation exercise typically follows — rather than precedes — a substantive regulatory overhaul, and it often signals that SEBI is moving toward tighter alignment between its Mutual Fund and Intermediaries frameworks. Compliance teams should watch for further procedural circulars streamlining other registration or reporting formats under the SEBI (Mutual Funds) Regulations, 2026 in the coming months.