Issuing Authority: SEBI, Investment Management Department | Date of Issue: 21st July 2026 | Effective: Immediately | NISM Series XIII requirement for SIF distribution ends 21st September 2026
Quick Reference — Circular HO/24/13/17(1)2026-IMD-POD-1/I/16895/2026
SEBI Circular on SIF Distributor Certification — What Changed
The Securities and Exchange Board of India (SEBI) has, through Circular No. HO/24/13/17(1)2026-IMD-POD-1/I/16895/2026 dated 21st July 2026, revised the certification requirements applicable to entities engaged in the sale and/or distribution of Specialized Investment Funds (SIFs). The circular is addressed to all Mutual Funds, all Asset Management Companies (AMCs), all Trustee Companies, all Registrars to an Issue and Share Transfer Agents (RTAs), and the Association of Mutual Funds in India (AMFI).
Paragraph 1 traces the background: SEBI had originally issued the SIF regulatory framework via Circular No. SEBI/HO/IMD/IMD-I POD-1/P/CIR/2025/26 dated 27th February 2025. Those provisions were since incorporated under Chapter 21 of the SEBI Master Circular for Mutual Funds dated 20th March 2026 ("the MF Master Circular"), with paragraph 21.10 of that Master Circular setting out the certification requirements for SIF distribution.
Per paragraph 3, based on representations received from industry participants and following discussions with the National Institute of Securities Markets (NISM), SEBI reviewed the certification requirement and has now decided to modify paragraph 21.10 accordingly.
New Certification — NISM Series-V-D
Any person employed, engaged, or to be employed/engaged in the sale and/or distribution of SIF products must hold a valid "NISM Series-V-D – Mutual Fund - Specialized Investment Fund Distributors Certification." Entities holding this certification are eligible to distribute both Mutual Fund and SIF products, without separately holding the "NISM Series V-A – Mutual Fund Distributors Certification."
Mutual-Fund-Only Distributors — No Change
Revised paragraph 21.10.2 clarifies that entities engaged in the sale and/or distribution of only Mutual Fund products shall continue to comply with the NISM Series V-A certification, as specified under Gazette Notification No. LAD-NRO/GN/2010-11/09/6422 dated 31st May 2010. This requirement is unaffected by the new SIF-specific certification.
Sunset of NISM Series XIII for SIF Distribution
Revised paragraph 21.10.3 states that the existing requirement of holding "NISM Series XIII – Common Derivatives Certification" for the sale and/or distribution of SIF products shall not be applicable after 21st September 2026.
Transition Arrangements for Existing NISM XIII Holders
SIF distributors holding a valid NISM Series XIII certification, obtained on or before 21st September 2026, are not required to obtain the new NISM Series-V-D certification until their existing NISM Series XIII certification expires. During this transition period, such distributors must continue to hold a valid NISM Series V-A certification, as required under the erstwhile framework.
Compliance Responsibility and Scope
Revised paragraph 21.10.5 places responsibility on AMFI and AMCs to ensure compliance with these certification requirements by distributors and agents. Paragraph 4 of the circular confirms that all other provisions of the MF Master Circular dated 20th March 2026 remain unchanged. Per paragraph 5, the circular's provisions come into force with immediate effect.
The circular is issued under Section 11(1) of the SEBI Act, 1992, read with Regulation 84 of the SEBI (Mutual Funds) Regulations, 2026, and Regulation 3(1) of the SEBI (Certification of Associated Persons in the Securities Markets) Regulations, 2007. It is signed by Peter Mardi, Deputy General Manager, Investment Management Department.
Key Change — Old vs New SIF Distributor Certification Requirements
Compliance Checklist — SIF Distributor Certification Transition
☑ Identify all distributors/agents currently selling SIF products and check their existing NISM certification status (V-A, XIII, or both).
☑ For distributors without a valid NISM Series XIII by 21st September 2026, ensure they obtain the new NISM Series-V-D certification before that date.
☑ For distributors already holding valid NISM Series XIII (obtained by 21 Sept 2026), confirm they continue to hold valid NISM Series V-A during the transition period.
☑ Track the expiry date of each distributor's existing NISM Series XIII certification, since NISM Series-V-D becomes mandatory for them only upon that expiry.
☑ Update internal distributor onboarding checklists to reference NISM Series-V-D as the combined MF+SIF certification going forward.
☑ AMCs and AMFI should communicate the revised paragraph 21.10 requirements clearly to all distribution networks and RTAs.
☑ Confirm no other provisions of the MF Master Circular dated 20th March 2026 are mistakenly treated as amended, since paragraph 4 confirms all else remains unchanged.
CorpLawUpdates Analysis
This circular addresses a practical friction point that SIF distributors have likely flagged since the SIF framework's rollout: requiring both a derivatives-focused certification (NISM XIII) and a mutual fund distribution certification (NISM V-A) created a two-exam burden for a product category that, in substance, sits closer to mutual fund distribution than to derivatives trading. Consolidating this into a single, purpose-built NISM Series-V-D certification is a sensible simplification, and the explicit NISM consultation referenced in paragraph 3 suggests the new certification's content has been designed specifically around SIF distribution competencies rather than repurposed derivatives material.
The transition mechanics in paragraph 21.10.4 are carefully calibrated to avoid disrupting existing distributors mid-certification-cycle. By tying the NISM Series-V-D requirement to the expiry of an existing NISM Series XIII certification — rather than an immediate hard cutover — SEBI avoids forcing currently compliant distributors to requalify before their existing certification would naturally lapse. The requirement to keep NISM V-A valid throughout the transition period ensures no compliance gap opens up for MF distribution capability during the interim.
For AMCs and AMFI, the practical challenge will be operational: tracking two overlapping certification populations — those transitioning via the grandfathering route and those obtaining NISM V-D fresh — over the roughly two-month window before 21st September 2026. Distribution compliance teams should build a simple tracker now rather than reacting close to the deadline, given the certification's direct bearing on which staff can legally engage in SIF sales.
Practitioners should also watch for whether NISM issues a syllabus or transition FAQ for NISM Series-V-D specifically, since the circular itself does not detail the certification's content or examination structure — only its regulatory consequence.
This article is for informational and educational purposes only and does not constitute legal or regulatory advice. Verify with primary regulatory sources before acting.
