SEBI Circular - Key Details
Circular Title: Compliance Reporting Formats for Specialized Investment Funds (SIFs)
Circular No.: HO/24/13/12(4)2025-IMD-POD-1/I/2062/2026
Date: January 08, 2026
Issued By: SEBI - Investment Management Department (IMD)
Category: Compliance / Certification / AIF Governance / Investor Protection
Applicable To: All Mutual Funds, All Asset Management Companies (AMCs), All Registrar and Share Transfer Agents (RTAs), All Trustee Companies/ Board of Trustees of Mutual Funds, Association of Mutual Funds in India (AMFI)
How should AMCs and Trustees report SIF compliance in a uniform way under SEBI’s mutual fund compliance framework?
SEBI has mandated that Specialized Investment Fund (SIF) compliance must be reported within the existing Mutual Fund (MF) compliance reporting framework, instead of creating any separate or parallel reporting mechanism. To achieve uniformity, comparability, and governance discipline, SEBI has modified the formats of two existing MF reports:
- Compliance Test Report (CTR) submitted by AMCs
- Half-Yearly Trustee Report (HYTR) submitted by Trustees
Under this framework:
- Asset Management Companies (AMCs) managing SIFs must report SIF-specific compliance checks as an additional section (Part IV) within the CTR already filed for Mutual Funds.
- Trustees / Trustee Companies must report SIF-related oversight and confirmations by adding a new clause (Clause 72A) within the HYTR already filed for Mutual Funds.
This approach ensures that:
- SIFs are governed with the same rigor as Mutual Funds,
- Trustees are explicitly accountable for SIF oversight, and
- SEBI receives standardized, auditable, and comparable compliance data across the industry.
In essence, SIF compliance is embedded into MF compliance, not reported separately.
HINDI: सेबी ने यह स्पष्ट किया है कि Specialized Investment Fund (SIF) की अनुपालन रिपोर्टिंग के लिए कोई अलग या समानांतर रिपोर्टिंग प्रणाली नहीं बनाई जाएगी। SIF की अनुपालन रिपोर्टिंग मौजूदा Mutual Fund (MF) अनुपालन ढांचे के अंतर्गत ही की जाएगी। इस एकरूपता और गवर्नेंस की स्पष्टता सुनिश्चित करने के लिए सेबी ने दो मौजूदा MF रिपोर्टों - CTR और HYTR - के प्रारूपों में परिवर्तन किए हैं, ताकि SIF अनुपालन इन्हीं रिपोर्टों का हिस्सा बन सके।
Hinglish: SEBI ka approach yeh hai ki SIF compliance ko MF compliance ke saath hi integrate kiya jaaye, alag report banane ki zarurat nahi hai. Isliye SEBI ne CTR aur HYTR ke formats modify kiye hain, jisme SIF ke liye extra sections add kiye gaye hain. Matlab SIF compliance MF reporting ke andar hi embed hoti hai, alag se nahi bheji jaati.
What changes happen to the CTR (Compliance Test Report) format for SIF?
SEBI has modified the existing CTR format prescribed under Format No. 2.B of the MF Master Circular (June 27, 2024) by introducing an additional section called “Part IV”, which is exclusively dedicated to SIF-specific compliance checks.
Key aspects of this change:
- Part IV (Annexure A1) is added to the CTR format.
- This new part contains a detailed, regulation-mapped checklist covering all major SIF compliance requirements.
- The checklist includes compliance relating to:
- Minimum investment threshold
- Fund manager certification (NISM, when notified)
- Strategy characteristics
- Fees and expenses
- Investment restrictions (issuer limits, derivatives, INVITs/REITs)
- Product differentiation
- Branding and advertising
- Offer document disclosures
- Portfolio disclosures and scenario analysis
- Subscription, redemption, listing, benchmarking, distribution, and risk band
Importantly:
- AMCs are not required to file a separate CTR for SIFs.
- Instead, Part IV must be filled and submitted as part of the same CTR that is already submitted for Mutual Funds.
This ensures that SIF compliance becomes an auditable extension of MF compliance, rather than a standalone or fragmented report.
HINDI: सेबी ने MF मास्टर सर्कुलर के CTR प्रारूप (Format 2.B) में एक नया Part IV जोड़ा है, जो केवल SIF-विशिष्ट अनुपालन जाँच के लिए है। इस भाग में न्यूनतम निवेश सीमा, शुल्क एवं व्यय, निवेश प्रतिबंध, प्रकटीकरण, जोखिम बैंड जैसे सभी महत्वपूर्ण SIF आवश्यकताओं की एक चेकलिस्ट दी गई है। AMC को SIF के लिए अलग से CTR दाखिल नहीं करना है, बल्कि MF CTR के भीतर ही Part IV भरकर जमा करना होगा।
Hinglish: CTR ke format mein Part IV add hua hai, jo poora SIF compliance checklist cover karta hai. AMC ko separate SIF CTR nahi banana, bas jo MF CTR already submit hota hai usme Part IV add karke SIF compliance report karni hai. Isse SIF compliance MF compliance ka extension ban jaata hai.
What changes happen to the HYTR (Half-Yearly Trustee Report) format for SIF?
SEBI has modified the existing HYTR format prescribed under Format No. 2.C of the MF Master Circular by introducing a new clause called “Clause 72A”, which specifically addresses Trustee oversight of SIFs.
Key aspects of this change:
- Clause 72A (Annexure A2) is added to the HYTR format.
-
Through this clause, Trustees must explicitly confirm and report whether:
- The AMC has adequate expertise, internal controls, and risk management systems to manage SIFs
- Minimum investment thresholds are complied with
- Fees and expenses comply with regulatory limits
- SIF strategies adhere to prescribed characteristics
- Investment restrictions are followed
- Product differentiation requirements are met
- Disclosure obligations are complied with
- Branding and advertising rules are adhered to
- Other risk management, investor protection, and reporting obligations are fulfilled
Crucially:
- Trustees must include Clause 72A within the same HYTR that is submitted for Mutual Funds.
- There is no separate SIF trustee report.
This change strengthens Trustee accountability by requiring affirmative confirmation, not just general oversight, for SIF operations.
From when are these reporting changes applicable?
The reporting changes introduced by this circular are applicable with immediate effect, i.e., from the date of the circular itself - 08 January 2026.
Key points to note:
- SEBI has not provided any transition period or deferment.
- All AMCs and Trustees managing SIFs are expected to implement the revised CTR and HYTR formats from this date onward.
-
Any CTR or HYTR filed after this date must include:
- Part IV (SIF compliance) in CTR, and
- Clause 72A (SIF trustee confirmations) in HYTR.
This underscores SEBI’s expectation of immediate governance alignment and reporting readiness for SIFs.
🧠 Exam Memory Hook: SIF ka compliance alag file nahi, MF CTR aur MF HYTR ke andar ek extra layer hai - effective 08 Jan 2026.
SIF compliance is not a new report - it is a new layer inside MF CTR (Part IV) and MF HYTR (Clause 72A), effective immediately from 08 Jan 2026.”
📥 FREE RESOURCE: Download the 1-Page RegDEEP™ Exam Micro-Summary & Industry Impact Note PDF] (Zero Cost - Instant Access)
RegDEEP™ Decoding SEBI Circular Dec 2025: Compact 2-in-1 RegDEEP™ guide Exam decoding + Industry notes for the latest SEBI update. Designed to help learners & industry professionals quickly understand what changed, who must report what, and how SIF compliance fits into the existing Mutual Fund framework.
1. Snapshot Summary
- 🟢 SEBI has already introduced the SIF framework via Feb 27, 2025 circular(s); now it is standardizing how compliance will be reported. (Page 1)
- 🟢 SIFs must follow all reporting requirements applicable to mutual funds, including the MF Master Circular (June 27, 2024) and other related circulars. (Clause 2.1, Page 1)
- 🟢 The CTR format (Format 2.B of MF Master Circular) is modified by adding Part IV (SIF-specific checks). (Clause 2.2, Page 1 + Annexure A1)
- 🟢 AMCs managing SIF must include SIF compliance reporting inside the same CTR submitted for Mutual Funds. (Clause 2.2.2, Page 2)
- 🟢 The HYTR format (Format 2.C of MF Master Circular) is modified by adding Clause 72A (SIF-specific trustee confirmations). (Clause 2.3, Page 2 + Annexure A2)
- 🟢 Effective immediately from the date of circular (Jan 08, 2026). (Clause 3, Page 1)
2. Background & Context
- SEBI launched the regulatory framework for SIF in Feb 27, 2025 and subsequent circulars. (Clause 1, Page 1)
- Once a new product framework is introduced, the next big compliance problem is usually inconsistent reporting (different AMCs interpret/submit differently). This circular fixes that by standardizing formats for AMC + Trustees. (Clause 2, Page 1 - 2)
- Legal basis: issued under Section 11(1) of SEBI Act, 1992 read with Chapter VI-C of SEBI (Mutual Funds) Regulations, 1996 for investor protection and market development/regulation. (Clause 4, Page 1)
3. Clause-by-Clause Decoding
Clause 1 - What exists already
What SEBI said: SIF framework already specified via Feb 27, 2025 circular and subsequent circulars. (Page 1)
What it means in practice: Don’t treat this as “new SIF rules.” This is about reporting format alignment.
Exam angle: Identify whether circular is substantive regulation vs operational reporting → here it’s reporting standardization.
Clause 2.1 - “Everything MF reporting applies to SIF too”
What SEBI said: Under Reg 49V(2), all reporting requirements applicable to mutual funds (MF Regulations 1996 + MF Master Circular June 27, 2024 + other circulars) shall also apply to SIF. (Page 1)
What it means in practice: If a reporting obligation exists for mutual funds, the AMC/Trustee should assume it applies to SIF unless specifically excluded.
Exam angle: Candidates may think “SIF = separate bucket.” SEBI is saying “SIF reporting sits inside MF reporting universe.”
Clause 2.2 - CTR changes (Format 2.B updated)
What SEBI said: CTR format is modified to include an additional Part IV (Annexure A1). (Page 1)
What it means in practice: AMC compliance team must add SIF-specific tests into CTR.
Ref: Annexure A1
Clause 2.2.2 - Who reports it
What SEBI said: AMCs managing SIF shall report Part IV as part of CTR submitted for Mutual Funds. (Page 2)
What it means in practice: No separate CTR filing silo. It’s an integrated reporting add-on.
Clause 2.3 - HYTR changes (Format 2.C updated)
What SEBI said: HYTR format modified to include Clause 72A (Annexure A2). (Page 2)
Ref: Annexure A2 - Clause 72A (Trustee-level confirmations)
Exam angle: Trustee oversight is not “generic”; SEBI requires trustees to explicitly confirm SIF readiness and ongoing compliance.
Clause 2.3.2 - Who reports it
What SEBI said: Trustees/Trustee Companies managing SIF shall report Clause 72A as part of HYTR submitted for Mutual Funds. (Page 2)
Practical interpretation: Trustees must embed SIF oversight inside standard MF trustee reporting..
Clause 3 - Effective date
What SEBI said: Effective from the date of circular. (Page 1)
Practical interpretation: No grace period mentioned → implement immediately
4. Exam Relevance Mapping
Most relevant exams / modules:
- NISM-Series V-A (Mutual Fund Distributors) - Likely focus: product differentiation, disclosures, risk band, distribution rules (because these affect what distributors can communicate/sell).
Question pattern: factual (what report, what clause added), plus scenario (who reports what). - NISM-Series X-A / X-B (Investment Adviser) :Angle - governance + disclosures + investor protection lens; how specialized products require tighter reporting.
- Compliance InterviewIntentSignal (AMC/Trustee/RTA) :“Explain what changed in CTR and HYTR for SIF and who is responsible.”
5. Industry Impact & Real-World Application
Who must comply:
- AMCs managing SIF → add Part IV tests in CTR (Page 2 - 5).
- Trustees/Trustee Companies → add Clause 72A confirmations in HYTR (Page 2, 6).
- RTAs indirectly impacted through data/records needed for disclosures, reporting, subscription/redemption tracking.
Operational changes:
- Compliance teams must update CTR templates, internal checklists, evidence repositories.
- Trustees need enhanced review packs: expertise/control readiness, risk band, scenario analysis, advertising compliance.
HCAM Signal: SEBI wants SIF treated with MF-like discipline + extra SIF-specific guardrails.
Table 1: SIF Compliance Checklist Table (CTR Part IV) - Area, What to Verify, Evidence to Keep
This is a structured compliance checklist table for Specialized Investment Funds (SIFs) aligned to CTR Part IV reporting under SEBI’s Mutual Fund compliance framework. The table maps each compliance area to what must be verified and the evidence that should be retained for audit and reporting readiness. This dataset is indicative and intended for academic and examination-preparation use under the RegDEEP™ methodology; always refer to the official SEBI circular for authoritative requirements.
Disclaimer: This table is Indicative, illustrative, and intended solely for academic and examination-preparation purposes under the RegDEEP™ methodology. This is not an official SEBI communication or compliance advice. For authoritative requirements, applicability, and compliance obligations, always refer to the original and latest SEBI circulars, regulations, and communications.
Table 2: Trustee Confirmation Checklist Table (HYTR Clause 72A) - Trustee Must Confirm, Evidence Expected
This is a structured trustee oversight checklist table for Specialized Investment Funds (SIFs) aligned to HYTR Clause 72A reporting under SEBI’s Mutual Fund compliance framework. The table maps each trustee confirmation requirement to the evidence expected for audit readiness, governance documentation, and reporting support. This dataset is indicative and intended for academic and examination-preparation use under the RegDEEP™ methodology; always refer to the official SEBI circular for authoritative requirements.
Disclaimer: This table is Indicative, illustrative, and intended solely for academic and examination-preparation purposes under the RegDEEP™ methodology. This is not an official SEBI communication or compliance advice. For authoritative requirements, applicability, and compliance obligations, always refer to the original and latest SEBI circulars, regulations, and communications.
6. Why This Matters for Learners
- This circular is a classic “format + governance” circular: very exam-friendly because questions are often direct and list-based.
- Helps you learn the compliance architecture: MF Master Circular → CTR/HYTR formats → product-specific add-ons.
- Interview advantage: you can explain “SIF compliance is not separate; it is appended into MF CTR/HYTR.”
HCAM Memory anchor SIF ka compliance alag file nahi - MF CTR/HYTR ke andar extra Part/Clause.
7. Key Takeaways
- Reg 49V(2): MF reporting requirements apply to SIF also.
- CTR (Format 2.B) gets Part IV for SIF compliance (Annexure A1).
- HYTR (Format 2.C) gets Clause 72A for SIF trustee reporting (Annexure A2).
- AMC reports Part IV inside MF CTR; Trustees report 72A inside MF HYTR.
- Effective immediately: Jan 08, 2026.
8. Updates, Amendments & Implementation Timeline
- Nature: Reporting format modification (CTR + HYTR) for SIF. (Page 1 - 2)
- Effective date: From date of circular (Jan 08, 2026).
- Special note: For quarter ending Dec 2025, provide compliance regarding restrictions on investments in REITs (noted in Annexure A1 notes).
- Conditional note: NISM certification compliance item applies when SEBI specifies the certification requirement.
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9. FAQ (Learner Clarification Layer)
Q1. What is the Compliance Reporting Formats for Specialized Investment Funds (SIFs) Micro Summary PDF, is it free, and how is this 1-minute read different?
The SIF Compliance Reporting Formats Micro Summary PDF is a concise, focused explanatory document created under the RegDEEP™ methodology to help learners and industry professionals quickly understand the essence of SEBI’s circular on SIF compliance reporting. It is free to download, designed as a two-page one-minute read, and presents information through structured summary tables and checklists. The PDF explains what changed under the circular, who must report what across AMCs, Trustees, RTAs, and compliance teams, where SIF compliance fits within CTR Part IV and HYTR Clause 72A, and includes key exam memory hooks. Unlike the full article on this page, which provides detailed clause-by-clause regulatory explanation, the Micro Summary PDF distills the information into high-signal, table-based highlights suitable for quick revision, industry briefings, onboarding discussions, and executive snapshots. The PDF is purely educational in nature and does not constitute compliance implementation advice.
Q2. Why did SEBI introduce changes in compliance reporting for SIFs?
SEBI introduced these changes to ensure that Specialized Investment Funds are governed with the same level of discipline, transparency, and trustee oversight as Mutual Funds, without creating a parallel or fragmented compliance system. By embedding SIF compliance within existing Mutual Fund reporting formats, SEBI ensures uniform governance standards, clearer accountability for AMCs and Trustees, and standardized, auditable compliance data for supervisory review.
Q3. Does this circular create any new standalone compliance reports for SIFs?
No, the circular does not introduce any separate or standalone compliance reports for Specialized Investment Funds. SIF compliance is integrated into existing Mutual Fund Compliance Test Report and Half-Yearly Trustee Report formats, and reporting continues through the same filings with the addition of SIF-specific sections. This approach avoids duplication and keeps SIFs within the mainstream Mutual Fund governance framework.
Q4. What exactly is required to be reported in the CTR for SIFs?
SEBI has introduced Part IV in the Compliance Test Report for Specialized Investment Funds. Through Part IV, Asset Management Companies must report SIF-specific compliance checks covering areas such as minimum investment thresholds, strategy characteristics and differentiation, fees and expenses, issuer concentration limits, derivatives usage, disclosure requirements, risk band classification, and scenario analysis. Part IV is submitted as part of the same CTR filed for Mutual Funds and is not a separate report.
Q5. What additional responsibility is placed on Trustees under the revised HYTR format?
SEBI has introduced Clause 72A in the Half-Yearly Trustee Report, under which Trustees must explicitly confirm that the Asset Management Company has adequate expertise, systems, and internal controls for managing SIFs, that regulatory limits and investment restrictions are complied with, that product differentiation from Mutual Fund and AIF structures is maintained, and that disclosure, branding, risk management, and investor protection obligations are fulfilled. This strengthens trustee accountability by requiring affirmative confirmations rather than general oversight statements.
Q6. Are Trustees required to submit a separate HYTR for SIFs?
No, Trustees are not required to submit a separate Half-Yearly Trustee Report for Specialized Investment Funds. Trustees must continue filing the same HYTR prescribed for Mutual Funds and include Clause 72A within that report to cover SIF-related oversight and confirmations.
Q7. From when are these reporting requirements applicable, and what is the practical impact on industry participants?
The revised reporting requirements are applicable with immediate effect from 08 January 2026, the date of issuance of the circular. SEBI has not provided any transition period or deferred implementation timeline. As a result, Asset Management Companies must immediately incorporate CTR Part IV for SIF compliance, Trustees must include Clause 72A confirmations in the HYTR, RTAs and operations teams must support data, disclosures, and reporting evidence, and compliance teams must align internal SOPs and reporting templates. The impact is primarily enhanced governance and reporting discipline rather than an increase in the number of filings.
Q8. How is this circular likely to be tested in NISM or other regulatory and professional exams?
This circular is likely to be tested through direct factual questions such as where SIF compliance is reported, conceptual questions examining the rationale for embedding SIFs within the Mutual Fund governance framework, and scenario-based questions involving AMC or Trustee reporting obligations after 08 January 2026. A common exam pitfall is assuming that Specialized Investment Funds require separate compliance reports, which is incorrect under this circular.
9. Micro Glossary - Key Terms from SEBI Compliance Reporting Formats for Specialized Investment Funds (SIFs) Circular
Specialized Investment Fund (SIF)
English: A Specialized Investment Fund (SIF) is a category of mutual fund product introduced by SEBI with differentiated investment strategies, higher minimum investment thresholds, and enhanced governance and compliance requirements compared to traditional mutual fund schemes.
Hindi: Specialized Investment Fund (SIF) SEBI द्वारा शुरू किया गया एक विशेष म्यूचुअल फंड उत्पाद है, जिसमें अलग-अलग निवेश रणनीतियाँ, उच्च न्यूनतम निवेश सीमा और पारंपरिक म्यूचुअल फंड की तुलना में अधिक कड़े गवर्नेंस और अनुपालन नियम होते हैं।
Hinglish: SIF ek special type ka mutual fund product hai jo SEBI ne introduce kiya hai, jisme unique strategies hoti hain, minimum investment zyada hota hai, aur governance aur compliance rules normal mutual funds se zyada strict hote hain.
Compliance Test Report (CTR)- Part IV
English: CTR Part IV is the additional section introduced by SEBI in the existing Mutual Fund Compliance Test Report to capture Specialized Investment Fund - specific compliance checks and confirmations by Asset Management Companies.
Hindi: CTR Part IV, Mutual Fund Compliance Test Report में जोड़ा गया एक अतिरिक्त भाग है, जिसके माध्यम से Asset Management Companies को Specialized Investment Fund से संबंधित विशेष अनुपालन जांच और पुष्टि रिपोर्ट करनी होती है।
Hinglish: CTR Part IV CTR ka naya section hai jisme AMC ko SIF-specific compliance checks report karni hoti hain, aur yeh wahi MF CTR ka part hota hai, koi alag report nahi hoti.
Half-Yearly Trustee Report (HYTR)- Clause 72A
English: Clause 72A is a newly inserted clause in the Half-Yearly Trustee Report requiring Trustees to provide explicit confirmations on governance, compliance, risk management, disclosures, and investor protection relating to Specialized Investment Funds.
Hindi: Clause 72A, Half-Yearly Trustee Report में जोड़ा गया एक नया प्रावधान है, जिसके तहत Trustees को Specialized Investment Funds के गवर्नेंस, अनुपालन, जोखिम प्रबंधन, प्रकटीकरण और निवेशक संरक्षण से संबंधित स्पष्ट पुष्टि देनी होती है।
Hinglish: HYTR ka Clause 72A ek naya clause hai jisme Trustees ko SIF ke governance, compliance, risk management, disclosures aur investor protection par clear confirmation deni hoti hai.
Embedded Compliance Reporting
English: Embedded compliance reporting refers to SEBI’s approach of integrating Specialized Investment Fund compliance within existing Mutual Fund reporting formats, instead of introducing separate or standalone compliance reports.
Hindi: Embedded compliance reporting का अर्थ है कि SEBI ने Specialized Investment Fund के अनुपालन को मौजूदा Mutual Fund रिपोर्टिंग ढांचे में ही शामिल किया है, न कि कोई अलग रिपोर्टिंग प्रणाली बनाई है।
Hinglish: Embedded compliance reporting ka matlab hai ki SIF compliance ko existing MF CTR aur HYTR ke andar hi include kiya gaya hai, alag se koi new report banana required nahi hai.
Uniform Compliance Reporting Framework for SIFs
English: The Uniform Compliance Reporting Framework for SIFs refers to SEBI’s regulatory approach of ensuring that Specialized Investment Funds are governed, monitored, and reported through the same Compliance Test Report and Trustee reporting mechanisms applicable to Mutual Funds, with SIF-specific additions.
Hindi: Uniform Compliance Reporting Framework for SIFs का अर्थ है SEBI की वह नियामकीय व्यवस्था, जिसके तहत Specialized Investment Funds का अनुपालन, निगरानी और रिपोर्टिंग Mutual Funds के समान रिपोर्टिंग ढांचे के माध्यम से की जाती है, जिसमें SIF-विशिष्ट अतिरिक्त प्रावधान जोड़े गए हैं।
Hinglish: Uniform Compliance Reporting Framework for SIFs ka matlab hai ki SEBI ne SIFs ke liye bhi wahi MF CTR aur HYTR reporting system use karne ko kaha hai, bas usme SIF-specific checks add kiye gaye hain.
10. Official Resources & References
- SEBI Circular (Jan 08, 2026): Compliance Reporting Formats for Specialized Investment Funds (SIFs)
Gurukul Resources & Exam Support
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- NISM-Series-III-C: Securities Intermediaries Compliance (Fund) NISM Series 3C Online Mock Test 2026 | 2000+ MCQs
- All RegDEEP™ Regulatory Circulars Decoded (Global + India): 2025 - 26 Exam Guide for NISM, CAIIB, JAIIB, III, FINRA, CII, CISI, IRDAI | Notes for BFSI, BPO, KPO & GCC
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