Until March 2026, the manager of an Alternative Investment Fund (AIF) used to file a detailed quarterly report with the Securities and Exchange Board of India (SEBI) and moved on. A Circular of March 2026 changed that. AIFs are now required to submit a comprehensive Annual Activity Report and limited Quarterly Activity Report, with different reporting timelines. The change reflects a revised approach to regulatory reporting.   

However, it does not reduce manager’s responsibility. Once the scheme starts operating, the manager has to keep track of investor reports, portfolio valuation, audit and regulatory filings. All these do not fall due on the same date. Some follow financial year, others are linked to quarterly-end, and a few arise when specific changes take place. An AIF compliance calendar brings these obligations together in one place, with deadline and person responsible for each task.  

The framework is governed by the SEBI (Alternative Investment Funds) Regulations, 2012, along with subsequent circulars and regulatory instructions. SEBI introduced a new AIF Master Circular on 3 June 2026 that was later updated on 16 June 2026. These changes make it important to check existing compliance schedules against current requirements. 

Why AIF Compliance Continues After SEBI Registration 

Registration allows an AIF to operate within its approved category, subject to applicable conditions. The SEBI (Alternative Investment Fund) Regulations, 2012 sets the base framework. Registration fixes the fund’s category. Each category carries its own conditions.  

Manager is responsible to follow the fund’s investment strategy, maintain records, provide information to invest and meet continuing regulatory requirements. They also need to distinguish between obligations created by the regulations and the procedures set out in the SEBI circulars. Each year manager prepares a Compliance Test Report (CTR), a self-assessment covering every chapter of the Master Circular, which goes to the trustee or sponsor for review. 

AIF Compliance Calendar: Key SEBI Obligations and Deadlines 

The recurring requirements can be organised around the financial year, quarter-end and the fund’s valuation cycle. The table below summarises important deadlines.  

Compliance requirement	Frequency or trigger	Deadline	Applicability
Annual Activity Report	Once every financial year	Within 30 calendar days from the end of March	All AIFs
Limited Quarterly Activity Report	Quarterly, beginning with the quarter ending June 2026	Within 15 calendar days after quarter-end; no separate report for the March quarter	All AIFs
Compliance Test Report (CTR)	Annually	Within 30 days after the financial year-end	AIFs, subject to applicable provisions
PPM compliance audit	Annual, where required	Within six months after the financial year-end	Subject to specified exemptions
Investor reporting	Annual for Categories I and II; quarterly for Category III	Within 180 days after year-end for Categories I and II; within 60 days after quarter-end for Category III	Category-specific
Investment valuation	Periodic	At least every six months for Categories I and II, subject to the permitted extension	Categories I and II
NAV disclosure to investors	According to scheme type	At least quarterly for close-ended Category III schemes and monthly for open-ended Category III schemes	Category III
NAV upload to depositories	Following valuation	Within 30 days of the valuation date for ongoing uploads, subject to the applicable directions	Through the fund’s registrar and transfer agent

Two requirements deserve particular attention when preparing the annual schedule: 

1. PPM compliance audit – It is not a universal requirement without exceptions. Certain AIFs qualify for exemptions under specified conditions. An AIF that has not raised funds must submit a Chartered Accountant’s certificate confirming this within six months after the financial year-end, as applicable under SEBI’s directions, rather than conduct the PPM audit. Eligibility for any other exemption should be checked before the audit is removed from the schedule. 

2. Audit of the fund’s books of account – This is separate from the PPM compliance audit. Completing one should not be treated as evidence that the other requirement has also been met. 

How Compliance Requirements Differ Across AIF Categories 

The fund type plays a huge role when it comes to compliance requirements. Applying the same reporting and valuation schedule to all the categories can leave important obligations uncovered.  

Category I and Category II AIFs 

These categories include funds investing in areas such as startups, infrastructure, private equity and debt. These kinds of investments must be valued by an independent valuer atleast once every six months. The period of valuation can be extended to one year with approval from investor representing at least 75% of the value of their investments in the AIF.  

Manager should also monitor the investment conditions applicable to the fund. The framework between the categories differs. Therefore, ongoing attention with regards to compliance requirements is crucial. 

Category III AIFs 

This category uses more complex trading strategies and leverages, where permitted. Their net asset value (NAV) must be calculated independently of the fund management function.  

NAV must be disclosed to the investors at intervals not exceeding one quarter for close-ended scheme and one month for open-ended schemes. Where leverage is used, the applicable limits and reporting requirements are also monitored. These checks sit alongside routine investor reporting and should have their own control.  

Event-Based Compliance Obligations That Require Separate Tracking 

Some duties carry no calendar dates. The clock starts when something happens and must be counted from that event. Some changes include: 

• Change of manager, sponsor or control: Prior SEBI approval is required under Regulation 20 (13), and a fee equal to the registration fee is payable within 15 days of the change taking place. Dissenting investors get an exit option, with one month to object unless 75% of unit holders by value approve.  
• Overseas investment: Utilisation of an allocated limits is reported within five working days, and a divestment within three. 
• Conversation to an accredited-investor-only scheme: Reported to SEBI and depositories within 15 days. 
• First close: Within 12 months of the scheme becoming eligible to launch, or a fresh application is needed.  

Note: From January 2027, only a person holding NISM Series-III C certification can act as a manager’s compliance officer. 

How to Maintain an Effective AIF Compliance Calendar 

A useful compliance calendar consists of more than just the filing dates. Each entry should identify the source provisions, applicability, triggering event, deadline, responsible person, reviewer and supporting documents. A well-maintained compliance system should include: 

• Assigning Ownership: Allocate each obligation to a responsible person across compliance, finance, legal and fund operations. 
• Maintaining evidence: Retain submitted reports, acknowledgements, valuation records, audit findings and investor communications.  
• Monitoring regulatory changes: Review new SEBI circulars and amendments, then update the relevant deadlines, templates and internal procedures. 
• Tracking other Legal Requirements: Tax, TDS and foreign exchange reporting apply depending on the fund’s structure and transactions. These obligations follow their respective framework and should not be assumed to share SEBI deadlines.  

SEBI’s Master Circular also requires Compliance Test Report (CTR) to cover the applicable provisions across its chapter. This makes CTR an important part of the annual compliance review.   

Common AIF Compliance Mistakes to Avoid 

Here are a few avoidable errors that should be taken care of when looking into AIF compliance: 

• Keeping an old calendar: A calendar built on the 2024 Master Circular no longer applies. It is advised to check the updated deadlines. 
• Treating all AIF Categories Same: Treating one category as the template for all can lead to missed valuation, investor reporting or leverage related requirements. 
• Recording only Fixed Deadlines: Changes to management, control or fund documents can create obligation before the next scheduled review.  
• Updating dates but not procedures: A new circular may require different information, approval steps or reporting format. It is important to keep in check any changes in the procedural along with the revised deadlines. 

A task should be marked complete only when the required action has been taken and the supporting evidence is available. 

Conclusion 

An AIF compliance calendar helps mangers to track the continuing obligations that follow SEBI registration and audit and event-based notifications. However, its effectiveness depends on whether it reflects the fund category, scheme documents, investment activities and other specific requirements aptly or not.  

The calendar needs to be reviewed whenever SEBI changes the applicable framework. It must be supported by clear ownership, reliable records and regular internal checks.  

For a broader understanding of the regulatory framework and the responsibilities of Alternative Investment funds, Explore our AIF Whitepaper.  

Frequently Asked Questions

What is an AIF compliance calendar?

It is a schedule of an AIF’s recurring and event-based regulatory obligations, showing the applicable deadline, source provision and person responsible for each task.

Which SEBI obligations continue after AIF registration?

Depending on the fund’s category and circumstances, these include activity reports, the Compliance Test Report, PPM compliance audit, investor disclosures, valuation requirements and compliance with applicable investment conditions.

Do compliance requirements differ across AIF categories?

Yes. Categories I and II generally follow different valuation and investor reporting arrangements from Category III. Category III funds also have specific NAV disclosure requirements and additional obligations where leverage is used.

Does an AIF that has not raised funds need a PPM compliance audit?

An AIF that has not raised funds is subject to the applicable exemption from the PPM compliance audit and must submit the prescribed Chartered Accountant’s certificate within six months after the financial year-end. The separate requirement to audit the books of account should also be considered.

How should an AIF update its compliance calendar when SEBI changes the rules?

The compliance team should identify the affected obligations, revise deadlines and internal procedures, assign responsibility for the changes, and retain the relevant regulatory source and implementation record.