The Securities and Exchange Board of India (SEBI) on 5 November 2026 eased the framework for SEBI accredited investors, letting Alternative Investment Fund (AIF) managers, Specialised Investment Fund (SIF) asset management companies and portfolio managers verify and certify an investor’s accredited status. The optional manager-led route sits alongside recognition by accreditation agencies and takes effect immediately under SEBI circular HO/19/34/11(6)2026-AFD-POD1/I/25244/2026.
The circular implements AIF Regulation amendments notified on 15 October 2026. It is distinct from SEBI’s same-week digital KYC easing for NRIs and OCIs, which covers identity checks rather than accreditation for AIF, SIF and portfolio products.
How manager-led accreditation works
A “Manager” means an AIF manager, the AMC of a SIF under the Mutual Funds Regulations, 2026, or a portfolio manager under the Portfolio Managers Regulations, 2026. That Manager may determine and record accredited status at onboarding or during a scheme’s tenure after verifying eligibility.
- Accreditation lasts three years from the determination date and is recognised across Managers in the same corporate group for AIFs, SIFs and portfolio management services.
- Investment Advisers and Research Analysts cannot certify status themselves, but may rely on a valid determination by a Manager in their group.
- The agency route remains open: a valid Accreditation Agency certificate must be relied upon, with no fresh determination during its validity.
- The Manager must confirm status in writing, with the accreditation date and validity period.
Eligibility thresholds and five-year records
Eligibility still rests on income, net worth or securities market exposure under Regulation 2(1)(ab). Qualifying exposure is ₹5 crore for an individual, HUF, family trust or sole proprietorship, and ₹20 crore for a body corporate or other trust. Counted exposures include demat securities (via eCAS), mutual fund folios, unlisted demat holdings, overseas market investments and National Pension System units.
Managers must keep supporting documents and verification evidence for at least five years from accreditation, or until five years after the investor exits every scheme they manage, whichever is later. Internal audit must cover the process, and Managers need an accreditation policy with conflict-of-interest controls that separate accreditation from distribution, plus grievance redressal and data-privacy safeguards—consistent with other SEBI compliance easing such as the MF Lite framework for passive schemes.
LLPs and persons resident outside India
A Limited Liability Partnership qualifies only if each partner independently meets the criteria applicable to that partner. Persons Resident Outside India under FEMA are deemed accredited investors and need no separate certificate or manager-led accreditation, though the Manager must record the residency basis. Deemed status does not dilute Prevention of Money-laundering Act duties on client due diligence, beneficial ownership or source of funds.
Why it matters for AIFs, SIFs and PMS
Accreditation has slowed onboarding into India’s alternative and discretionary wealth pipelines for UHNI and family-office capital, a theme visible in InCred Black’s UHNI wealth segment and broader wealth management industry shifts. Group-portable, Manager-led certification should shorten that path for AIF, SIF and PMS desks while keeping accountability and AML duties with the Manager.
Key takeaways
- AIF managers, SIF AMCs and portfolio managers may optionally verify and certify accredited investor status; agency certificates remain valid.
- Accreditation lasts three years and is portable across Managers in the same corporate group; records must be kept for at least five years.
- LLPs qualify partner-by-partner; persons resident outside India are deemed accredited without a separate certificate, without diluting AML/CDD duties.
Frequently asked questions
When does SEBI’s accredited investor circular take effect?
It came into force with immediate effect on 5 November 2026 under circular HO/19/34/11(6)2026-AFD-POD1/I/25244/2026.
Can an Investment Adviser certify accredited investor status?
No. Investment Advisers and Research Analysts cannot determine status independently, but may rely on a valid determination by a Manager in their group.
Do overseas residents still need an accreditation certificate?
Persons Resident Outside India under FEMA are deemed accredited investors and need not obtain a separate certificate, but Managers must still meet AML and client due diligence obligations.
Featured image: SEBI Bhavan, Mumbai. Photo: Jimmy vikas via Wikimedia Commons (CC BY-SA 3.0)
