GIFT City Updates (November 2025)

CIRCULARS

• Clarification on INR Invoice

On November 28, 2025, the International Financial Services Centres Authority (IFSCA) issued a circular providing formal clarification on the permissibility and operational treatment of Indian Rupee (INR) denominated invoices within GIFT IFSC. This clarification was issued in response to queries from industry participants regarding the invoicing framework applicable to entities undertaking financial transactions, services, and cross-border activities within the IFSC. The circular reiterates that entities operating in IFSC must adhere to the currency usage provisions under the IFSCA Act, 2019 and other applicable regulations, while also confirming the circumstances in which INR-invoicing is permitted without contravening the foreign currency orientation of the IFSC regime. The clarification seeks to ensure consistency in accounting, settlement, and reporting practices while avoiding regulatory arbitrage or misinterpretation regarding the use of INR for billing cross-border or IFSC-specific services. Click here.

• Disclosure under Clause 39 of the GAP Circular

On November 26, 2025, the International Financial Services Centres Authority issued a circular requiring entities operating under the Global Access Programme (GAP) to comply with disclosure obligations specified under Clause 39 of the GAP Circular. These disclosures primarily relate to governance, compliance status, operational conduct, and risk-related information that must be furnished to the Authority and, where applicable, to clients or participants interacting with GAP entities. The clarification is aimed at strengthening transparency within the global access framework, improving reporting consistency and ensuring that entities providing global market access align with expectations regarding market integrity, client interest protection and regulatory accountability. The circular directs all concerned entities to review their internal reporting mechanisms and ensure timely and accurate compliance with Clause 39 obligations. Click here.

• Requirement of Certification on AML/CFT for Designated Director and Principal Officer under the IFSCA (AML/CTF/KYC) Guidelines, 2022

On November 17, 2025, the International Financial Services Centres Authority released a circular mandating that all regulated entities ensure that their Designated Director (DD) and Principal Officer (PO) obtain an official certification in Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF). This requirement has been introduced under the IFSCA (AML/CTF/KYC) Guidelines, 2022, with the objective of strengthening senior-level oversight over financial crime compliance within IFSC-based firms. The certification—developed jointly by the IFSCA Academy and the National Institute of Securities Markets (NISM)—covers global AML/CTF standards, risk-based frameworks, suspicious transaction reporting obligations, and IFSC-specific compliance requirements. Regulated entities are expected to ensure that their designated compliance personnel complete the certification within the timelines prescribed and maintain ongoing upskilling in line with evolving financial crime risks. This circular signifies IFSCA’s continued emphasis on fostering high-quality governance and compliance culture across all financial sectors operating from GIFT City. Click here.

• Reporting of Transactions for India’s External Account Statistics – Additional directions to IFSC Banking Units

On November 11, 2025, IFSCA issued supplementary instructions to IFSC Banking Units (IBUs) regarding the reporting of foreign exchange and cross-border financial transactions for the purpose of India’s External Account Statistics. These directions are an extension of the existing framework requiring IBUs to provide transactional data to support compilation of the country’s Balance of Payments (BoP) and external sector statistics. The circular introduces additional data fields, enhanced reporting frequency, and revised formats to improve granularity, accuracy, and timeliness of external account submissions. IBUs are required to integrate these reporting requirements into their internal systems, ensure adequate checks for data quality, and comply with all filing deadlines. The Authority has emphasised that such reporting is central to enhancing transparency in cross-border financial flows and ensuring the seamless regulatory supervision of IFSC banking activity. Click here.

PRESS RELEASES

• Consultation Paper on the proposed IFSCA (Pension Fund) Regulations, 2025

On November 4, 2025, the International Financial Services Centres Authority (IFSCA) issued a Press Release announcing the publication of the Consultation Paper on the proposed IFSCA (Pension Fund) Regulations, 2025. These draft regulations aim to introduce a dedicated pension-fund framework in GIFT IFSC that would permit Pension Fund Managers (PFMs) and related service providers to offer voluntary pension schemes to subscribers, including Non-Resident Indians (NRIs), Persons of Indian Origin (PIOs), and other eligible individuals. The Press Release highlights that the proposed framework is enabled by recent Government of India notifications classifying pension-fund schemes as “financial products” for the purposes of the IFSCA Act, 2019, and exempting the application of Section 25 of the PFRDA Act, 2013 for IFSC entities. The draft Regulations outline eligibility norms, governance requirements, investment and risk-management standards, custody arrangements, disclosures, and the operational architecture for pension schemes. The Consultation Paper invites stakeholder comments in the prescribed format by the notified deadline. The proposal is intended to establish GIFT IFSC as a competitive global jurisdiction for long-term retirement and pension capital. Click here.

PUBLIC CONSULTATIONS

• Consultation Paper — Master Circular for Broker Dealers and Clearing Members

On November 29, 2025, the International Financial Services Centres Authority (IFSCA) released a Consultation Paper proposing the issuance of a comprehensive Master Circular for Broker Dealers and Clearing Members operating within GIFT IFSC. The proposed Master Circular seeks to consolidate multiple circulars, directions and operational guidelines previously issued by IFSCA and SEBI (as applicable to IFSC entities), into a single harmonised regulatory document. The objective is to streamline compliance requirements, eliminate overlaps, and provide a unified framework governing the activities of broker dealers and clearing members across capital-market infrastructure in the IFSC.

The Consultation Paper outlines a broad regulatory structure covering key areas including eligibility and registration requirements; fit-and-proper criteria for key management personnel; net-worth and financial adequacy norms; client on-boarding, risk profiling and KYC obligations; margining standards; risk-management systems; record-keeping requirements; segregation of client assets; restrictions on proprietary trading; and obligations relating to prevention of market abuse and conflicts of interest. Further, the draft proposes detailed reporting formats, periodic submission timelines, supervisory disclosures, governance requirements for compliance officers, incident-reporting protocols, and responsibilities of entities during system outages or disruptions.

The proposed Master Circular aims to improve regulatory clarity, promote uniform operational standards across market intermediaries, and ensure orderly functioning of the trading and clearing ecosystem within GIFT IFSC. Stakeholders, including stock exchanges, clearing corporations, broker dealers, technology providers and market participants, have been invited to provide comments in the prescribed format by the timelines specified in the Consultation Paper. Click here.

• Consultation Paper on the Proposed IFSCA Good Delivery Guidelines 2025

On November 28, 2025, the International Financial Services Centres Authority released a Consultation Paper proposing IFSCA Good Delivery Guidelines for precious metals traded on platforms such as the India International Bullion Exchange (IIBX). These proposed guidelines aim to align bullion quality, refinery accreditation, bar specifications, assaying standards, vaulting practices, and traceability requirements with international norms followed by global bullion markets. The initiative is intended to enhance market integrity, ensure uniformity in quality standards, and strengthen the credibility of the IFSC bullion ecosystem. Stakeholders—including refiners, trading members, vault operators, and market infrastructure institutions—are invited to submit comments on the proposed framework. Click here.

• Consultation Paper on Guidelines on Cyber Security and Cyber Resilience for MIIs in IFSC

On November 25, 2025, IFSCA issued a public consultation paper proposing a comprehensive cyber security and cyber resilience framework for Market Infrastructure Institutions (MIIs) operating in GIFT IFSC. The draft guidelines introduce mandatory controls relating to cyber governance, 24×7 Security Operations Centres, incident reporting timelines, penetration testing, red-team exercises, third-party risk management, and enhanced technological resilience measures. The framework is aligned with emerging global standards for systemic financial market infrastructure and aims to safeguard critical systems supporting trading, clearing, settlement and related services. Feedback has been sought from MIIs, technology providers, and market intermediaries. Click here.

• Consultation Paper on Proposed Amendment to IFSCA (Registration of Insurance Business) Regulations, 2025 (19/11/2025)

On November 19, 2025, the Authority issued a consultation paper proposing amendments to the IFSCA (Registration of Insurance Business) Regulations. The proposed changes seek to streamline entry norms for foreign insurers, clarify registration requirements, modernise solvency and reporting obligations, and facilitate innovative insurance structures tailored for cross-border and internationally mobile clientele. The amendments aim to deepen the insurance marketplace in IFSC and ensure proportionate, risk-based supervision. Comments from insurance companies, intermediaries, and industry associations have been invited. Click here.

• Seeking Public Comments on the IFSCA Regulations for International Branch Campuses and Offshore Education Centres, 2022

On November 14, 2025, IFSCA invited public comments on its existing framework governing the establishment and operations of International Branch Campuses (IBCs) and Offshore Education Centres (OECs) in GIFT IFSC. The consultation seeks stakeholder input on refining admission requirements, quality assurance mechanisms, accreditation standards, and governance norms to encourage globally reputed universities to operate within IFSC while maintaining academic integrity and student protection. The review aims to modernise regulatory oversight and strengthen the education ecosystem emerging in GIFT City. Click here.

• Consultation Paper on Regulatory Framework for Implementation Services by Investment Advisers

On November 13, 2025, IFSCA issued a consultation paper proposing a regulatory framework under which Investment Advisers (IAs) operating in IFSC may offer implementation services to clients in addition to advisory services. The proposal outlines safeguards to prevent conflicts of interest, including mandatory client consent, segregation of advisory and implementation fees, and enhanced disclosure requirements. The framework aims to increase efficiency for investors while maintaining the independence of the advisory function and ensuring that execution support does not compromise investor protection. Click here.

• Consultation Paper on the Proposed IFSCA (Pension Fund) Regulations, 2025 (04/11/2025)

On November 4, 2025, the Authority published a consultation paper introducing the draft IFSCA (Pension Fund) Regulations, 2025. This marks the first comprehensive regulatory framework for pension fund entities operating in GIFT IFSC. The proposed regulations address registration criteria, governance requirements, investment norms, custody and trusteeship arrangements, and risk-management obligations. The objective is to position GIFT IFSC as a global hub for retirement planning solutions and to attract international pension administrators and service providers. Click here.

• Consultation Paper on Amendments to the IFSCA (Capital Market Intermediaries) Regulations, 2025

On November 3, 2025, IFSCA released a consultation paper proposing amendments to the regulatory regime governing capital market intermediaries in GIFT IFSC. The proposed amendments seek to update registration norms, broaden the permissible scope of intermediary activities, strengthen fit-and-proper criteria, and introduce enhanced compliance, disclosure, and risk-management requirements to align with evolving market practices. Stakeholder feedback has been sought to ensure regulatory clarity, facilitate ease of doing business, and preserve investor protection within the IFSC ecosystem. Click here.

REGULATIONS

• IFSCA (Performance Review Committee) Regulations, 2022, as Amended up to 29.09.2025

On November 13, 2025, the International Financial Services Centres Authority published the updated version of the IFSCA (Performance Review Committee) Regulations, 2022, reflecting all amendments made up to September 29, 2025. These regulations govern the constitution, functioning, evaluation parameters, and oversight responsibilities of Performance Review Committees (PRCs) constituted across IFSC-regulated entities. The amended regulations introduce refinements to governance standards, performance-assessment methodologies, reporting obligations, and oversight expectations to enhance accountability and ensure that entities maintain robust internal performance monitoring frameworks consistent with international best practices. Click here.

NOTIFICATIONS

• Companies (Meetings of Board and its Powers) Amendment Rules, 2025

On November 21, 2025, the Ministry of Corporate Affairs notified the Companies (Meetings of Board and its Powers) Amendment Rules, 2025 via G.S.R. 811(E), amending Rule 11(2) of the Companies (Meetings of Board and its Powers) Rules, 2014. The amendment expands the definition of “business of financing industrial enterprises” for the purposes of Section 186(11)(a) of the Companies Act, 2013. Under the revised provision, the definition now extends to certain activities undertaken by IFSC-registered Finance Companies, specifically those permitted under sub-clauses (a) and (e) of Regulation 5(1)(ii) of the IFSCA (Finance Company) Regulations, 2021. This amendment enables IFSC-based finance companies to undertake inter-corporate loans, guarantees and security transactions as part of their ordinary course of business without triggering Section 186 restrictions, thereby aligning corporate-law definitions with IFSCA’s finance-company regulatory framework. IFSC entities engaged in treasury functions and intra-group financing should reassess their documentation and compliance in light of this expanded scope. Click here.