PPM validity and extensions: why VC and restricted schemes now differ from retail schemes and SSFs

A placement memorandum or offer document taken on record by IFSCA is valid for 12 months. Within that time the scheme must declare its first close with the minimum corpus. What happens when the money is slow to come in now depends on the scheme type.

Repeatable extensions

For VC schemes (Regulation 19(3)) and open-ended restricted schemes (Regulation 35(2)), from 30 January 2026, and for close-ended restricted schemes (Regulation 31(3)), from 10 September 2026, the FME may apply for extensions of six months at a time. The first costs 25% of the fresh-scheme fee prevailing at the time; each later extension costs 50%. The application must be made while the PPM is still valid; a late application cannot be saved by paying more.

One-time extension

Retail open-ended schemes (Regulation 47(6)) and Special Situation Funds (Regulation 55(3)) keep the older rule: a single six-month extension at 50% of the fee.

If the corpus never arrives

A scheme that does not reach its minimum corpus within the validity period, and has no valid extension, falls to be wound up. A scheme that was filed but never onboarded investors or collected funds can now be wound up voluntarily under Regulation 131(1)(d), inserted with effect from 30 January 2026.

Practical points

Diarise the 12-month date on the day IFSCA takes the PPM on record, and set a reminder at least a month before it. Keep the extension application, fee receipt and IFSCA's record of the extension on the scheme file. The PPM extension calculator gives the dates and fee percentage for each extension.