FME Regulatory Intelligence, Learning & Practice · IFSCA (Fund Management) Regulations, 2025

Topic A of 6 · 14 terms

People and entities

Who is responsible for what?

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1 · In one sentence

A regulated institution that keeps the fund's securities safe and records them.

2 · Think of it like thisThink of a bank locker. You keep your jewellery there so it is safe and recorded, even if you hand the key to someone else to use. A custodian is the fund's locker: it holds the shares, bonds and other securities, and keeps a record of every movement.

4 · A real-world example

A custodian holds the shares a fund has bought and settles its trades.

5 · Why it matters

Keeping assets with an independent custodian protects them from misuse.

6 · How is it different from trustee?

CustodianPhysically safekeeps securities
vs
TrusteeOversees the fund as a whole

The trustee oversees; the custodian physically safekeeps securities.

7 · Regulatory meaning

In GIFT IFSC a custodian is needed once a scheme's AUM exceeds USD 70 million, and always for retail and open-ended restricted schemes (IFSCA FM Regulations, Reg 132). For portfolio managers: every portfolio manager must appoint a custodian, unless it provides only advisory services (Reg 19, SEBI (Portfolio Managers) Regulations, 2026 (in force from 1 April 2027)).

8 · Explain it to someone else

Remember it this way: Custodian = the fund's safe-deposit locker.

A fund buys listed shares. Which service provider holds them in safekeeping?

Plain-English explanations to aid understanding. Regulatory points cite their source; general finance concepts are explained as commonly used. Not legal or tax advice.

Prashant Kumar

Meet the expert

CS Prashant Kumar

Company Secretary & Compliance Officer
Global Horizons Capital Advisors (IFSC) Private Limited — an IFSCA-licensed investment banker

13+ years of experienceFCS Fellow member, ICSIAuthor Audit Under Fire

Published in The Chartered Accountant (Jun 2025, Jan 2025, Mar 2024) and Chartered Secretary (Aug 2023)

Prashant Kumar is a seasoned Company Secretary and corporate governance strategist with more than 13 years of experience advising large corporates, promoter-led groups and global businesses on compliance, regulatory risk and board governance. In GIFT IFSC, the IFSCA regime is his day job rather than a research topic.