Resources · GIFT IFSC
Numbers room
Every threshold and trigger, each linked to its provision. These decide when an obligation switches on.
| Number | What it controls | Applies to | When crossed | Source |
|---|---|---|---|---|
| 5 yrs managing ≥ USD 200m AUM for > 25,000 investors | Registered FME (Retail) | Qualifies for Retail registration on this route | Reg 6(2)(a)(i) | |
| Control person(s) ≥25%: 5 yrs, ≥1,000 investors, ≥ USD 50m; FME net worth ≥ USD 2m | Registered FME (Retail) | Alternate route to Retail registration | Reg 6(2)(a)(ii) | |
| AUM ≥ USD 1 billion (excluding FoF AUM) at FY close | Any FME | Appoint an additional fund-management KMP within 6 months of FY end | Reg 7(4) | |
| USD 75,000 | Authorised FME | Continuous minimum net worth | Second Schedule | |
| USD 500,000 | Registered FME (Non-Retail) | Continuous minimum net worth | Second Schedule | |
| USD 1,000,000 | Registered FME (Retail) | Continuous minimum net worth | Second Schedule | |
| 50 investors | Venture Capital scheme | Cannot exceed; use a restricted scheme for more | Reg 20(1) | |
| USD 250,000 (USD 60,000 for FME insiders) | Venture Capital scheme | Below threshold not permitted (except accredited investors) | Reg 20(2) | |
| Min USD 3m; max USD 200m | Venture Capital scheme | First close needs min corpus; corpus capped at USD 200m | Reg 23(1) | |
| ≥80% of corpus in investees ≤10 yrs old (follow-on relief added) | Venture Capital scheme | Follow-on beyond 10 yrs only on the three Second-Amendment conditions | Reg 23(3) + 2nd Amdt | |
| ≥2.5% of corpus or USD 750,000 (lower), capped at 10% | Venture Capital scheme | Mandatory skin-in-the-game unless an exemption applies | Reg 28(1) (2nd Amdt) | |
| 1,000 investors | Restricted scheme | Cannot exceed (or as specified) | Reg 32(1) | |
| USD 150,000 (USD 40,000 for FME insiders) | Restricted scheme | Below threshold not permitted (except accredited investors) | Reg 32(2) | |
| Min USD 3m; open-ended may commence at USD 1m | Restricted scheme | Open-ended must reach USD 3m within 12 months | Reg 35(2) | |
| ≤25% of corpus in unlisted securities | Restricted scheme (open-ended) | Unlisted investment only after USD 3m corpus achieved | Reg 35(1) | |
| Close-ended: ≥2.5%/USD 750k; Open-ended: ≥5%/USD 1.5m (lower), cap 10% | Restricted scheme | Mandatory contribution unless exempt (incl. index / passive-ETF FoF) | Reg 40(1) (2nd Amdt) | |
| ≥20 investors; no single investor >25%; within 6 months of offer close | Retail scheme | Must achieve within 6 months of offer closure | Reg 44 | |
| ≤15% of AUM in unlisted securities | Retail scheme (open-ended) | Breach requires correction | Reg 47(1) | |
| ≤10% AUM (up to 15% with fiduciary approval) | Retail scheme | Concentration limit | Reg 47(3) | |
| ≤25% AUM (≤50% for financial services) | Retail scheme | Sectoral cap (except sectoral/thematic/index) | Reg 47(4) | |
| ≤25% of AUM in associate | Retail scheme | Related-party concentration limit | Reg 47(5) | |
| Min USD 3m; open-ended may commence at USD 1m | Retail scheme | Reach USD 3m within 12 months | Reg 47(6) | |
| ≥1% of AUM or USD 200,000 (lower) | Retail scheme | Mandatory unless exempt (relocated / FoF / index / passive-ETF FoF) | Reg 52(1) (2nd Amdt) | |
| ≥10 stocks; single-stock ≤35% (sectoral) / ≤25% (other); ≥95% replication | ETF (Equity Index) | Index/replication norms | Reg 62 | |
| ≥5 issuers; single-issuer ≤25%; investment grade; ≥90% replication | ETF (Debt Index) | Index/replication norms | Reg 63 | |
| ≥90% gold; ETCD ≤10% of AUM | ETF (Gold) | Composition norms; half-yearly physical verification | Reg 65 | |
| ≥90% silver; ETCD ≤10% of AUM | ETF (Silver) | Composition norms; half-yearly physical verification | Reg 66 | |
| AUM > USD 3 billion at FY close (excluding FoF AUM) | Any FME | Establish ESG governance policy and annual-report disclosures | Reg 72(1) (2nd Amdt) | |
| USD 75,000 | FME offering PMS | Cannot accept below (except accredited investors) | Reg 77(1) | |
| USD 75,000 | FME offering PMS (advisory) | Advisory only above the floor; comply with CMI Regs 2025 | Reg 80(c) (2nd Amdt) | |
| ≥5% units; net worth ≥ USD 15m (REIT: ≥USD 3m each, ≥USD 15m collective) | Investment Trust (Sponsor) | Cure sub-5% holding within 1 year | Reg 86 | |
| Asset value ≥ USD 75m; offer size ≥ USD 35m | Investment Trust | No initial offer below these | Reg 91(1) | |
| USD 150,000 (USD 1m if <80% in completed revenue-generating assets) | Investment Trust (PP listed) | Per-investor minimum | Reg 92(c) | |
| USD 250,000 min; ≤50 investors | Investment Trust (PP unlisted) | Per-investor minimum and investor cap | Reg 93(b),(c) | |
| ≥26% ultimate holding via holdco; 3-yr hold; unit-holder approval for sale >10% of asset value/yr | Investment Trust | Structuring and disposal controls | Reg 97 | |
| ≥80% in completed revenue-generating infrastructure; ≤10% under-construction | Investment Trust (InvIT) | Cure breach within 6 months | Reg 98(2) | |
| ≥75% in income-producing real estate; development ≤10% (up to 25% for redevelopment) | Investment Trust (REIT) | Cure breach within 6 months | Reg 99(3) | |
| ≥90% of net distributable cash flows to unit-holders | Investment Trust | Distribute at least half-yearly (public InvITs) | Reg 100(1) | |
| ≤70% (InvIT) / ≤49% (REIT); >25% triggers rating + unit-holder approval | Investment Trust (listed) | Borrowing controls | Reg 101(1) | |
| USD 10 million within 3 years of registration | Family Investment Fund | Aggregate across all vehicles | Reg 104(3) | |
| USD 500,000 | Registered FME (third-party) | Separate and additional to normal net worth | Reg 107F | |
| USD 50 million per scheme | Registered FME (third-party) | Restricted schemes managed for a third party | Reg 107G(1) | |
| 8 years (books/records); 5 years after winding-up (scheme records) | All FMEs | Minimum electronic retention periods | Reg 119(2),(3) | |
| AUM > USD 70 million (plus retail / open-ended restricted) | All schemes | Appoint an independent IFSC-based custodian | Reg 132 | |
| Within 6 months of FY end (was 4 months) | All FMEs | Submit to Authority and disclose to investors | Reg 134 (2nd Amdt) | |
| Exemption up to 18 months | Sandbox participants | No public solicitation in sandbox | Reg 145(1) |
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.