Borrowings and deferred payments
Regulation 101
Borrowings and deferred payments
IFSCA (Fund Management) Regulations, 2025No change in 2026Chapter VI · Other Fund Management Activities
Chapter VI · Other Fund Management Activities
Regulation 101 – Borrowings and deferred payments
High importance about 3 min
Investment Trusts — REITs & InvITs: Setting up and running listed and unlisted Investment Trusts, from sponsor to distribution.
1
In plain English
Listed Investment Trusts may issue listed debt securities and are subject to aggregate borrowing/deferred-payment limits.
In plain English
≤70% (InvIT) / ≤49% (REIT); >25% triggers rating + unit-holder approval
IT — leverage
2
The rule, in its own words
Read the exact text of Regulation 101
101. (1) The following provisions shall apply to an Investment Trust listed on a recognised stock exchange:
(a) An Investment Trust whose units are listed on a recognised stock exchange may issue debt securities in the manner specified by the Authority:
Provided that such debt securities shall be listed on recognised stock exchange(s).
(b) The aggregate consolidated borrowings and deferred payments of the Investment Trust, holdco and the SPV(s), net of cash and cash equivalents shall not exceed:
(i) seventy per cent. (70%) of the value of the InvIT assets; or
(ii) forty nine per cent. (49%) of the value of the REIT assets.
(c) If the aggregate consolidated borrowings and deferred payments o…
Show the full text
101. (1) The following provisions shall apply to an Investment Trust listed on a recognised stock exchange:
(a) An Investment Trust whose units are listed on a recognised stock exchange may issue debt securities in the manner specified by the Authority:
Provided that such debt securities shall be listed on recognised stock exchange(s).
(b) The aggregate consolidated borrowings and deferred payments of the Investment Trust, holdco and the SPV(s), net of cash and cash equivalents shall not exceed:
(i) seventy per cent. (70%) of the value of the InvIT assets; or
(ii) forty nine per cent. (49%) of the value of the REIT assets.
(c) If the aggregate consolidated borrowings and deferred payments of the Investment Trust, holdco and the SPV(s), net of cash and cash equivalents exceed twenty five per cent. (25%) of the value of the assets of Investment Trust, for any further borrowing,–
(i) up to forty nine per cent. (49%), the Investment Trust shall -
(a) obtain credit rating from a credit rating agency; and
(b) seek approval of unitholders.
(ii) above forty–nine per cent. (49%), an InvIT shall -
(a) obtain a credit rating of "AAA" or equivalent for its consolidated borrowing and the proposed borrowing, from a credit rating agency;
(b) utilize the funds only for acquisition or development of infrastructure projects;
(c) have a track record of at least six distributions, on a continuous basis, post listing, in the years preceding the financial year in which the enhanced borrowings are proposed to be made; and
(d) obtain prior approval of unitholders.
(d) If the conditions specified in the above sub-clauses are breached on account of market movements of the price of the underlying assets or securities, the investment manager shall inform the same to the trustee and ensure that the conditions are satisfied within six months of such breach.
(2) An Investment Trust whose units are not listed on a recognised stock exchange may undertake borrowing to the extent permitted under the trust deed, after seeking approval from such number of investors as specified in the trust deed.
Statutory text — Principal Regulations, 2025 (as amended to 30 January 2026), consolidated where amended. The notified Gazette text prevails. Tap a highlighted word for how it functions.
3
Exceptions and conditions
Taken from the wording of this provision — the carve-outs and conditions worth reading closely.
Provided that such debt securities shall be listed on recognised stock exchange(s)
4
What this means in practice
Compliance actions
- Applies to
- Investment Trust (listed)
- Frequency
- Ongoing
- Evidence
- Borrowing/leverage computation workpaper; Debt securities listing confirmation
5
The numbers that matter
| Requirement | Threshold | On crossing |
|---|---|---|
| IT — leverage | ≤70% (InvIT) / ≤49% (REIT); >25% triggers rating + unit-holder approval | Borrowing controls |
6
Where it connects
Read alongside
7
Check yourself
Quiz Centre
Test yourself on Regulation 101
9 questions in the unified bank test this regulation. Each explains every option and cites the provision.
Above what consolidated borrowing level does an Investment Trust need a credit rating and unit-holder approval?
8
Your notes
→ Next
Work with Prashant Kumar
A question on Regulation 101 for your FME?
Borrowings and deferred payments: get advice on how it applies to your structure, scheme or filing.
›
Investment Trusts — REITs & InvITs