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

Regulation 34

Permissible investments

IFSCA (Fund Management) Regulations, 2025Amended in 2026Chapter III · Schemes for Fund Management

Chapter III · Schemes for Fund Management

Regulation 34 – Permissible investments
Amended 2026 Critical importance about 4 min

Restricted (non-retail) schemes: The core non-retail scheme regime — corpus, investors, disclosure, valuation and contribution.

1

In plain English

Sets the exhaustive list of permissible investments for Restricted schemes, subject to the amended provisos on certificates of deposit and pre-first-close/pre-USD-1-million liquidity restrictions.

In plain English
2

The rule, in its own words

Read the exact text of Regulation 34
34. (1) Subject to other provisions of these regulations, a restricted scheme may invest only in the following instruments or entities in IFSC, India or foreign jurisdiction:- (a) Unlisted securities; (b) Securities listed or to be listed or traded on stock exchanges; (c) Money market instruments; (d) Debt securities; (e) Securitised debt instruments, which are either asset backed or mortgage-backed securities; (f) Units of other investment schemes subject to appropriate disclosure in the placement memorandum; (g) Derivatives including commodity derivatives subject to suitable disclosures in the placement memorandum; (h) Limited liability partnerships; or (i) Such other securities or financi…
Show the full text
34. (1) Subject to other provisions of these regulations, a restricted scheme may invest only in the following instruments or entities in IFSC, India or foreign jurisdiction:- (a) Unlisted securities; (b) Securities listed or to be listed or traded on stock exchanges; (c) Money market instruments; (d) Debt securities; (e) Securitised debt instruments, which are either asset backed or mortgage-backed securities; (f) Units of other investment schemes subject to appropriate disclosure in the placement memorandum; (g) Derivatives including commodity derivatives subject to suitable disclosures in the placement memorandum; (h) Limited liability partnerships; or (i) Such other securities or financial products/assets or instruments as specified by the Authority: Provided that pending deployment of monies, FME may invest in 17[***] units of investment schemes such as overnight, liquid or money market schemes, money market instruments, bank deposits or any other securities or financial assets or instruments as may be specified by the Authority. 18[Provided further that any monies received from the contributors prior to the first close in case of a close-ended scheme, or prior to raising USD 1 Million in funds in case of an open-ended scheme, shall be deployed only in such permissible investments as per sub-regulation (1) of regulation 34 that support preservation of capital and adequate liquidity of the monies deployed, such as bank deposits with option for premature withdrawal, overnight funds, etc., as disclosed by the FME in the placement memorandum.] (2) Any investment made under sub-regulation (1) shall be in accordance with the provisions of these regulations, investment objective of the restricted scheme and disclosures made in the placement memorandum. (3) In addition to the above, a close ended scheme may invest up to twenty per cent. (20%) of the corpus in physical assets such as real estate, bullion, art or any other physical asset as may be specified by the Authority.
Statutory text — Principal Regulations, 2025, consolidated as amended up to 10 September 2026 (including the Second Amendment, 2026). 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.

(1) Subject to other provisions of these regulations, a restricted scheme may invest only in the following instruments or entities in IFSC, India or foreign jurisdiction:- (a) Unlisted securities
(f) Units of other investment schemes subject to appropriate disclosure in the placement memorandum
(g) Derivatives including commodity derivatives subject to suitable disclosures in the placement memorandum
or (i) Such other securities or financial products/assets or instruments as specified by the Authority: Provided that pending deployment of monies, FME may invest in 17[***] units of investment schemes such as overnight, liquid or money market schemes, money market instruments, bank deposits or any other securities or financial assets or instruments as may be specified by the Authority
4

What this means in practice

Compliance actions
Applies to
Restricted scheme
Frequency
Per investment decision
Evidence
Investment approval memos; Pre-first-close/pre-USD-1M treasury deployment records
5

What changed in 2026

"Certificates of deposit" removed from the permissible short-term instruments proviso for Restricted schemes (mirrors item 3 for VC).

Practical effect
Same as VC scheme change — certificates of deposit no longer specifically listed.
What to do
Review Restricted scheme documentation referencing certificates of deposit.

Pre-first-close (close-ended) / pre-USD-1-million-raised (open-ended) monies from Restricted scheme contributors must be deployed only in Reg 34(1) permissible, capital-preserving, liquid investments (bank deposits with premature withdrawal, overnight funds, etc.) as disclosed in the placement memorandum.

Practical effect
Mirrors the VC pre-first-close liquidity restriction (item 4) for Restricted schemes, with an open-ended-scheme trigger of USD 1 million raised.
What to do
Update Restricted scheme PMs and treasury policy for the pre-first-close/pre-USD-1M liquidity restriction.
6

Where it connects

Referred to by

Read alongside

7

Check yourself

The list of permissible investments for a Restricted scheme is exhaustive (a closed list).
The Second Amendment omitted which instrument from the Restricted-scheme short-term list?
8

Your notes

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Restricted (non-retail) schemes
Regulation 34 Chapter III · Part B Amended 2026 Critical · about 4 min