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

Regulation 36

Disclosures to investors

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

Chapter III · Schemes for Fund Management

Regulation 36 – Disclosures to investors
Amended 2026 Critical importance about 3 min

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

1

In plain English

Requires material PM disclosures for Restricted schemes; as amended, sets NAV disclosure at least monthly (open-ended) or half-yearly (close-ended) — extendable to annual with 75%-by-value investor approval — and disclosure at least quarterly.

In plain English
2

The rule, in its own words

Read the exact text of Regulation 36
36. (1) The placement memorandum for restricted schemes shall clearly include disclosures regarding the investment objective, the targeted investors, proposed corpus, investment style or strategy, investment methodology, proposed tenure of the scheme, proposed fees and expenses, risk management practices, KMPs of the FME and other relevant details of the FME and the scheme. (2) Any material deviation or alteration to the fund strategy should be made with the consent of at least two-thirds (2/3rd) of investors by value. (3) 22[The FME shall ensure that the NAV is disclosed to the investors at least on a monthly basis in case of an open-ended scheme and half-yearly in case of a close-ended sch…
Show the full text
36. (1) The placement memorandum for restricted schemes shall clearly include disclosures regarding the investment objective, the targeted investors, proposed corpus, investment style or strategy, investment methodology, proposed tenure of the scheme, proposed fees and expenses, risk management practices, KMPs of the FME and other relevant details of the FME and the scheme. (2) Any material deviation or alteration to the fund strategy should be made with the consent of at least two-thirds (2/3rd) of investors by value. (3) 22[The FME shall ensure that the NAV is disclosed to the investors at least on a monthly basis in case of an open-ended scheme and half-yearly in case of a close-ended scheme, starting from the month or half-year period, as the case may be, in which the scheme commences investment activities, excluding investments made in accordance with second proviso to sub-regulation (1) of regulation 34, and within such time period as disclosed in the placement memorandum of the scheme. Provided that such half-year period may be enhanced to one year in case of a close-ended scheme on prior approval of at least seventy-five per cent. (75%) investors in the scheme by value of their investments. (4) The FME shall ensure that the portfolio under the scheme is disclosed to the investors at least on a quarterly basis, starting from the quarter in which the scheme commences investment activities, excluding investments made in accordance with second proviso to sub-regulation (1) of regulation 34, within one (1) month from the end of each quarter.] (5) Any other material disclosure as considered suitable by the FME or the fiduciaries shall be informed to the investors immediately. (6) The FME and the fiduciaries shall comply with the disclosure requirements 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.
Amendment history (1 note)

Footnotes from the consolidated text. They record earlier wording and are not operative law.

  1. 22 Substituted by the International Financial Services Centres Authority (Fund Management) (Second Amendment) Regulations, 2026, w.e.f. September 10, 2026. Prior to the substitution, it read as- “(3) The FME shall ensure that the NAV is disclosed to the investors at least on a monthly basis in case of an open-ended scheme and half-yearly in case of a close ended scheme within such time period as disclosed in the placement memorandum. (4) The FME shall ensure that the portfolio under the scheme is disclosed to the investors at least on a quarterly basis within one month from the end of the quarter.”
3

Exceptions and conditions

Taken from the wording of this provision — the carve-outs and conditions worth reading closely.

Provided that such half-year period may be enhanced to one year in case of a close-ended scheme on prior approval of at least seventy-five per cent
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What this means in practice

Practical effect
Disclosure cadence is what investors rely on; changing it now needs their approval, not just a PM edit.
Compliance actions
Applies to
Restricted scheme
Frequency
Monthly/half-yearly (NAV); quarterly (portfolio)
Trigger
Commencement of investment activities
Evidence
NAV disclosure communications; 75% investor approval documentation (if annual cadence used); Quarterly portfolio disclosure communications
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What changed in 2026

NAV disclosure to Restricted scheme investors: at least monthly (open-ended) or half-yearly (close-ended), from the month/half-year the scheme commences investment activities (excluding Reg 34(1) second-proviso investments), within the PM-disclosed timeline. The half-yearly period can be extended to one year with prior approval of at least 75% of investors by value. Portfolio disclosure: at least quarterly from the commencement quarter, within 1 month of each quarter-end.

Practical effect
Introduces the investment-activity-commencement trigger and the 75%-investor-approval route to move close-ended Restricted schemes from half-yearly to annual NAV disclosure — a material flexibility for close-ended funds' investor reporting cadence, conditional on investor consent.
What to do
For close-ended Restricted schemes wanting annual NAV disclosure, obtain and document the 75%-by-value investor approval before relying on the extended period; otherwise maintain half-yearly disclosure.
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Where it connects

Referred to by

Read alongside

7

Check yourself

A close-ended restricted scheme wants to move NAV disclosure from half-yearly to annual. What does the Second Amendment require?
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Your notes

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Restricted (non-retail) schemes
Regulation 36 Chapter III · Part B Amended 2026 Critical · about 3 min