Filing the placement memorandum late
Scenario 5 of 15 · Reg 12
A Category II AIF (not an Accredited Investors only fund) plans to launch a new scheme on Monday 2 November 2026. The merchant banker can file the placement memorandum with SEBI only on Monday 26 October 2026.
Can the launch go ahead on 2 November?
Choose an answer to see the verdict and the approach.
Scenarios are for learning. They apply the SEBI (AIF) Regulations, 2012 provision named to simplified facts. Real situations need a review of the full provision, SEBI's circulars and your own facts.
Meet the expert
CS Prashant Kumar
Company Secretary & Compliance Officer
Global Horizons Capital Advisors (IFSC) Private Limited — an IFSCA-licensed investment banker
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.