Chapter IV · General Obligations, Responsibilities and Transparency
Regulation 21
Conflict of Interest
Chapter IV · General Obligations, Responsibilities and Transparency
SEBI (Alternative Investment Funds) Regulations, 2012
In plain English
In plain English
The sponsor and the manager act as fiduciaries for investors. They must disclose every conflict of interest as and when it arises or seems likely to arise. The manager must have written policies to identify, monitor and mitigate conflicts, and both must follow SEBI's high-level principles on avoiding conflicts with associated persons.
Where this sits
Regulation 21 is in Chapter IV — General Obligations, Responsibilities and Transparency of the SEBI (Alternative Investment Funds) Regulations, 2012.
Provisos, explanations and conditions
This regulation has no provisos or explanations in its text. Check Connections for other provisions it refers to.
What changed
No change to this regulation by the 2026 amendments (No. 303 of 16 April 2026 and No. 313 of 10 July 2026).
Where it connects
The text of this regulation does not refer to other numbered regulations.
Related Master Circular chapters (by subject)
Chapter
Check yourself
3 practice questions on Regulation 21, each with an explanation for every option.
- When must the sponsor and manager disclose conflicts of interest to investors?
- In what capacity must the Sponsor and Manager act towards the AIF's investors?
- True or false: the Manager must have written policies and procedures to identify, monitor and mitigate conflicts of interest.
The regulation
21. (1) The Sponsor and Manager of the Alternative Investment Fund shall act in a fiduciary capacity towards its investors and shall disclose to the investors, all conflicts of interests as and when they arise or seem likely to arise.
(2) Manager shall establish and implement written policies and procedures to identify, monitor and appropriately mitigate conflicts of interest throughout the scope of business.
(3) Managers and Sponsors of Alternative Investment Fund shall abide by high level principles on avoidance of conflicts of interest with associated persons, as may be specified by the Board from time to time.
Text from the consolidated Regulations. Square brackets and [***] mark earlier amendments and omissions, as in the official text. Check the official Gazette text before relying on it.
Last checked against source on 10 October 2026: consolidated Regulations to 19 November 2025, read with Amendment Regulations No. 303 (16 April 2026) and No. 313 (10 July 2026).
Source and verification
- Instrument
- SEBI (Alternative Investment Funds) Regulations, 2012 — Regulation 21
- Text used
- Consolidated Regulations as amended up to 19 November 2025, read with the 2026 amendments (no change to this regulation)
- Last checked
- 10 October 2026
- Official source
- www.sebi.gov.in → Legal → Regulations. The Gazette text prevails.
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