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

Custodian trigger

Find out whether an independent custodian is required, based on the scheme type and AUM.

Source: Reg 132, IFSCA (Fund Management) Regulations, 2025.

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An independent custodian is always required for this scheme type.

How to use this calculator

  1. Choose a mode. Simple asks one question at a time. Detailed shows every input on one page, with the working.
  2. Enter your figures in the units shown next to each box (USD, USD million or %). The result updates as you type.
  3. Read the outcome, then the working and the regulation it rests on. Use Start again to clear the figures.

Worked example

A close-ended restricted scheme has grown to USD 85 million of AUM.

What to notice: For schemes other than retail and open-ended restricted ones, the trigger is AUM above USD 70 million.

Result

14 Oct 2026

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Outcome

Independent custodian required

An independent custodian is always required for this scheme type.

In simple terms

An independent custodian is always required for this scheme type. This is an indicative check against the provision named above. If the result is close to a limit or your facts are unusual, have it reviewed.

The figures

Scheme typeRetail scheme
Scheme AUMNot relevant for this scheme type
Rule for this scheme typeAlways required
Independent custodian required?Yes

How this is worked out

  1. Retail scheme or open-ended restricted scheme: an independent custodian is always required.
  2. Any other scheme: required once AUM is above USD 70 million. At or below that, keep monitoring AUM.

Regulatory source

Reg 132
Open source

Relevant provisions

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Prashant Kumar

Expert review

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Company Secretary & Compliance Officer, Global Horizons Capital Advisors (IFSC) Private Limited · FCS · 13+ years in compliance and governance

A tool points the way. CS Prashant Kumar checks your facts, structure and documents, then gives you a written view and a clear path to registration and compliance.

Each calculator gives an indicative result based on the figures entered and the provision named on it. It is not legal or professional advice. Check the full provision and your own facts, including any extension or relaxation granted.

Prashant Kumar

Meet the expert

CS Prashant Kumar

Company Secretary & Compliance Officer
Global Horizons Capital Advisors (IFSC) Private Limited — an IFSCA-licensed investment banker

13+ years of experienceFCS Fellow member, ICSIAuthor Audit Under Fire

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.