Description
SEBI mandates NISM Series-III-C certification for Compliance Officers of AIF Managers, effective January 01, 2027.
Summary
SEBI has introduced a mandatory certification requirement for Compliance Officers of Alternative Investment Fund (AIF) Managers. All Compliance Officers must obtain NISM Series-III-C: Securities Intermediaries Compliance (Fund) Certification. From January 01, 2027, only certified persons can be appointed as or continue to act as Compliance Officers for AIF Managers. This circular is issued under Regulation 20(18) of SEBI (Alternative Investment Funds) Regulations, 2012.
Key Points
- Compliance Officers of AIF Managers must obtain NISM Series-III-C certification
- Certification is Securities Intermediaries Compliance (Fund) Certification Examination
- Effective date for mandatory compliance: January 01, 2027
- Applies to both new appointments and existing Compliance Officers
- Based on Regulation 20(17) and 20(18) of AIF Regulations, 2012
- Compliance must be included in Compliance Test Reports prepared by managers
Regulatory Changes
SEBI has specified eligibility criteria for Compliance Officers of AIF Managers under Regulation 20(18) of the AIF Regulations. The new requirement mandates passing the NISM Series-III-C: Securities Intermediaries Compliance (Fund) Certification Examination as detailed in NISM communique dated November 20, 2025 (NISM/Certification/Series-III-C: Securities Intermediaries Compliance (Fund)/2025/01).
Compliance Requirements
- AIF Managers: Ensure Compliance Officers obtain NISM Series-III-C certification before January 01, 2027
- Existing Compliance Officers: Must obtain certification to continue in role beyond January 01, 2027
- New Appointments: Only certified persons can be appointed as Compliance Officers from January 01, 2027
- Trustees/Sponsors/Managers: Include compliance with this circular in the Compliance Test Report as per para 15.2 of SEBI Master Circular No. SEBI/HO/AFD-1/AFD-1-PoD/P/CIR/2024/39 dated May 07, 2024
Important Dates
- December 30, 2025: Circular issuance date (immediate effect)
- January 01, 2027: Deadline for Compliance Officers to obtain mandatory certification
- Compliance Officers must be certified by this date to be appointed or continue in their role
Impact Assessment
This circular has significant impact on the AIF industry as it establishes professional qualification standards for Compliance Officers. All existing Compliance Officers have approximately 12 months to obtain certification. AIF Managers must plan for training and certification of current officers or recruitment of certified personnel. Non-compliance could result in inability to maintain qualified Compliance Officers, potentially affecting AIF operations. The measure aims to strengthen compliance frameworks and protect investor interests in the AIF sector by ensuring Compliance Officers possess standardized knowledge of securities market regulations.
Impact Justification
Mandatory certification requirement affecting all AIF Managers with strict January 2027 deadline for compliance officer appointments and continuations.