Description

SEBI settles enforcement proceedings against Accuracap Prime Opportunities Fund and related entities for AIF regulation violations including corpus maintenance failure and exceeding investment limits in Bajaj Auto Limited.

Summary

SEBI issued a Summary Settlement Order (SO/2025-26/PSD/7-12) settling enforcement proceedings against six applicants related to Accuracap Vectra Fund, a scheme of Accuracap Prime Opportunities Fund (AIF). The violations, observed in quarterly filings for FY 2023-24, involved failure to maintain minimum corpus, failure to wind up the scheme after corpus breach, and exceeding investment limits in Bajaj Auto Limited. The matter was settled for ₹21,75,000 paid jointly and severally by the applicants.

Key Points

  • Accuracap Vectra Fund failed to maintain the minimum corpus of ₹20 Crores under the scheme during FY 2023-24
  • The AIF did not restore the corpus above ₹20 Crores within the required three-month window, and also failed to redeem units and wind up the scheme
  • The AIF exceeded the maximum permissible investment limit in a single investee company — Bajaj Auto Limited
  • Six applicants were named: Accuracap Prime Opportunities Fund, Accuracap Technologies LLP (Manager), and four Key Managerial Personnel (Naresh Chand Gupta, Raman Nagpal, Prateek Gupta, Divya Singhal)
  • Summary Settlement Notices were issued on November 24, 2025 under Regulation 16 of the SEBI (Settlement Proceedings) Regulations, 2018
  • Settlement amount of ₹21,75,000 (Rupees Twenty-One Lakhs Seventy-Five Thousand) was remitted and confirmed by SEBI

Regulatory Changes

No new regulatory changes introduced. This order applies existing provisions:

  • Regulation 10(b) of AIF Regulations r/w Clause 5.5.2 and 5.5.3 of Master Circular dated May 07, 2024
  • Regulation 15(1)(d) of AIF Regulations
  • Regulation 20(1) r/w Clause 2(a) and 2(b) of the Code of Conduct under Fourth Schedule of AIF Regulations (applicable to Manager and KMPs)

Compliance Requirements

  • AIFs must maintain a minimum corpus of ₹20 Crores per scheme at all times
  • If corpus falls below ₹20 Crores, it must be restored within three months; failing that, units must be redeemed and the scheme wound up
  • AIFs must adhere to maximum permissible investment limits in any single investee company
  • Managers and Key Managerial Personnel are jointly accountable for compliance with AIF Regulations and the Code of Conduct

Important Dates

  • FY 2023-24: Period during which violations were observed in quarterly filings
  • November 24, 2025: Date of issuance of Notices of Summary Settlement to applicants
  • Within 30 calendar days of receipt of Notices: Deadline for filing settlement application and remitting settlement amount
  • March 17, 2026: Date of this Settlement Order

Impact Assessment

The impact of this order is limited to the specific fund and its stakeholders. There is no broader market or systemic impact. The settlement closes enforcement proceedings without admission of guilt. For the AIF industry, the order reaffirms SEBI’s active monitoring of corpus maintenance and single-issuer concentration limits through quarterly filings. Fund managers operating AIFs with declining AUM should be alert to corpus thresholds and wind-up obligations under the AIF Regulations.

Impact Justification

Fund-specific settlement order with limited broader market impact; affects only Accuracap Vectra Fund and its manager/KMPs. Settlement amount of ₹21.75 lakhs is modest. Bajaj Auto mentioned only as the investee company where limits were breached.