SEBI has coordinated with the Central Board of Direct Taxes (CBDT) to resolve difficulties faced by Foreign Portfolio Investors (FPIs) in obtaining PAN under the newly notified Income-tax Rules, 2026. CBDT issued five specific clarifications to simplify the completion of updated PAN forms, reducing barriers to FPI on-boarding in Indian markets.

Key Points

• CBDT notified new Income-tax Rules, 2026 and updated PAN forms on March 20, 2026, adding new mandatory fields (e.g., Taxpayer Identification Number, Representative Assessee/Authorized Representative details, mobile number)
• FPIs expressed significant difficulties in furnishing the newly mandated information
• SEBI actively engaged CBDT and secured five operational clarifications to ease compliance
• The Authorized Signatory (AS) named in the Common Application Form (CAF) can serve as the Representative Assessee/Authorized Representative (RA/AR) for PAN purposes
• No supporting documents are required for the AS/RA/AR fields
• FPIs use a single Common Application Form (CAF) for SEBI registration, bank/demat account opening, and PAN issuance

Regulatory Changes

No new regulations were introduced. CBDT issued the following clarifications to the existing PAN application process under Income-tax Rules, 2026:

1. The Authorized Signatory (AS) named in the CAF may be used for the RA/AR field; liability of the AS is limited solely to the purpose of PAN application
2. AS’s address, mobile/landline number, and email ID may be used for RA/AR fields; if unavailable, FPI-level contact details may be substituted
3. PAN, Aadhaar, or Passport of the AS may be furnished; if unavailable, the FPI registration number may be provided instead
4. Where TIN or equivalent is not applicable for a jurisdiction, the TIN field may be filled with “0000000000”
5. Where a mobile number is unavailable, a landline number may be provided in the contact details field

Compliance Requirements

• FPIs applying for PAN under the new Income-tax Rules, 2026 forms should follow the above CBDT clarifications
• Designated Depository Participants (DDPs) and custodians facilitating FPI registration should update their on-boarding processes to reflect these clarifications
• No new documentation burden is imposed; existing CAF-captured Authorized Signatory information is sufficient for RA/AR fields

Important Dates

• March 20, 2026: CBDT notified new Income-tax Rules, 2026 and updated PAN forms
• May 15, 2026: SEBI press release (PR No. 30/2026) issued communicating CBDT clarifications

Impact Assessment

This circular has a moderate positive impact on foreign capital inflows into India. The clarifications remove procedural friction in FPI on-boarding that had arisen following CBDT’s revision of PAN forms in March 2026. By allowing substitution of FPI registration numbers for personal identifiers (PAN/Aadhaar/Passport) and permitting landline numbers in lieu of mobile numbers, the clarifications are particularly beneficial for institutional FPIs from jurisdictions where certain identifiers are not applicable. No market-wide or securities-specific impact is expected; the effect is limited to operational ease for new and renewing FPI registrations.