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What is a Category II AIF Compliance Calendar?

If you are operating a Category II alternative investment fund in India, you must comply with the SEBI-prescribed investment conditions, leverage restrictions, valuation norms, and investor reporting requirements in the Category II AIF compliance calendar. In simple terms, it is a structured time-bound schedule that helps track all SEBI-mandated filings, disclosures, audits, certifications, and reporting obligations applicable to Category II AIFs.

The category II AIF compliance calendar further helps fund managers and sponsors to systematically track the quarterly, annual, and event-based compliance. Join hands with Enterslice to ensure management of the Category II AIF compliances through our Category II AIF compliance calendar while continuing to strictly operate in line with SEBI’s regulatory framework.

Quarterly Regulatory to SEBI in Prescribed Format

Ongoing Investor Reporting and Mandatory Disclosures

Monitor Compliance with Category II Investment Norms

Intimation to SEBI of Material Events and Changes

Commitments Raised- Rs 11,20,589 Crore

Funds Raised- Rs 4,04,212 Crore

Investments Made- Rs 3,69,570 Crore (Approx)

Investment in Listed Securities- Rs 36,343 Crore

Investment in Unlisted Securities- Rs 3,25,231 Crore

Stay Compliant with SEBI Category II AIF Compliance Calendar Deadlines

Partner with experts at Enterslice and get timely updates through our SEBI Category II AIF Compliance Calendar to track quarterly, annual, and event-based compliance in India.

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Why Manage Compliance through SEBI Category II AIF Compliance Calendar?

Managing the compliance through SEBI Category II AIF Compliance Calendar plays a crucial role in ensuring that funds operate in adherence to SEBI (AIF) Regulations, 2012 and other applicable SEBI circulars:

Monitors SEBI-Prescribed Timelines

Managing the category II AIF compliance helps monitor all SEBI-prescribed deadlines, ensuring quarterly, annual, and event-based filings are submitted accurately and on time.

Ensures Consistent Valuation & Reporting Norms

Managing the compliance through category II compliance calendar mandates adherence to consistent valuation policies, auditor reviews, and periodic reporting standards.

Strengthens Internal Compliance Framework

Managing and defining the category II compliance responsibilities promotes systematic internal monitoring, accountability, and coordination among fund managers, trustees, auditors, and compliance teams.

Reduces Regulatory & Compliance Risks

Timely identification of category II AIF compliance obligations helps mitigate the risk of delayed filings, regulatory observations, penalties, or SEBI inspection issues.

Supports Transparent & Disciplined Fund Practices

Managing compliance via a structured category II AIF compliance calendar supports transparent investor disclosure and disciplined fund operations in line with SEBI’s governance.

Facilitates Audit & Inspection Readiness

Managing the category II AIF compliance ensures the timely coordination of audits, certifications, and documentation, keeping the fund inspection-ready at all times.

What are the Additional Key Compliance Areas for Category II AIFs?

Have a look at the additional key compliance areas for category II AIFs in India:

  • Implementation of robust risk management frameworks
  • Conduct periodic internal reviews and documentation of risk mitigation measures
  • Timely investor reporting as per SEBI regulations and the PPM
  • Disclosure of fund performance, valuation information, and material risks
  • Sponsor and manager accountability for ethical and compliant fund operations
  • Maintenance of statutory records, investor documents, and compliance registers
  • Use of digital tools to track compliance deadlines and regulatory filing
  • Secure digital storage of investor and regulatory documentation to ensure accuracy and efficiency
  • Retention of records in accordance with SEBI-prescribed timelines
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Annual Compliance Calendar for Alternative Investment Funds Category II

The annual compliance calendar for alternative investment funds category II includes adherence to specific obligations as mandated by the Securities and Exchange Board of India:

Mandatory Compliance Description Regulatory Reference Submission By Submission To Deadline
Digital Accessibility Compliance Ensuring that the AIF’s website and investor-related platforms meet accessibility standards. SEBI (AIF) Regulations, 2012 and IT Guidelines Fund Managers / Compliance Team SEBI / Internal Records Within 1 month of the end of the financial year
Compliance Test Report (CTR) Submission of an independent report verifying adherence to SEBI AIF regulations, including investment conditions and disclosures. SEBI Circular on CTR Fund Managers / Auditors Trustee and Sponsor (trust or other structures) Within 30 days from the end of the financial year
Annual PPM Filing Filing of any changes to the Private Placement Memorandum (PPM), including modifications to fund or scheme documents. SEBI (AIF) Regulations, 2012 Fund or Investment Managers SEBI, Investors Within 30 days from the end of the financial year
PPM Audit Independent audit of the PPM to ensure accuracy of disclosures and fund details. SEBI Circulars on PPM Audit Investment Manager Trustee / Board of Directors / Designated Partners of the Manager / SEBI Within 6 months of the end of the financial year
Statutory Audit Audit of the fund’s books of account by an SEBI-approved auditor. Companies Act, 2013 and SEBI (AIF) Regulations, 2012 Statutory Auditor SEBI / Fund Board Within 6 months from the end of the financial year (ideally May 31st for Form 64D)
Annual Investor Reporting Reporting on financials of investee companies and risk management. Regulation 22(g) of SEBI (AIF) Regulations, 2012 Investment Manager Investors Within 180 days from the year-end or earlier as per fund documents
FATCA / CRS Filing Reporting of financial transactions or reportable accounts for the previous calendar year. Section 285BA of the Income Tax Act, 1961 Investment Manager Income Tax Department Annual, as per FATCA / CRS timelines
Form 64D Income details distributed by the AIF in the previous financial year (excluding business income). Section 115UB and Rule 12CB of the Income Tax Act, 1961 Investment or Fund Manager Income Tax Department Annual / Financial Year End
Form 64C Investor-wise statement of income distributed in the previous financial year. Section 115UB and Rule 12CB of the Income Tax Act, 1961 Investment Manager Income Tax Department Annual / Financial Year End
Income Tax Return Filing of the fund’s income tax return including taxable income and deductions. Section 139 of the Income Tax Act, 1961 Investment Manager Income Tax Department Annual / 30th September (for AIFs under the Companies Act)
Foreign Liabilities and Assets (FLA) Return Reporting of all foreign investments received and made during the previous financial year. FEMA Regulations, 2019 Investment Manager Reserve Bank of India (RBI) On or before 15th July of the financial year following the previous year

Half-Yearly Compliance Calendar for AIF Category II

The half-yearly compliance calendar for AIF category II sets out the mandatory regulatory reporting, disclosures, and certifications, as discussed below:

Mandatory Compliance Description Regulatory Reference Submission By Submission To Deadline
Valuation and Cash Flow Data to Benchmarking Agencies Reporting of all necessary information, including scheme-wise valuation and cash flow data for AIF schemes that have completed at least one year from the date of β€œFirst Close”. Para 16.3.3 and Para 16.4 of the Master Circular (Annexure 14) and Para 4.6 of SEBI Circular No. SEBI/HO/AFD/PoD-1/P/CIR/2024/123 dated September 19, 2024 Investment Manager Performance Benchmarking Agency Within 45 days from the end of the half-year ending 30th September and within 6 months from the end of the half-year ending 31st March
Valuation Report Disclosure of the valuation of investments made by the AIF, including valuation procedures and methodologies used for valuing assets. Regulation 23(1) and 23(2) of SEBI (AIF) Regulations Investment Manager Investors Once every six months (may be annual with 75% investor approval by value)
Half-Yearly Investor Reporting Providing investors with NAV details, portfolio performance, and risk disclosures for the relevant half-year period. SEBI (AIF) Regulations, 2012 and Placement Memorandum Investment Managers Investors Within 45 days from the end of each half-year
Half-Yearly Trustee / Auditor Certification Certification confirming compliance with SEBI regulations, investment conditions, and reporting obligations. SEBI Circulars on AIF Compliance and Trustee Responsibilities Trustee / Auditors SEBI / Investors Within 45 days from the end of each half-year

Quarterly Category II AIF Compliance Calendar

The quarterly Category II AIF compliance calendar sets out the mandatory reporting, disclosures, and tax-related filings as mentioned under SEBI (AIF) Regulations, 2012:

Mandatory Compliance Description Regulatory Reference Submission By Submission To Deadline
Investor Complaint Data Maintenance and quarterly submission of complaint data, which must be updated regularly. Para 17.4 of the Master Circular Investment Manager SEBI / Trustee Within 7 days from the end of each quarter
SEBI Quarterly Activity Report Quarterly report on AIF activities, including portfolio updates and compliance status. SEBI Circulars / SEBI (AIF) Regulations, 2012 Investment Manager SEBI Within 15 days from the end of each quarter
Trustee Compliance Report Quarterly report covering activities and compliance undertaken by the AIF. SEBI (AIF) Regulations, 2012 Investment Manager Trustee Filing deadlines vary for each trustee
TDS Return Filing of TDS returns for income distributions, salaries, and other applicable payments. Income Tax Act, 1961 Investment Manager Income Tax Department Quarterly filing deadlines: Q1 – 31 July, Q2 – 31 October, Q3 – 31 January, Q4 – 31 May
High-Value Immovable Property Reporting (PMLA) Furnishing information on purchases and sales of immovable property valued at β‚Ή50 lakh or more registered by the AIF. Rule 3(f) read with Rule 8(3) of the PMLA Rules, 2005 Principal Officer Director / FIU-IND Within 15 days from the end of each quarter

Monthly Category II Alternative Investment Fund Compliance Calendar

The monthly category II alternative investment fund compliance calendar sets out routine obligations that must be fulfilled every month in the manner discussed below:

Mandatory Compliance Description Regulatory Reference Submission By Submission To Deadline
TDS Payment Payment of Tax Deducted at Source on distributions, salaries, and other applicable payments made by the AIF. Income Tax Act, 1961 Investment Manager Income Tax Department On or before the 7th of the following month to maintain tax compliance
Escrow Reporting Reporting investor-wise KYC details of units held in the aggregate escrow demat account, including name, PAN, and bank account details. SEBI (AIF) Regulations, 2012 Investment Manager Custodian Within 15 days from the end of each month
Cash Transaction Reporting (PMLA) Reporting of all cash transactions, including cross-border wire transfers exceeding β‚Ή5 lakh or its foreign currency equivalent where the origin or destination is India. Rule 3(e) read with Rule 8(1) of the PMLA Rules, 2005 Principal Officer Director / FIU-IND Within 15 days of the succeeding month
Downstream Investment Intimation Intimation required when an AIF makes a downstream investment in another Indian entity, including the modality of investment in new or existing ventures, even if equity instruments have not yet been allotted. Rule 4(11)(a) of FEMA Regulations, 2019 Manager Secretariat for Industrial Assistance (DPIIT) Within 30 days of the downstream investment

Event-Based Compliance Calendar for AIF Category II

The event-based compliance calendar for AIF category II applies upon the occurrence of specific regulatory or transactional events, as discussed below:

Mandatory Compliance Description Regulatory Reference Submission By Submission To Deadline
Filing of Form InVI Filing of Form InVI when an AIF has issued units to a person resident outside India. Rule 4(10) of FEMA Regulations, 2019 Manager RBI (via FIRMS Portal) Within 30 days from the date of issue of units
Filing of Form DI Filing of Form DI when the AIF makes a downstream investment regarded as indirect foreign investment due to non-Indian owned and controlled sponsor or manager. Rule 4(11)(b) of FEMA Regulations, 2019 Manager RBI (via FIRMS Portal) Within 30 days from the date of allotment of equity instruments
Form FC-TRS Filing Reporting transfer of capital instruments of an Indian company between resident and non-resident through an authorised dealer bank. FEMA (Non-Debt Instruments) Rules, 2019 Resident (Transferor or Transferee) RBI Within 60 days of receipt of funds or transfer of instruments, whichever is earlier
Form 15CA / 15CB Filing Certification and reporting of withholding taxes on foreign remittances. Income Tax Act, 1961 Investment Manager Income Tax Department At the time of foreign remittance
FLA Return Reporting of foreign liabilities and assets held by the AIF. Rule 4(2) of FEMA Regulations, 2019 Investment Manager RBI On or before 15th July of the following financial year
ODI Filing Filing related to allocation, utilisation, and disinvestment of overseas investment limits in the prescribed SEBI format. FEMA (Overseas Investment) Rules & RBI Directions Investment Manager SEBI As prescribed for each ODI event
Investor Grievance Redressal Resolution of investor complaints received by the AIF. Regulation 24A(1) of SEBI (AIF) Regulations, 2012 Investment Manager Investors Promptly, but not later than 21 calendar days from the date of receipt
Credit Default Swap Transactions Reporting details of credit default swap transactions entered into by the AIF. RBI / SEBI Guidelines on CDS Investment Manager Custodian By the next working day
Investor-wise KYC Reporting (Escrow Demat Account) Reporting investor-wise KYC details of units held in the Aggregate Escrow Demat Account, including name, PAN, bank account details, and audit trail of transactions. SEBI Circulars / Depository Guidelines Manager Depositories and Custodians Monthly
Reporting of Regulatory Non-Compliance Reporting any non-compliance with SEBI Act, regulations, circulars, or directives. Regulation 20(19) of SEBI (AIF) Regulations, 2012 Compliance Officer SEBI As soon as possible, but not later than seven working days from observation
Update on Material Events / Changes Intimation of any material changes in fund strategy, key personnel, sponsor, or investment policy impacting investors. SEBI (AIF) Regulations, 2012 and SEBI Circulars on Material Disclosures Investment Manager SEBI / Investors Within 30 days of occurrence of the event
Declaration of First Close of Scheme Intimation regarding the first close of the AIF scheme. Regulation 12(4) read with Para 2.3 of the Master Circular Manager SEBI Within 12 months from the date of SEBI communication for taking the PPM on record
Compliance Reporting for Liquidation Scheme Reporting compliance under Chapter 23 of the Master Circular upon exercising liquidation options. SEBI Master Circular on AIFs Manager SEBI As specified at the time of exercising liquidation option
Performance Reporting of Liquidation Scheme Reporting performance of the liquidation scheme. SEBI Performance Benchmarking Guidelines Manager Performance Benchmarking Agency Within 45 days from half-year ending 30th September and within 6 months from half-year ending 31st March

How Enterslice Eases Compliance through SEBI Category II AIF Compliance Calendar?

At Enterslice, we assist category II AIFs with our SEBI Category II AIF compliance calendar in compliance with SEBI (Alternative Investment Funds) Regulations, 2012. From AIF registration to AIF audit and compliance management, we provide end-to-end support. Connect us to build strong goodwill by effectively maintaining accuracy, timelines, and regulatory discipline throughout the fund lifecycle.

  • End-to-end category II AIF compliance management solutions in India
  • Access to a dedicated tax team offering services to the financial service sector
  • Partner-led proactive, pragmatic and solution-oriented approach
  • Assistance with attestation services for evaluating AIF compliance
  • Offers annual tax compliance services for filing of income tax or TDS returns
  • Provide regulatory compliance service for filing FLA return, Form InVi & Form DI
  • Conduct income tax and regulatory due diligence of investee companies
  • Liaison with lawyers, trustees, and fund managers during fund setup
  • Assist in responding to queries raised by SEBI with respect to the application
  • Advice on regulatory matters and taxation of income earned by the AIF
  • Built-in checks and reviews to minimize filing errors and regulatory observations
  • Unified handling of SEBI, FEMA, RBI, Income Tax, and PMLA obligations

FAQs on SEBI Category II AIF Compliance Calendar

Category II AIFs in India are pooled investment vehicles that primarily focus on long-term investments in private companies, structured debt, or real estate. These funds aim for growth by investing in unlisted entities, distressed assets, or other AIFs, providing capital for expansion or restructuring.

Category II AIFs that do not undertake leverage or borrow other than to meet day-to-day operational requirements and as permitted in SEBI (AIF) Regulations, 2012, include various types of funds such as real estate funds, private equity funds, funds for distressed assets, etc.

No, category II AIFs may not borrow funds directly or indirectly and shall engage in leverage except for meeting temporary funding requirements for not more than 30 days.

Fund managers, or alternative investment fund managers, are the ultimate responsible authority for the true and fair valuation of alternative investment assets in India.

A PPM audit is a mandatory annual review for alternative investment funds to ensure their operations align with their private placement memorandum disclosures, covering accuracy, investor reporting, and compliance with SEBI norms.

Yes, AIF fund managers in India must have at least one key personnel in the investment team with a specific SEBI-mandated NISM certification.

The SEBI category II AIF compliance calendar 2026 matters because it serves as a crucial roadmap for fund managers to meet SEBI’s strict rules, ensure legal operations, build investor trust, avoid hefty penalties, manage complex risks, and keep up with India’s evolving AIF market.

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