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What is a Category III AIF Compliance Calendar?

If you are operating a category III alternative investment fund in India, compliance with the SEBI (Alternative Investment Funds) Regulations, 2012, is critical given the heightened regulatory scrutiny. The Category III AIF compliance calendar further ensures adherence to SEBI-prescribed leverage limits, risk management norms, valuation standards, investor disclosures, and periodic regulatory reporting.

In simple terms, the category III AIF compliance calendar further enables fund managers and sponsors to systematically monitor frequent reporting obligations, valuation reporting, investor communications, audits, certifications, and regulatory notifications. Talk to our AIF compliance experts at Enterslice to ensure accurate and timely management of your category III AIF compliance calendar in strict alignment with SEBI’s evolving regulatory framework and get an AIF audit done.

Quarterly Regulatory Reporting to SEBI

Ongoing Investor Reporting & Mandatory Disclosure

Custodian and Clearing Corporation Reporting

Ongoing Oversight by a Designated Compliance Officer

Category III AIF (Commitments Raised)- Rs 2,92,398 Crore

Category III AIF (Funds Raised)- Rs 1,77,982 Crore

Category III AIF (Investments Made)- Rs 1,97,335 Crore

Cat III AIF (Investments in Listed Securities)- Rs 1,59,576 Crore

Cat III AIF (Investments in Unlisted Securities)- Rs 7,977 Crore

Why is keeping a Track of SEBI Category III AIF Compliance Calendar required?

Managing the SEBI Category III AIF Compliance Calendar is essential because of the following reasons, as discussed below:

Build Investor Trust

A well-managed compliance calendar ensures timely disclosure, accurate reporting, and adherence to SEBI norms, thereby enhancing investor trust and confidence in category III AIF.

Risk Mitigation

Regular management of the category III AIF compliance calendar helps identify and control risks related to leverage, derivatives exposure, and market volatility, thereby reducing the likelihood of regulatory and operational failures.

Ensure Transparency

A structured category III AIF compliance calendar ensures transparent reporting of NAV, portfolio exposure, fees, and material changes, as mandated under SEBI AIF Regulations.

Maintain Market Stability

SEBI category III AIF compliance calendar helps maintain regulatory oversight by ensuring timely reporting, adherence to exposure and risk parameters, thereby supporting overall market stability.

Ensure Regulatory Adherence

The management of the category III AIF compliance calendar is subject to stricter reporting and disclosure norms for disclosure and event-based intimations to SEBI.

Operational Discipline and Governance

Maintaining a category III alternative investment fund compliance calendar strengthens internal controls, the risk management system, the governance framework, and key management personnel.

Avoid Penalties and SEBI Observations - Stay Compliant with Real-Time Category III AIF Monitoring.

Annual Compliance Calendar for Alternative Investment Funds Category III

The annual compliance calendar for alternative investment funds category III includes compliance with obligations prescribed under the SEBI (AIF) Regulations, 2012. Some of them are discussed below:

Mandatory Compliance	Description	Regulatory Reference	Submission By	Submission To	Deadline
Digital Accessibility Compliance	Confirmation of compliance with SEBI’s digital accessibility requirements	SEBI Circular on Digital Accessibility	Investment Manager	SEBI	Within 1 month of the end of the financial year
Compliance Test Report (CTR)	Submission of Compliance Test Report in the format shared by the Trustee/ Sponsor	Para 15.2 of the Master Circular	Investment Manager	Trustee and Sponsor	Within 30 days from the end of the financial year
Annual PPM Filing	Consolidated filing of the revised PPM with SEBI and Investors. A Merchant Banker certificate may be required for certain modifications.	Para 2.5.2 and Para 17.2 of Master Circular (Annexure 15)	Investment Manager	SEBI / Investors	On a consolidated basis, within 1 month of the end of each financial year
PPM Audit	Annual audit of compliance with terms of the PPM	Para 2.4.2 of Master Circular	Investment Manager	Trustee / Board of Directors / Designated Partners / SEBI	Within 6 months of the end of the financial year
Statutory Audit	Audit of the books of account of the AIF	Regulation 20(14) of SEBI (AIF) Regulations, 2012	Statutory Auditor	Investment Manager	Within 6 months from the end of the financial year (ideally by May 31st for Form 64D)
Annual Investor Reporting	Report on the financials of investee companies and risk management	Regulation 22(g) of SEBI (AIF) Regulations, 2012	Investment Manager	Investors	As per PPM, generally within 60 days from the end of the quarter or earlier, as per fund documents
FATCA / CRS Filing	Report of financial transactions or reportable accounts for the previous calendar year	Section 285BA of the Income Tax Act, 1961	Investment Manager	Income Tax Department	On or before 31st May of the relevant year
Income Tax Return (AIF)	Filing of the income tax return of the AIF for the previous financial year	Section 139 of the Income Tax Act, 1961	Investment Manager	Income Tax Department	On or before 30th November (subject to extensions)
Valuation Disclosure	Disclosure of details regarding valuation of investments based on valuation methodologies and approaches, including changes therein	Regulation 23(6) of the AIF Regulations and Para 22.2.3 of the Master Circular	Manager	SEBI / Investors	On a consolidated basis, within 1 month of the end of each financial year
Annual SEBI Reporting on Leverage & Risk	Annual consolidated reporting of leverage, exposure and risk parameters	SEBI AIF Master Circular (Category III reporting)	Investment Manager	SEBI	Along with annual filings / as specified by SEBI

Manage NAV, PPM Filings, Tax, FEMA, and PMLA Reporting with One Platform.

Half-yearly SEBI Category III AIF Compliance Calendar

The half-yearly SEBI Category III AIF compliance calendar sets out the mandatory regulatory reporting, disclosures, and certifications as prescribed by SEBI (AIF) Regulations, 2012, as discussed below:

Mandatory Compliance	Description	Regulatory Reference	Submission By	Submission To	Deadline
Valuation and Cashflow Data to Benchmarking Agencies	Reporting of necessary information, including scheme-wise valuation and cash flow data for the schemes of AIF, completed at least 1 year from the date of First Close	Para 16.3.3 and Para 16.4 of the Master Circular (Annexure 14)	Investment Manager	Benchmarking Agencies	Within 45 days from the half-year ending September 30 and within 7 months for the half-year ending March 31
Trustee / Board Reporting	Submission of the compliance and operational review report	SEBI (AIF) Regulations & Trust Deed / LLP Agreement	Investment Manager	Trustee / Board of Directors / Designated Partners	Half-yearly
Half-Yearly Portfolio Disclosure to Investors	Disclosure of portfolio holdings, leverage, exposure, and risk metrics	Regulation 22 & SEBI Master Circular (Category III disclosures)	Investment Manager	Investors	As per PPM, generally within 45 days from the end of the half-year

Quarterly Category III Alternative Investment Fund Compliance Calendar

The quarterly category III alternative investment fund compliance calendar covers mandatory filings as specified under SEBI (AIF) Regulations, SEBI Master Circulars, Income Tax Act, and the PMLA Rules:

Mandatory Compliance	Description	Regulatory Reference	Submission By	Submission To	Deadline
Investor Complaint Data	Maintenance and quarterly submission of complaint data. This has to be updated in the PPM annexure as well.	Para 17.4 of Master Circular	Investment Manager	Investors	Within 7 days from the end of each quarter
SEBI Quarterly Activity Report	Submission of the quarterly report on the activities of the AIF	Para 15.1.1 of SEBI Master Circular	Investment Manager	Investors / SEBI	Within 15 calendar days from the end of each quarter
Trustee Compliance Report	Quarterly report on the activities and compliance undertaken by the AIF	SEBI AIF Regulations / Trust Deed	Investment Manager	Trustee	The filing deadline for the Trustee Compliance Report differs for each trustee
Disclosure of Net Asset Value	Undertake calculation and disclosure of net asset value. For Category III AIFs, valuation of investments in unlisted securities and listed debt securities must be done by an independent valuer.	Regulation 23(3) of SEBI (AIF) Regulations, 2012	Investment Manager	Investors	Quarterly for close-ended funds and not longer than a month for open-ended funds
TDS Return	Quarterly filing of TDS returns for tax deducted	Income Tax Act, 1961	Investment Manager	Income Tax Department	As per quarterly due dates prescribed under the Act
Advance Tax	Payment of advance tax on income, if applicable	Income Tax Act, 1961	Investment Manager	Income Tax Department	15 June, 15 September, 15 December, 15 March
PMLA Reporting – Immovable Property Transactions	Furnish information in respect of all purchases and sales of immovable property valued at fifty lakh rupees or more that is registered by the AIF, as applicable.	Rule 3(F) read with Rule 8(3) of the PMLA Rules, 2005	Principal Officer	FIU-IND (Director)	Within 15 days of the end of the quarter

Monthly Compliance Calendar for Category III Alternative Investment Fund

The monthly compliance calendar for category III alternative investment fund outlines routine statutory and regulatory obligations, as discussed below:

Mandatory Compliance	Description	Regulatory Reference	Submission By	Submission To	Deadline
TDS Payments	Deposit of tax deducted at source on payments such as management fees, professional fees, salaries, interest, or other applicable payments	Income Tax Act, 1961	Investment Manager	Income Tax Department	On or before the 7th of the following month
Investor-wise Escrow Demat Reporting	Reporting of investor-wise KYC details of units held in the Aggregate Escrow Demat Account, including name, PAN and bank account details, along with the audit trail of the transactions	SEBI Circulars on Dematerialization of AIF Units	Manager	Custodians and Depositories	Within 15 days from the end of each month
NAV Calculation & Disclosure	Calculation of Net Asset Value (NAV) of the scheme as per valuation norms	SEBI Circulars on Valuation of AIFs	Manager	Investors and Custodians	At least monthly (or more frequently, as applicable)
Leverage Monitoring & Reporting	Monitoring compliance with leverage limits and internal risk thresholds applicable to Category III AIFs	Regulation 21 of SEBI (AIF) Regulations, 2012	Manager	Internal Records / Custodian	Ongoing (reviewed monthly)
Custodian Reconciliation	Reconciliation of portfolio holdings, leverage positions, margins, and cash balances with the custodian	SEBI (AIF) Regulations, 2012 and Custodian Guidelines	Manager	Custodian	Monthly
Compliance with Investment Restrictions	Review of adherence to scheme-level investment strategy, concentration norms, and risk limits	SEBI (AIF) Regulations, 2012 & PPM	Manager	Internal Compliance Records	Monthly review

Event-Based Category III AIF Compliance Calendar

The event-based category III AIF compliance calendar applies upon the occurrence of specific regulatory or transactional events mentioned under SEBI (AIF) Regulations:

Mandatory Compliance	Description	Regulatory Reference	Submission By	Submission To	Deadline
ODI Filings	AIF shall furnish the sale/divestment details of the overseas investments to SEBI	Para 7.2.1 of SEBI (ODI) Master Circular	Investment Manager	SEBI	As and when ODI transaction occurs
Systemic Risk Information	Submission of information for systemic risk purposes including identification, analysis, and mitigation of systemic risks	Regulation 22(j) of SEBI (AIF) Regulations, 2012	Investment Manager	SEBI	As and when required by SEBI
Investor Grievances	Reporting of investor complaints and their resolution	Regulation 24A(1)	Investment Manager	Investors	Promptly, but not later than 21 calendar days from receipt
Conflicts of Interest	Disclosure of conflicts of interest and their management in the PPM and through separate communication	Regulation 21(1) and Para 5.3.4 of the Master Circular	Investment Manager / Sponsor	Investors	As and when conflict occurs; disclose to SEBI if required
Unhedged CDS Positions	Intimation where gross unhedged CDS positions exceed 25% of investable funds	Para 9.3.5 of the Master Circular	Investment Manager	Investors	As and when occurred
Leverage Breach	Reporting of breach of leverage limits along with reasons	SEBI (AIF) Regulations, 2012	Investment Manager	Investors / SEBI	Immediately upon occurrence
Credit Default Swap Transactions	Reporting details of credit default swap transactions	Para 9.3.1 of the Master Circular	Investment Manager	Investors	By the next working day
CDS Exposure Breach	Reporting where earmarked securities fall below CDS exposure	Para 9.3.4 of the Master Circular	Investment Manager	Custodian	Same day as breach
CDS Breach Rectification	Reporting details of rectification of CDS exposure breach	Para 9.3.4 of the Master Circular	Investment Manager	Custodian	By the end of the next trading day
Concentration Norms Breach	Reporting when investment exceeds limits under Regulation 15(1)(d)	Para 5.1.3 of the Master Circular	Investment Manager	SEBI / Investors	Within 30 days of the breach
Form InVi Filing	Mandatory FEMA reporting for Investment Vehicles receiving foreign investment	FEMA (Non-Debt Instruments) Rules, 2019 & RBI Circular dated 23-May-2025	Investment Manager	RBI	Within 30 days from issue of units
Form DI Filing	Downstream investment reporting where Manager or Sponsor is foreign owned or controlled	FEMA (Non-Debt Instruments) Rules, 2019	Investment Manager	RBI	Within 30 days from the date of allotment
FLA Return	Annual reporting of foreign liabilities and assets received or made	Rule 4(2) of FEMA Regulations, 2019	Investment Manager	RBI	On or before 15 July of the following financial year
Reporting of Investments under Custody	Reporting of data on investments of AIFs under custody	Regulation 20(11) read with Para 15.4 of the Master Circular	Custodian	SEBI	As and when required
Reporting Non-Compliance	Reporting any non-compliance with SEBI laws, rules, or circulars	Regulation 20(19)	Compliance Officer	SEBI	Within 7 working days of observation
Filing Client KYC Records	Electronic filing of client KYC records	Rule 9(1-A) of PMLA Rules, 2005	Manager	Central KYC Records Registry	Within 10 days of account-based relationship commencement
Reporting Cash and Suspicious Transactions	Reporting of all cash and suspicious transactions	Rule 3(D) read with Rule 8(2) of PMLA Rules, 2005	Principal Officer	Director	Immediate
Principal Officer & Designated Director Reporting	Intimation of appointment and details of Principal Officer and Designated Director	Rule 7(1) of PMLA Rules, 2005	Manager	Director, FIU-India	Immediate

Why Trust Enterslice for SEBI Category III AIF Compliance Calendar?

At Enterslice, we help category III AIFs effectively manage their compliances through our SEBI Category III AIF compliance calendar, thereby ensuring adherence to the SEBI (AIF) Regulations, 2012 and other regulatory frameworks. From AIF registration to AIF compliance management and audit, we provide end-to-end support. Connect with us to maintain accuracy, timeliness, and complete regulatory AIF compliance across the entire fund lifecycle.

Comprehensive Category III AIF compliance management solutions
Dedicated team with tax and regulatory expertise in RBI, PMLA, and SEBI regulations
Partner-led guidance to reduce operational and regulatory risks
Support for PPM audits, NAV audits, statutory audits, and compliance test reports
Conduct regulatory, tax, and financial due diligence of investee companies
Query resolution expertise related to filings, disclosures, or regulatory requirements
Minimize filing errors and reduce chances of SEBI observations or penalties
Integrated SEBI, FEMA, RBI, Income Tax, and PMLA compliance handling
Tracks 50+ regulatory timelines for Category III AIFs to ensure no filing is delayed
Support for cross-border investments, ODI filings, and FEMA reporting obligations
15+ years of combined expertise across Category III AIF structuring and compliance
99% proven track record in Category III AIF compliance management

Frequently Asked Questions on Category III AIF Compliance Calendar

Category III AIF refers to India’s SEBI-regulated funds that use complex trading, leverage, and derivatives for short-term, absolute returns, and differ from simpler Category I and Category II funds.

The key compliance requirements for category III AIF are periodic reporting, quarterly reporting, private placement memorandum, independent valuation, NAV reporting, cybersecurity and cyber resilience, and SCORES registration.

The minimum corpus for category III AIFs in India is around Rs 20 crores per scheme, thereby requiring diverse trading strategies for short-term gains.

Yes, category III AIFs can use leverage, and their key feature, like a vehicle, is permitted by the Securities and Exchange Board of India.

Income from category III AIF is primarily taxed at the fund level, meaning the fund itself pays the tax before distributing the net returns to investors.

Category III AIF Compliance Calendar

What is a Category III AIF Compliance Calendar?

SEBI Category III AIF Compliance Calendar: Track, Monitor, and Meet All Regulatory Deadlines