What is a Compliance Test Report for AIF?

A compliance test report for AIF is a mandatory annual regulatory filing required by the Securities and Exchange Board of India. The SEBI AIF compliance test report confirms whether the AIF has complied with applicable SEBI regulations, circulars, Private Memorandum disclosures, and investment conditions during the relevant financial year.

The preparation of the compliance test report for AIF simply serves as a comprehensive verification that the fund has adhered to all applicable regulations and circulars throughout the financial year. Connect with Enterslice to ensure your SEBI AIF compliance test report is prepared accurately, duly certified, and filed within the SEBI-prescribed timelines.

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Let our experts handle the preparation and certification of the SEBI AIF Compliance Test Report with complete accuracy and on-time submission.

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Know the Scope of Compliance Test Report for Alternative Investment Fund?

The scope of a compliance test report for alternative investment fund, which showcases a snapshot of the fund’s operational and financial status, covers the following:

  • Investment Limits :- Verification that the alternative investment funds adhere to SEBI-prescribed investment limits, diversification norms, sectoral exposure rules, and approved investment strategies.
  • Conflict of Interest Governance :- Evaluation of governance mechanisms, including conflict of interest policies, fee structures, the functioning of trustees, and controls over related-party transactions.
  • Valuation & Accounting Practices :- Confirmation that asset valuation is conducted by an independent valuer at the prescribed frequency, in compliance with SEBI guidelines and the fund’s disclosed valuation policies.
  • Disclosure & Reporting Compliance :- Verification that all material changes, periodic disclosures, financial statements, and performance information are accurately reported to SEBI and investors as mandated.
  • Adherence to PPM Disclosure :- Assessment of whether the fund’s operations and activities are fully aligned with the terms, conditions, and representations made in the Private Placement Memorandum (PPM).

What are the Benefits of Preparing SEBI AIF Compliance Test Report?

The merits of preparing the SEBI AIF compliance test report are discussed below:

Build Investor Trust & Confidence

Preparing the SEBI AIF compliance test report confirms that the fund’s adherence to its stated investment strategy builds investor confidence among high-end wealth and institutional investors.

Risk Mitigation

Preparing the compliance test report for AIF helps identify, manage, and reduce operational, financial, and compliance risks, particularly those related to investment limits and valuation norms.

Ensure Regulator Adherence

Preparing a duly certified compliance test report for AIF confirms compliance with SEBI’s regulatory, reporting, and disclosure norms, thereby helping the fund avoid severe consequences.

Validate Asset Valuation and NAV

Preparing a transparent & auditor-certified compliance test report ensures that the valuation of portfolio investments is fair, independent, and compliant with prescribed standards.

Ensure Alignment with PPM

Preparing the SEBI AIF compliance test report confirms that the fund manager is operating within the investment guidelines and strategies originally promised to investors in the Placement Memorandum.

Promote Operational Transparency

Preparing the compliance test report for AIF helps promote accountability by ensuring that all material changes, fees, and expenses are accurately reported.

When is the Alternative Investment Fund Compliance Test Report Submitted?

The timeline required for the preparation and the submission of the alternative investment fund compliance test report in India is as discussed below:

AIF Structured as a Trust: Within 30 Days

Where the AIF is structured as a trust, the CTR must be submitted to the trustee and the sponsor within 30 days of the end of the financial year.

Observation or Comment on CTR: Within 30 Days

If the trustee or sponsor records any observation/ comment on the CTR, the same must be intimated to the fund manager within 30 days of receipt of the CTR.

Rectification by the Manager: Within 15 days

Upon receipt of observation or comments, the AIF manager shall make necessary corrections or clarifications within 15 days and update the CTR accordingly.

Reporting of Regulatory Violations: Immediate

If the trustee of sponsor identified any violation of SEBI AIF regulations or related circulars issued thereunder is observed by the trustee or sponsor, the same shall be intimated to SEBI as soon as possible.

 

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Challenges Faced While Submitting Compliance Test Report for AIF

The AIF managers submitting the compliance test report for AIF face the following challenges, as discussed below:

  • Meeting Strict Reporting Deadlines :- Delays in meeting the strict timelines for preparation, review, and rectification of the compliance test report as prescribed by SEBI.
  • High Regulatory Complexity :- Challenges arising from frequent amendments to SEBI regulations and the Master Circular governing Alternative Investment Funds.
  • Compliance with Standardized Format :- Difficulties in ensuring compliance with the standardized reporting format prescribed under Annexure 12 of the SEBI Master Circular for AIFs.
  • SEBI Intermediary Portal Usage :- Technical or procedural challenges in filings through the SEBI Intermediary (SI) Portal, which may result in delays or resubmissions.
  • Complexity in Valuation & Asset Reporting :- Challenges in adhering to the updated valuation and asset reporting framework, particularly for illiquid or unlisted assets held by AIFs.
  • Lack of Expertise :- Newly registered AIFs often lack internal expertise to navigate the stringent compliance, reporting, and AIF audit requirements.

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Why Trust Enterslice to Prepare a Compliance Test Report for AIF?

As a leading consulting and India’s Number 1 AIF compliance management firm, we at Enterslice ensure the preparation and submission of the SEBI-mandated AIF compliance test report with precision and accuracy. Here’s why connecting to Enterslice is considered the best choice for preparing a compliance test report for AIFs in India:

  • End-to-end CTR preparation and coordination, from data review to final certification
  • 10,000+ regulatory, financial, and compliance experts supporting SEBI-regulated entities
  • Multi-level compliance checks to minimize errors, revisions, and regulatory observations
  • Cost-effective CTR solutions tailored for Category I, II, and III AIFs
  • Experience in handling SEBI queries, inspections, and post-CTR follow-ups
  • Expertise in SEBI AIF Regulations and circulars governing Compliance Test Reports
  • 100% CTR coverage across investment limits, valuation norms, governance, and disclosures
  • Coordination with Chartered Accountants/ SEBI-registered professionals for certification
  • Proactive identification of compliance gaps before regulatory escalation
  • Offers ongoing support to ensure audit-ready compliance documentation
  • Ensures timely coordination with trustees and sponsors for CTR review and comments
  • SEBI-aligned CTR formats used to reduce rejection and clarification risk
  • 30-day turnaround framework aligned with SEBI’s post-financial-year CTR timelines

Frequently Asked Questions on Compliance Test Report for AIF

CTR in AIF stands for Compliance Test Report, a mandatory document prepared in addition to the quarterly report that confirms the funds have operated in full compliance with SEBI’s regulations throughout the year.

A compliance officer in an AIF ensures that the fund manager adheres to SEBI regulations and other laws, acting as the primary monitor of legal compliance, developing policies, conducting internal checks, managing disclosures, and reporting non-compliance.

AIF audit and compliance is subject to an annual audit of the Private Placement Memorandum by a qualified auditor, filings of audited financial & compliance certifications, with specific NISM certification for Compliance Officers, and regular investor reporting and valuation, all under SEBI’s AIF Regulations.

A compliance test report for AIF in India is a mandatory annual report for SEBI-regulated AIFs, that certified the fund manager’s adherence to AIF regulations and related circulars. It further ensures transparency, investor protection, proper governance, and risk mitigation for all investors and regulators, and verifies operational practices such as valuation, disclosures, and ethical practices.

In India, the manager of an Alternative Investment Fund is responsible for preparing and submitting the Compliance Test Report (CTR).

Yes, the format for the SEBI AIF Compliance Test Report is fixed and standardized, subject to periodic revisions by the authorities. The fixed format further ensures uniformity in reporting across the industry, often leading to collaborations with associations like IVCA.

SEBI AIF compliance test report in India is independently prepared and certified by a SEBI-registered Merchant Banker, a Chartered Accountant, or a Designated Compliance Officer to ensure regulatory accuracy and transparency.

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