SEBI (Alternative Investment Funds) (Second Amendment) Regulations, 2026: First Scheme Fee Exemption and 10-Working-Day Filing Timeline Explained

SEBI (Alternative Investment Funds) (Second Amendment) Regulations, 2026: First Scheme Fee Exemption and 10-Working-Day Filing Timeline Explained

Notification: SEBI (Alternative Investment Funds) (Second Amendment) Regulations, 2026 Date of Notification: 14 July 2026

Effective Date: 14 July 2026

Introduction

The Securities and Exchange Board of India (SEBI) has notified the SEBI (Alternative Investment Funds) (Second Amendment) Regulations, 2026, effective 14 July 2026, bringing in some important procedural changes for Alternative Investment Funds (AIFs).

The amendments mainly focus on:

• Exempting the first scheme launched by an AIF from scheme filing fees.
• Cutting down the advance filing period from 30 days to 10 working days before a scheme is launched.
• Adjusting the scheme filing and review process to make compliance simpler and quicker.

What is an Alternative Investment Fund (AIF)?

An Alternative Investment Fund (AIF) is a privately pooled investment vehicle registered with SEBI that raises funds from investors for investment according to a defined investment policy.

AIFs are regulated under the SEBI (Alternative Investment Funds) Regulations, 2012 and are broadly classified into:

• Category I AIF
• Category II AIF
• Category III AIF

Key Amendments Introduced

1. Exemption from Scheme Filing Fee for the First Scheme

 Earlier Position

Every AIF launching a scheme had to file its Placement Memorandum with SEBI along with the prescribed scheme filing fee.

Position after the Amendment

A new proviso has been inserted under Regulation 12(1) stating that:

The payment of scheme filing fees shall not apply in the case of the launch of the first scheme by an Alternative Investment Fund.

Practical Impact

• Newly registered AIFs launching their first scheme no longer need to pay the scheme filing fee.
• This brings down the initial compliance cost for new fund managers.
• Filing fees still apply for subsequent schemes, as prescribed by SEBI.

2. Filing Timeline Reduced from 30 Days to 10 Working Days

One of the most significant changes here is to Regulation 12(2).

Earlier Requirement

The Placement Memorandum had to be filed with SEBI at least 30 days before the scheme’s proposed launch.

Revised Requirement

The amendment replaces “thirty days” with “ten working days.” The Placement Memorandum must now be filed with SEBI at least ten working days prior to the launch of the scheme.

Why this Matters

This change:

• Shortens the pre-launch waiting period.
• Allows for quicker fund launches.
• Improves operational efficiency for AIF managers.
• Supports ease of doing business while SEBI’s regulatory oversight stays intact.

3. Documents Instead of Filing Fees

SEBI has also amended Regulation 12(2) by replacing the earlier reference to filing fees with documents specified by the Board.

In other words, the emphasis shifts from simply paying a fee to making sure the required documentation is actually submitted in the prescribed manner.

4. SEBI’s Review Process

Regulation 12(3) has been substituted to make clear that:

• Once the required documents are filed, SEBI may communicate its comments, if any, to the merchant banker or the Manager.

This gives the regulatory review mechanism before a scheme’s launch a bit more clarity.

Comparison: Before vs After the Amendment

Benefits of the Amendment

The amendment brings several advantages:

For AIF Managers

• Lower initial compliance cost, thanks to the fee exemption on the first scheme.
• Faster launch timelines, with the shorter advance filing period.
• Greater operational flexibility overall.

For Investors

• Faster introduction of new investment schemes.
• A more streamlined regulatory process, without compromising investor protection.

For the Industry

• Promotes ease of doing business.
• Encourages the setting up of new AIFs.
• Simplifies procedural compliance.

Compliance Checklist

AIF managers should:

• Check whether the proposed launch is genuinely the first scheme, which would make it eligible for the fee exemption.
• Make sure the Placement Memorandum and all documents specified by SEBI are filed.
• Complete the filing at least ten working days before the proposed launch.
• Review and address any comments received from SEBI before going ahead with the scheme launch.

Conclusion

The SEBI (Alternative Investment Funds) (Second Amendment) Regulations, 2026 bring in meaningful procedural reforms — exempting an AIF’s first scheme from the scheme filing fee, and cutting down the advance filing requirement from 30 days to 10 working days.

These changes are expected to lower compliance costs, shorten fund-launch timelines, and make India’s AIF framework more efficient, all while SEBI keeps its oversight in place through its document review and comments process.

For fund managers and compliance professionals, this amendment marks an important step toward a more streamlined, business-friendly regulatory environment.