SEBI compliance reports: the monthly and quarterly cadence

An AIF in India has a compliance calendar that runs continuously across the fund's life. Monthly filings, quarterly filings, half-yearly filings, annual filings, ad-hoc filings on specific events. The cadence is fully prescribed by SEBI and the calendar is well documented. The compliance officer's job is to deliver against it without fail.

Most funds we work with handle the routine cadence well after the first year. The interesting question is where compliance fails — not by deliberate decision but by operational drift. This article walks through the calendar, identifies the five common failure modes, and explains why even funds with good compliance teams stumble on them.

The monthly cadence

NAV reporting. Monthly under the 2025 amendment. Due by the 10th of the following month. Submitted via the SEBI Intermediary Portal. Format includes NAV per unit, total fund AUM, and a summary of material movements.

Transaction reporting. Specific transactions (significant follow-ons, exits, related-party transactions) need to be reported via the portal within specified windows, typically 7 days for material transactions.

Leverage reporting (Cat III only). Monthly leverage report for Cat III AIFs, including gross leverage, net leverage, and the calculation methodology. Due by the 10th of the following month.

Custodian reconciliation. While not a SEBI filing, the monthly custodian reconciliation is a foundational compliance function. The fund administrator reconciles the custodian's records to the fund's books each month.

The quarterly cadence

Investor disclosure report. Quarterly LP report under the expanded 2025 standards. Includes NAV, deal-by-deal valuation, portfolio company financial summary, risk factor disclosure, and fee/expense reconciliation. Due within 60 days of quarter-end.

Compliance certificate. Quarterly certificate from the compliance officer confirming that the fund has complied with the AIF Regulations and the SEBI circulars. Submitted to the trustee (where applicable) and retained in the fund's records.

Governance reporting. Quarterly summary of IC meetings, valuation committee meetings, audit committee meetings, and any escalations.

Related party transactions. Quarterly disclosure of any transactions involving the GP, the GP's principals, or related entities.

The half-yearly cadence

Governance review. Half-yearly review by the IC, the valuation committee, and the audit committee of the fund's governance practices. Documented as a half-yearly governance report.

Compliance review. Half-yearly review by the compliance officer of the fund's compliance history, including any reportable incidents, regulatory observations, or LP complaints.

The annual cadence

Audited accounts. Audited annual accounts of the fund, prepared in accordance with Ind AS and audited by a SEBI-registered auditor. Due within 180 days of the fund's financial year-end (typically September 30 for funds with March 31 year-end).

Sponsor commitment certificate. Annual certificate from the GP confirming that the sponsor commitment (2.5% or ₹5 crore for Cat I/II; 5% or ₹10 crore for Cat III) is in place and funded.

Regulatory observation status. Annual report on any SEBI examination observations from the prior year and the fund's response status.

PPM update. Annual review of the PPM to confirm continued accuracy. Material changes need a formal amendment filed with SEBI.

The ad-hoc cadence

Specific events trigger ad-hoc filings:

1. Change in key personnel. Within 15 days.

2. Change in sponsor or GP. Subject to SEBI prior approval.

3. Change in fund structure. Subject to SEBI prior approval.

4. Material breach of the AIF Regulations. Within 7 days.

5. LP complaint requiring escalation. Within prescribed timelines.

The five common failure modes

1. Missed monthly NAV deadlines. The 10th-of-the-following-month deadline is tight when the valuation process is heavy. Funds that try to do a full quarterly-quality valuation each month run out of time. The standard solution (discussed in our NAV article) is to do an event-based monthly NAV with a full quarterly revaluation. Funds that do not have this hybrid process in place miss deadlines in months where significant events happen.

2. Custodian reconciliation lapses. The custodian reconciliation is a foundational compliance function. When it lapses, the downstream filings (NAV, governance, audit) lose their basis. Funds with weak operational discipline often have custodian reconciliations that drift — small differences accumulate, larger differences appear, and the reconciliation becomes a backlog rather than a routine.

3. KMP register stale. The Key Managerial Personnel register needs to reflect the current set of fund personnel. When team members join or leave, the register needs to be updated within 15 days. Funds that have high team turnover (or that have been operating for several years with informal personnel changes) often have stale KMP registers. The issue surfaces during SEBI examinations.

4. KYC database stale. LP KYC data needs to be refreshed periodically — typically every 2-3 years for individual LPs and every 5 years for institutional LPs. The KYC refresh is a substantial operational effort and many funds let it slip. The issue surfaces during a SEBI examination or, more commonly, during a fund administrator transition where the new administrator demands fresh KYC.

5. Board meeting minutes filed late. IC minutes, valuation committee minutes, audit committee minutes all need to be documented and filed within prescribed windows. Funds that produce minutes informally (verbal summaries, late finalisations) often have minute books that are incomplete or out of order. The issue surfaces during the annual audit and can lead to qualified audit opinions.

The compliance officer's role

Every AIF needs a designated compliance officer. The role is mandatory under the AIF Regulations and the compliance officer is personally accountable for the fund's regulatory filings.

The compliance officer's responsibilities:

1. Maintain the compliance calendar.

2. Coordinate with the fund administrator on monthly and quarterly filings.

3. Coordinate with the auditor on annual filings.

4. Liaise with SEBI on examinations and queries.

5. Maintain the fund's compliance documentation.

6. Train the fund team on compliance requirements.

For small funds (corpus under ₹500 crore), the compliance officer is often a single individual with a portfolio of other operational responsibilities. For larger funds, the compliance officer is supported by a compliance team.

The compliance calendar tool

Funds that handle compliance well have a structured calendar tool. The standard tool covers:

1. Monthly filings list with due dates.

2. Owners for each filing.

3. Status tracking (not started, in progress, completed, filed).

4. Documentation references for each filing.

5. Escalation paths for missed deadlines.

The tool is typically a spreadsheet or a basic compliance management software. The choice of tool matters less than the discipline of maintaining it. Funds that maintain the calendar with daily updates rarely miss deadlines. Funds that update the calendar weekly or less often start drifting on monthly NAV and quarterly disclosures.

What 2026 likely brings

Three changes to watch for the 2026 compliance calendar:

Accreditation reporting. With the expected accreditation framework changes, AIFs will likely need to file periodic reports on LP accreditation status. The frequency and format are unclear but the requirement is highly likely.

ESG reporting. If the 2026 ESG mandate lands as expected, annual ESG reporting will be added to the compliance calendar for Cat I and Cat II AIFs.

KMP register expansion. If the KMP definition is expanded to include senior investment professionals, the KMP register will become a more substantial document and will require more frequent updates.

One calendar, many filings, zero error tolerance

The AIF compliance calendar is the operational backbone of the fund's regulatory life. The cadence is well-defined and the filings are well-documented. The compliance work is straightforward when the operational discipline is in place and unforgiving when it is not. We work through this with funds during operational reviews and the conversation typically focuses on the five failure modes above — funds that fix them tend to have clean compliance histories, and funds that do not tend to have rolling backlog problems that worsen over time. The investment in compliance discipline is small compared to the cost of a SEBI examination that finds substantive issues.