SEBI Circular on Certification requirement for Compliance Officers of Managers of AIFs

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Date of Issue: 30-12-2025  
          
Issuer: SEBI

Certification requirement for Compliance Officers of Managers of AIFs

Highlights of  SEBI Circular dated December -30 -2025

New Certification Requirement

SEBI has now specified a mandatory certification requirement for Compliance Officers of AIF Managers.

Mandatory NISM Certification

• The Compliance Officer must obtain certification from the National Institute of Securities Markets (NISM).
  
  
• Specifically, the individual must pass:

• • NISM Series III-C: Securities Intermediaries Compliance (Fund) Certification Examination.
    
    
  • This requirement is aligned with the NISM communique dated November 20, 2025.

Applicability and Timeline

Effective date for appointment/continuation:

From January 1, 2027, only individuals who have obtained the above NISM certification:

• May be appointed as Compliance Officers, or
  
  
• May continue to act as Compliance Officers of AIF Managers.

This provides a transition period for existing Compliance Officers to acquire the certification.

Compliance and Reporting Obligations

• The trustee / sponsor / manager of the AIF, as applicable, must ensure compliance with this circular.
  
  
• The requirement must be explicitly covered in the “Compliance Test Report”, which is prepared by the Manager under:
  
  
  • Paragraph 15.2 of the SEBI Master Circular dated May 7, 2024.
    
    
• This effectively makes certification status a part of periodic regulatory compliance reporting.

Effective Date of the Circular

The circular comes into force immediately (i.e., from December 30, 2025).

However, the operational requirement for certified Compliance Officers applies from January 1, 2027.

Practical Impact

For AIF Managers:

• Need to review current Compliance Officer qualifications.
  
  
• Plan certification for existing officers well before January 1, 2027.

For Compliance Officers:

• Passing the NISM Series III-C exam becomes a statutory eligibility requirement.

For Governance:

• Enhances professional standards and accountability in AIF compliance functions.
  
  In case of any clarification or assistance required in the implementation of this circular, you may contact : Kaushik Jethwa at kau...@secmark.in and 9870210171