The International Financial Services Centres Authority (“IFSCA”), in exercise of the powers conferred under Section 12 of the International Financial Services Centres Authority Act, 2019, read with Regulation 6 and Regulation 15 of the IFSCA (TechFin and Ancillary Services) Regulations, 2025 (“TAS Regulations”), vide Circular No. eF.No. IFSCA-GIC/1/2024-CM,[1] dated July 31, 2025, introduced a Common Application Form (“CAF”) under the TAS Regulations (“Circular”). The key highlights have been captured below:
1. CAF Introduced: The IFSCA has released a standardised CAF for entities seeking registration under the TAS Regulations. The form applies to both: (i) entities establishing a branch in GIFT City IFSC; and (ii) Entities incorporating a new unit/entity within IFSC.
2. Scope of Application: The CAF applies to all applicants proposing to offer TechFin or Ancillary Services within the IFSC jurisdiction. Supplementary forms may also be required based on the applicant’s specific business activity.
3. Dual Compliance: The form integrates requirements under both the IFSCA and Special Economic Zone (“SEZ”) frameworks. It includes details required by the Development Commissioner and mandates submission of SEZ fees and investment projections.
4. Mandatory Documentation: The application requires the following documents:
- Corporate documents (MoA, AoA, Certificates)
- Business plan and five-year financial projections
- Shareholding disclosures and UBO structure
- Fit-and-proper declarations for promoters/directors
- Detailed AML/CFT, compliance, and governance frameworks
5. Permitted Services: The regulations bifurcate eligible activities into two categories:
- Ancillary Services (e.g., legal, audit, compliance support, HR, KPO, fund admin, valuation, trusteeship, secretarial)
- TechFin Services (e.g., AI/ML, Web 3.0, quantum tech, blockchain, cybersecurity, regulatory tech, ERP, payment systems)
6. Explicitly Prohibited Services: Entities cannot engage in:
- Core activities reserved for regulated financial entities;
- facility management, logistics, or construction services;
- any other services disallowed by the IFSCA under the Act
7. Code of Conduct Mandate: All applicants must commit to a binding Code of Conduct, including:
- FATF compliance (proactive disclosure on high-risk jurisdictions);
- Mandatory infrastructure and personnel in IFSC;
- Full regulatory cooperation and registration for regulated activities
8. Undertaking and Affidavit: A formal declaration is required confirming the truthfulness of submitted information, adherence to regulations, and assurance against misuse of funds or involvement in prohibited services.
[1]https://ifsca.gov.in/CommonDirect/GetFileView?id=21626bde60601ef44a0ed02201607eb3&fileName=TAS_Circular_31072025_20250731_1222.pdf