On July 25, 2025, the International Financial Services Centres Authority (“IFSCA”) has issued detailed guidelines to clarify the eligibility requirements for Key Managerial Personnel (“KMPs”), specifically Principal Officers (“POs”) and Compliance Officers (“COs”), under Regulation 7 of the International Financial Services Centres Authority (Fund Management) Regulations, 2025 (“FM Regulations”).[1]
Key Takeaways:
1. Minimum Qualifications & Experience:
- KMPs must possess a postgraduate or professional degree in finance, law, economics, etc., from recognised Indian or foreign institutions.
- A minimum of 5 (five) years’ relevant experience is mandatory, though up to 2 (two) years of consulting experience (e.g., deal due diligence, transaction advisory) is permissible within that total.
- POs with more than 15 (fifteen) years of fund management experience may qualify with only an undergraduate degree.
2. Experience Types that Qualify: Roles at the following regulated entities are recognised as valid experience:
- Portfolio managers, AIF/ mutual fund managers
- Investment advisers, broker-dealers, investment bankers
- Wealth managers, research analysts, credit rating agencies
- Market infrastructure institutions (stock exchanges, depositories, etc.)
- Debenture trustees, REITs/InvITs
- Listed companies and banks regulated by SEBI, RBI, IRDA, PFRDA
3. Specific Notes on CO Eligibility:
- COs must have more than 3 (three) years’ experience in compliance/risk management, particularly in securities law or financial regulatory compliance.
- Experience limited to internal audit or unrelated regulatory fields will not count.
4. Other Clarifications:
- Contractual roles and secondments can be counted, provided they’re substantiated.
- Experience in family offices or corporate treasuries may be considered on a case-by-case basis.
- BPO/ KPO experience and outsourced roles are capped at 2 (two) years of credit.
5. Appointment Protocol:
- Fund Management Entities are advised to seek prior approval for proposed KMPs before appointment.
- If a candidate is found ineligible by IFSCA, any re-application must be accompanied by the prescribed KMP application fee.
[1]https://ifsca.gov.in/CommonDirect/GetFileView?id=21626bde60601ef44a0ed0220150e4f6&fileName=Guidelines_on_KMP_eligiblity_Final_Published_25_July_2025_20250725_0402.pdf