left arrow Oct 27, 2026

GARUDA Mechanism for Processing of Private Placement Memorandums of AIFs Filed With SEBI

Securities and Exchange Board of India (‘SEBI’), by way of a Circular dated July 30, 2026, has prescribed operational modalities under the Green-Channel: AIF Rollout Upon Document Acknowledgement (GARUDA) mechanism for processing private placement memorandums (‘PPMs’). For regular schemes, Alternative Investment Funds (‘AIFs’) may launch 10 working days after filing the PPM with SEBI through a SEBI-registered merchant banker. The filing must include: (i) the merchant banker’s due diligence certificate; (ii) fit and proper declarations; (iii) sponsor/manager commitment declarations; and (iv) copies of PANs. The merchant banker must independently exercise due diligence over all PPM disclosures and must not be an associate of the AIF, its sponsor, manager, or trustee. Accredited investor only funds (‘AI Only Funds’), Large Value Funds for Accredited Investors (‘LVFs’), and Angel Funds may file PPMs directly with SEBI along with an undertaking from the chief executive officer and compliance officer of the manager. AI Only Funds and LVFs may launch immediately upon filing, and Angel Funds may circulate the PPM from the date of SEBI registration. New AI Only Fund and LVF schemes must include ‘AI Only Fund’/‘AIOF’ and ‘LVF’, respectively, in the scheme name. The Circular also prescribes mandatory PPM disclaimer clauses and exempts AI Only Funds, LVFs, and Angel Funds from intimating PPM changes through a merchant banker.

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