SEBI’s Responses to IVCA Queries Pertaining to the Annual Activity Report (AAR)

SEBI’s Responses to IVCA Queries Pertaining to the Annual Activity Report (AAR)

SEBI’s Responses to IVCA Queries Pertaining to the Annual Activity Report (AAR)
S. No.	Heading	Queries	Answers
Cost, NAV and co-investment related questions
1	“Cost of Investment” vs “Cost of Holding” – Table 14 and related references	Members seek clarity on the difference between “Cost of Investment” and “Cost of Holding”, particularly in Table 14 “, Details of Temporary Investments,” where “Cost of Investment” has been replaced by “Cost of Holding.” Clarification is requested on whether “Cost of Holding” refers to original acquisition cost, amortised cost, cost net of redemptions/sales, or some other defined measure.	It is the original acquisition cost
2	Choice of reporting date for “Cost of Holding as at the end of half year” in an annual AAR -Tables 6A/6B/14	While the AAR is annual, certain fields reference cost “as at the end of the half year.” Members request guidance on: a) Which half year (e.g. 30 September vs 31 March) is intended for the FY 2025-26 AAR; and b) whether the requirement is conceptually tied to the most recent half year within the financial year.	Cost of holding as on 31.03.2026
3	NAV disclosure where there is no NAV based concentrationlimit – Table 5B	In Table 5B, schemes that do not have concentrationlimits based on NAV are required to mark “No” in therelevant column. The subsequent column seeks “NAV of Scheme at end of reporting period” only if “If Yes.” However, historically, NAV was reported to SEBI under QCR. Members seek SEBI’s guidance on whether:	If schemes do not have concentrationlimits based on NAV, then the column may be left blank.
		a) The NAV field should be populated even when concentration limits are not NAV based; or
		b) The field should strictly be left blank, with no NAV reporting required in AAR.
4	Scope of “co investor” andrelated fields – Tables 4A and4B	a) For schemes with Co Investment Vehicles (CIVs),should the presence of CIVs be treated as “Managerfacilitated co invest in the scheme,” and if so, how shouldthe CIV units/investors be reflected in the co investorfields?b) In Table 4B, for wound up schemes where some money remains due to specific investor issues (e.g. investor debarment, banking problems), should this residual amount be reported as “amount held back”?	a) If ‘Status of Scheme” selected is”CoInvestment Scheme” then the lastfour columns of the table will becomedeactivated and will not be applicable.If ‘Status of Scheme” selected is otherthan “coinvestment Scheme” only then the last 4 columns of the table will be activated. Please select the relevant options. However, the concern on coinvestment units is not found as no such information is sought separately in any other column.
		b) In Table 4B, for wound up schemes where some money remains due to specific investor issues (e.g. investor debarment, banking problems), should this residual amount be reported as “amount held back”?	b) Yes
5	Angel fund reporting of commitments and investors at investment level – Tables 4A, 4B, 6A	Angel funds request a clear framework for reporting where one investor’s contributions are allocated across multiple investee companies, and the AAR appears to require investment wise commitment and investor numbers.	Scheme wise details need to be provided for angel funds as well. No additional request can be incorporated in this regard at this juncture.
6	Difference between “SEBI PMS registration number” and “PMS REG NO” – Table 4A	Some managers are unclear whether both fields refer to the same SEBI PMS registration number or if “PMS REG NO” refers to an additional identifier. Clarification is requested	“PMS REG NO” : field appearing due to technical error may be left blank at this juncture.
Valuation, deviation and escrow-related conceptual questions
7	Negative deviation reporting -representation of declines	Beyond the technical issue, funds seek confirmation on how negative deviations are to be conceptually captured: whether SEBI expects a signed percentage (e.g. -15%) or absolute deviation with a separate indication of direction.	Only absolute deviation (in number) may be provided even if negative deviation. For e.g. if there is a positive or negative deviation of 15% only “15 should be stated in the given column.
8	Whether deviation reporting is required for securities valueddaily on stock exchange prices	For listed equity portfolios (particularly Cat III) where valuation is purely mark to market, members request SEBI’s view on whether deviation reporting is intended,and if so, how thresholds and investor reporting should operate without causing excessive reporting for normalmarket volatility.	As per Clause 22.2.1. of Master Circularfor AIFs : “At each asset level, in casethere is a deviation of more than 20%between two consecutive valuations ora deviation of more than 33% in afinancial year, the manager shall inform the investors the reasons/factors for the same, both generic and specific, including but not limited to changes in accounting practices/policies, assumptions/projections, valuation methodology and approach, etc. and reasons thereof. “As per above clause, there is no exception in circular for Listed Equity portfolios.
9	Escrow related metrics – Tables 18 and 7H	a) For “Unique No. of Investors to which Escrow belongs,” should uniqueness be determined PAN wise, folio wise, or on some other basis (e.g. client code)? b) For “% of unique investors’ units lying in Escrow account,” how should AIFs calculate this where an investor holds multple unit lots and only a portion is in Escrow? Clarificaton of the exact numerator and denominator would help.	a) PAN wise b) (i) Unique No.of.Investors to which Escrow belongs = PAN wise unique investors whose units are lying in Escrow a/c (ii) Total no. of. Unique Investors in the scheme = Total unique investors PAN wise in the scheme (iii) %age of unique investors’ units lying in Escrow a/c = (i) / (ii). It is unlikely that AIFs where an investor holds multple unit lots and only a porton is in Escrow with the same AIF.
10	Classification of “Other Investor” – Table 7F	Guidance is sought on which investor categories should fall under “Other Investor” to ensure consistent classificaton across AIFs.	Those investors not falling in any of the other categories and are not Accredited investors need to be reported in : Non -AI Investors other than Sponsor & Manager
Compliance, benchmarking, and fee reporting
11	Reconciling NISM certification timeline with AAR requirements – Table 3E	In addit on to the ut lity point, we request SEBI’s explicit confirmaton that where the SEBI circular permits Compliance Officers t me untl the specified deadline to obtain NISM certficaton, AIFs may legitmately leave DATE_NISM_CERT and DATE_NISM_EXPIRY blank in the AAR untl the certficaton is obtained, without adverse inference.	NISM Certficaton details for Compliance officers may be left blank (if not already obtained). May be filled for the next reporting period once the deadline is crossed.
12	Disclosure of IFSCA FME registraton and similar overseas registratons – Table 3B	Some managers are registered as FMEs with IFSCA or have other regulatory registratons. They seek guidance on whether and where such registratons should be disclosed within the Sponsor/Manager/Trustee informaton.	Please provide the category of registraton with the other regulator along with the registraton number in the space provided. If multple registratons, the same could also be provided there itself.
13	Type of entty selecton for partnership/LLP structures with individual partners – Table 3B	Sponsors/managers that are partnerships or LLPs with only resident individual partners are uncertain about which “Type of entty” opt on to select from the drop down. Clarificaton on the intended choice would be helpful	Domestc Owned and Controlled Resident Non-individual
14	Benchmarking agency reporting date and alignment with AAR – Tables 11A/21	AIFs request clarity on:
		a) What date should be considered as “latest required information submitted” to the performance benchmarking agency; and	a) Select “Yes” in the concerned field,if data pertaining to the reporting financial year is provided to performance benchmarking agency at least once within the reportingfinancial year. Select “No”, if the lastdata provided is prior to the reportingfinancial year.
		b) Whether it is acceptable if valuation andbenchmarking timelines differ from the AAR filing date,i.e. no regulatory concern arises where benchmarkinginformation follows its own prescribed timeline.	b) Timeline for valuation and benchmarking needs to be complied as per applicable regulation / circular
15	Management fee and distribution fee reporting – Table 11B	Some questions have arisen:
		a) For schemes where management fee scheduleschange over time, should “Management Fee per annum(Rs. Cr)” be reported as fee accrued during the year, asteady state annual amount, or some other measure?	a) Annualized Management fee over the tenure of the fund
		b) For newly launched schemes or schemes where final close is pending, what amount should be reported as “Management Fee per annum” and “Total ManagementFees charged over the tenure”?	b) “Management fee per annum” asper the commitments received till thedate of reporting should be provided.per the commitments received till thedate of reporting should be provided.Total Management fee charged over the tenure field will be automatically calculated
		c) For open ended schemes with no defined tenure, how should “Total Management Fees charged over the tenure” be computed?	c) For oepen ended schemes, pleasefollow directions as mentioned in data validation for column “Tenure of Scheme”. The column “total Management Fees charged over thetenure” will be calculatedautomatically.
		d) Where distribution fees are borne by the managerand not charged to the scheme, should “TotalDistribution fee charged over the tenure” and related fields be reported as Nil, left blank, or marked as not applicable?	d) If not charged to the scheme, then it may be reported as Nil
		e) The new requirement to report management and distribution fees in absolute INR crore terms is operationally challenging, where future fees must be estimated; can SEBI clarify whether (i) only actual fees accrued up to 31 March 2026 should be reported, or (ii) an estimate of full tenure fees is expected?	e) Estimate of full fees during the tenure is expected
16	Treatment of consents embedded in fund documents – Table 4B and Table 7G	For tenure extensions or other changes that are already permitted/embedded in fund documents and notsubject to separate investor voting, AIFs seek guidance on:
		a) Whether such cases should still be reflected as “True” for consent related fields; and	a) In table 4B : Whether the tenure hasbeen extended: Reported as true if fundhas extended the tenure as per theterms of PPM with or without investor’sconsent.
		b) How “% investors by value that approved extension”should be calculated where no separate consent ispractically obtained.	b) If consent not applicable as per AIF Regulations and Circulars, then in Table 4B, the – If Yes, then provide % Investorsby value that approved extension may be reported as Zero
17	Details of Accredited & Other Investors in AIFs	With respect to Table 7D “Details of Accredited & Other Investors in AIFs”, Table 7E” Accredited & Other Investors – Commitments Received from Various Categories ofInvestors in AIFs” and Table 7F “Accredited & Other Investors – Funds Raised from Various Categories of Investors in AIFs” do investor details still need to be provided if there are no accredited investors in the fund?	Even if no accredited investors (AI):table is mandatory to enter. For fundswith no accredited investors, Zero value may be entered in AI Investors column.