SEBI’s circular dated 5 November 2026 introduces manager-led accreditation as an additional route for Accredited Investors. It also sets three-year validity, new securities-market exposure thresholds, documentation standards and safeguards for managers.
Who can now determine accreditation?
A “Manager” may determine and record accredited status when an investor is onboarded or during a scheme’s tenure. For this purpose, Manager means an AIF manager, the asset management company of a Specialized Investment Fund, or a registered portfolio manager.
This manager-led route is optional and sits alongside the existing route through a recognised Accreditation Agency. A manager’s determination is valid for three years. A fresh determination is required when the investor is onboarded by a manager outside the same group.
An investor who was accredited when admitted to a scheme continues to be treated as accredited for the remaining life of that scheme, even after the general three-year validity period.
The new securities-market exposure tests
| Applicant category | Minimum qualifying exposure |
|---|---|
| Individual, HUF, family trust or sole proprietorship | ₹5 crore |
| Body corporate or trust other than a family trust | ₹20 crore |
Qualifying exposure includes securities in dematerialised form, mutual fund investments held through folios, unlisted securities held in demat form, overseas securities-market investments and National Pension System investments.
For dematerialised holdings, the value in the electronic Consolidated Account Statement (eCAS) as of the statement date is used. Unlisted or overseas securities not valued in the eCAS require a practising Chartered Accountant’s certificate identifying the nature of the securities, valuation date and value.
Documents that can establish eligibility
| Eligibility route | Acceptable evidence under the circular |
|---|---|
| Income | Latest income-tax return, or a practising CA’s certificate confirming that the prescribed income threshold is met. |
| Net worth | Latest audited financial statements, or a practising CA’s net-worth certificate not older than six months. |
| Securities-market exposure | An eCAS summary statement generated by a depository and not older than six months, or a practising CA’s certificate confirming that the threshold was met within the preceding six months. |
The circular does not replace the underlying eligibility criteria in Regulation 2(1)(ab). Applicants and managers should identify the applicable route first and then assemble the prescribed evidence.
Special treatment for LLPs and non-residents
An LLP can be recognised as an Accredited Investor if every partner independently meets the eligibility criteria applicable to that partner on the determination date. A partner that is itself a body corporate, LLP, firm or trust must qualify in its own right.
A Person Resident Outside India under FEMA is deemed to be an Accredited Investor and need not obtain an accreditation certificate or undergo manager-led accreditation. The manager must record the basis for treating the investor as non-resident. This does not reduce obligations under anti-money-laundering law, including client due diligence, beneficial-owner identification and source-of-funds checks.
Safeguards managers must build
- Own the decision. The manager remains responsible for verifying the eligibility criteria and complying with the circular.
- Retain records for the longer period. Supporting documents and verification evidence must be kept for at least five years from accreditation or until five years after the investor leaves all schemes managed by that manager, whichever is later.
- Include accreditation in internal review. The process must form part of periodic internal audit and compliance review.
- Adopt a written policy. It must address conflicts of interest, separation from business-development and distribution functions, escalation, grievance redressal, privacy, cybersecurity and record retention.
- Make the file independently reviewable. Record the decision, the eligibility criterion used and the supporting verification.
What should investors and managers do?
- Choose the route. Decide whether manager-led accreditation or a recognised Accreditation Agency is more practical.
- Check portability. Confirm whether a prior determination came from a manager in the same group; otherwise prepare for a fresh review.
- Refresh evidence. Ensure eCAS and relevant CA certificates satisfy the six-month recency rule.
- Map each LLP partner. Test every direct and entity partner against its own applicable eligibility criteria.
- Update onboarding controls. Managers should approve the accreditation policy, separate commercial and verification responsibilities, and set three-year validity alerts.
Reviewed on 6 November 2026. Accreditation can affect access to specialised investment products and regulatory concessions; investors should understand the product’s risks separately from their accredited status.