SEBI Circular HO/19/34/14(10)2026-AFD-POD3/I/24814/2026, issued on 30 October 2026, replaces the annual and three-year review timetable for most Foreign Portfolio Investors. The changes take effect on 1 December 2026.
The new KYC review timetable
| Jurisdiction | FPI category | Review cycle |
|---|---|---|
| High risk | Category I registered under Regulation 5(a)(i) | Every 8 years |
| High risk | Other Category I FPIs | Every 2 years |
| High risk | Category II FPIs | Every 2 years |
| Non-high risk | Category I FPIs | Every 8 years |
| Non-high risk | Regulated Category II entities | Every 8 years |
| Non-high risk | Other Category II FPIs | Every 2 years |
Before this circular, the Master Circular generally required annual or three-year reviews depending on the same factors. The revised table changes the review interval; it does not change an FPI's category or jurisdiction classification.
Two exceptions remain
| GS-FPI | For an FPI investing only in Government Securities, the KYC review continues according to the periodicity applicable to its bank account under RBI requirements. |
|---|---|
| SWAGAT-FI FPI | The KYC review cycle remains 10 years. |
These two groups should therefore not replace their existing review date with the general two- or eight-year table.
What changes at continuation of registration?
SEBI has dispensed with the requirement to intimate changes in previously furnished information—or submit a no-change declaration—specifically at the time of continuation of registration. The FPI must still pay the continuation fee to its Designated Depository Participant at least 15 days before the current registration validity ends.
This procedural relief should not be read as permission to leave KYC information inaccurate. If ownership, control, regulatory status or another material fact changes, the FPI should follow the applicable ongoing reporting requirement and its DDP's instructions.
Who should act now?
The circular directly addresses FPIs, DDPs and custodians, depositories, stock exchanges and clearing corporations. SEBI has directed depositories, custodians and DDPs to update their systems and processes and inform the FPIs concerned.
- Confirm the FPI's classification. Record whether the jurisdiction is high risk or non-high risk, the FPI category and—where relevant—whether the Category II entity is regulated.
- Identify special-framework cases. Separate GS-FPIs and SWAGAT-FI FPIs before applying the general two- or eight-year table.
- Obtain the revised review date from the DDP or custodian. Do not infer a fresh starting date merely from 1 December 2026; reconcile the review calendar with the registration record and intermediary implementation.
- Keep the continuation-fee deadline. Schedule payment at least 15 days before the current registration validity ends.
- Update compliance calendars and controls. DDPs, custodians and affected FPIs should align system reminders, operating procedures and client communication before the effective date.
Reviewed on 31 October 2026. This note explains the SEBI circular's timetable and does not replace classification advice or a DDP's case-specific confirmation.