30 December 2025
Compliance officers of AIF managers must clear the NISM Series-III-C exam to hold the post from 1 January 2027
What certification does an AIF compliance officer need?
The NISM Series-III-C: Securities Intermediaries Compliance (Fund) Certification Examination. SEBI specified it by circular on 30 December 2025 as the eligibility criterion under regulation 20(18) of the AIF Regulations. From 1 January 2027, only a person holding that certification may be appointed as, or continue to act as, compliance officer of an AIF manager.
What changed
SEBI issued a circular on 30 December 2025, reference HO/19/(8)2025-AFD-POD1/I/1266/2025, addressed to all Alternative Investment Funds and signed by Anshul Jagdish Goyal, Deputy General Manager. It came into force with immediate effect.
Regulation 20(18) of the AIF Regulations has long said that a compliance officer must satisfy eligibility criteria "as may be specified by the Board from time to time." Until this circular, the Board had not specified them. This is that specification.
What it requires
The compliance officer of the manager of an AIF must obtain certification from the National Institute of Securities Markets by passing the NISM Series-III-C: Securities Intermediaries Compliance (Fund) Certification Examination, as set out in NISM communique No. NISM/Certification/Series-III-C: Securities Intermediaries Compliance (Fund) Certification Examination/2025/01 dated 20 November 2025.
The operative deadline is 1 January 2027. From that date, managers must ensure that only certified persons are appointed as, or continue to act as, compliance officer.
Who this reaches
Every AIF manager, and every person currently holding the compliance officer post at one. The circular gave just over twelve months' notice, and it reaches incumbents as well as new appointments — a person in the chair on 31 December 2026 without the certification cannot stay in it on 1 January 2027.
Compliance is reported through the Compliance Test Report under para 15.2 of the Master Circular, which the trustee, sponsor or manager must ensure covers this circular.
What is not settled
The circular does not address what happens to a manager whose compliance officer fails to certify in time, beyond the bare prohibition on continuing to act. Nor does it provide an exemption or transition for an officer who has held the role for many years, or one who holds a different NISM certification.
Sources
- Certification requirement for Compliance Officers of Managers of AIFs — HO/19/(8)2025-AFD-POD1/I/1266/2025 — SEBI, 30 December 2025 · primary
- Certification requirement circular, full text, 2 pages — SEBI, 30 December 2025 · primary
Dated 30 December 2025, last checked against source 25 August 2026. The dateline is the date of the instrument this item reports, not the date the page was written. This page reports what a document says. It is information, not legal, tax or investment advice, and it is not a recommendation about any fund.