27 February 2026
SEBI Mandates Reporting of AIF NAV to Depositories
 
The Securities and Exchange Board of India (SEBI), vide circular dated 06 February 2026, has introduced a new reporting requirement, mandating Alternative Investment Funds (AIFs) to upload the Net Asset Value (NAV) for each ISIN of their units to the depository system.

This requirement follows SEBI's earlier mandate that AIF units be issued in dematerialized form. Since AIF units are now held through depositories, SEBI has required that the NAV for each ISIN be made available within the depository system, rather than remaining only in fund-level records and investor communications.

Under the circular, AIFs, through their Registrars and Transfer Agents (RTAs), must upload the latest available NAV for each ISIN before 01 May 2026, or within 30 days of the valuation date of the investment portfolio, whichever is later. The valuation date will be the valuation report date for an independent valuer, or the date of formal internal documentation for an inhouse valuation.

The responsibility for the timely and accurate uploading of NAV rests with the AIF Manager. Depositories such as National Securities Depository Limited and Central Depository Services (India) Limited are required to establish the necessary system infrastructure to facilitate NAV uploads and to display the NAV along with a prescribed disclaimer clarifying that it is based on the valuation methodology and accounting practices followed by the respective AIF.

Trustees or sponsors must ensure that compliance with this circular is specifically covered in the Compliance Test Report under the Master Circular for AIFs.

 
Our Comments

In practical terms, NAV will now become a regulated, system-reported figure within the depository ecosystem, increasing external visibility and supervisory oversight. While the valuation methodology itself remains unchanged, AIFs should strengthen valuation sign-off processes, ensure clear documentation of valuation dates, align approved NAV with depository uploads, formalize RTA coordination protocols, validate ISIN-wise mapping controls, and update Compliance Test Report coverage to ensure smooth implementation and regulatory alignment.
Sudit K. Parekh & Co. LLP
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