India – SEBI Consultation on Foreign Portfolio Investors Disclosures

India – SEBI Consultation on Foreign Portfolio Investors Disclosures

On 7 February 2024, IND SEBI proposed relaxation on timelines for disclosure.

  • IND SEBI released Consultation paper on relaxation in timelines for disclosure of material changes by foreign portfolio investors, re two categories of material changes.
  • Follows IND SEBI August 2023 circular on additional disclosures by FPIs.

Categorization of Material Changes

  • IND SEBI proposed to categorize the material changes to be notified by the FPIs into two categories for the purpose of mandating timelines for notification of such changes.
  • Type I, being changes which require FPI to seek fresh registration or which affect any privileges/exemption available to the FPI; type II, being all other material changes.
  • Indicative list of type I changes includes change of jurisdiction as well as name change on account of acquisition; merger; demerger; restructuring; and ownership/control.
  • The indicative list also includes takeover/acquisition/merger/demerger resulting in cessation of existence of FPI; restructuring of legal form; and change in regulatory status of FPI.
  • Indicative list also includes change in status of compliant jurisdiction of FPI or beneficial owner (BO); reclassification of FPI from one category to another; changes which impact any exemption of IND SEBI's circular of 24 August 2024.


  • Type I material changes shall be informed by FPIs within 7 working days of occurrence of the change, and supporting documents shall be provided within 30 days of change.
  • Type II material changes shall be informed with supporting documents within 30 days.
  • Final list of type I material changes will be prepared in consultation with stakeholders.


  • The comment period for this consultation closes on 28 February 2024.