SEBI’s circular of 30 October 2026 lengthens the KYC review cycle for foreign portfolio investors (FPIs) from one or three years to every 2 or 8 years, depending on category, jurisdiction risk and regulated status. It also drops the change-in-information or no-change declaration at registration continuance. It applies from 1 December 2026; custodians, depositories and DDPs must change their systems.
Lotus Custodian Bank is a Designated Depository Participant (DDP). It looks after two foreign funds. Northfield Pension Fund is a Category I FPI from a jurisdiction that is not classed as high risk. Harbour Opportunities Fund is an unregulated Category II FPI. Both were due a KYC refresh under the old schedule. From 1 December 2026 the circular sets the following.
| Northfield Pension Fund (Category I, non-high-risk jurisdiction) | KYC review every 8 years |
|---|---|
| Harbour Opportunities Fund (Category II, not a regulated entity) | KYC review every 2 years |
| Either fund wanting to continue for the next block of three years | Pays the continuance fee to Lotus at least 15 days before registration expires. No separate change-in-information or no-change declaration |
What is an FPI and what is KYC review?
A foreign portfolio investor is a non-resident fund or institution that invests in Indian listed securities. It registers under the SEBI (Foreign Portfolio Investors) Regulations, 2019 through a Designated Depository Participant (DDP), which is the SEBI-designated bank or custodian that registers and services the FPI. KYC (know your client) is the identity and ownership information the DDP must hold and keep up to date. Registration lasts a block of three years, and ten years for a SWAGAT-FI FPI, a separate category with its own rules.
The detailed procedure sits in SEBI’s Master Circular for FPIs, DDPs and Eligible Foreign Investors dated 30 May 2024, as amended. Two parts of it are touched. Para 5 of Part B said the KYC of an FPI must be reviewed annually or every three years, depending on jurisdiction, category and regulated status. Para 4 of Part A required an FPI, other than one investing only in government securities, to report changes in earlier information or submit a no-change declaration when continuing its registration.
What changes?
BEFORE
KYC review annually or every three years. At continuance, intimate changes or file a no-change declaration, and pay fees.
FROM 1 DECEMBER 2026
Longer review cycle of 2 or 8 years by category. Continuance needs only the fee, paid to the DDP at least 15 days before registration expires.
The circular does not redefine “high risk” jurisdictions or the FPI categories, so check the Master Circular and the 2019 Regulations for how your fund is classified. The circular says the aim is to rationalise the requirements, reduce compliance burden and promote ease of doing business. The new schedule, which replaces Table 6, is below.
| Jurisdiction | Category I FPI | Category II FPI |
|---|---|---|
| High risk | Registered under Regulation 5(a)(i): every 8 years. Others: every 2 years | Every 2 years |
| Non-high risk | Every 8 years | Regulated entities: every 8 years. Others: every 2 years |
Two groups are not moved. For an FPI investing only in government securities (a GS-FPI), the review follows the periodicity of its bank account KYC as prescribed by RBI. For a SWAGAT-FI FPI it stays at 10 years. The same table is written into the DDP Investor Charter at Annexure H, against the “KYC Review / Update” timeline.
Who must do what?
DDPs and custodians
Change systems and processes to apply the new schedule, and tell FPIs. Collect continuance fees at least 15 days before expiry. Many DDPs are banks, so this lands on custody and operations teams.
Depositories
Named in para 4 alongside DDPs and custodians to make system changes and bring the circular to FPIs’ notice.
FPIs
Pay the continuance fee on time. Review whether you sit in the 2-year or 8-year row, since only some Category I and II FPIs get the long cycle.
Stock exchanges and clearing corporations
The circular is addressed to them. The directions in para 4 are to depositories, custodians and DDPs.
Our reading of the practical steps: re-tag every FPI client by category, jurisdiction and regulated status, set the next review date in your KYC system, and switch off the old change-in-information reminder for non-GS FPIs. How the clock for an existing FPI is counted from 1 December 2026 is a point to confirm with your depository or SEBI contact before you reschedule reviews.
When does it apply?
The circular is dated 30 October 2026 and comes into force on 1 December 2026, a month after issue.
Legal basis
- Power used
- Section 11(1) of the SEBI Act, 1992, read with Regulation 44 of the SEBI (Foreign Portfolio Investors) Regulations, 2019
- Instrument
- Circular HO/19/34/14(10)2026-AFD-POD3/I/24814/2026, 30 October 2026
- Amends
- Para 4 of Part A and para 5 of Part B of the Master Circular for FPIs, DDPs and Eligible Foreign Investors dated 30 May 2024, and Annexure H (Investor Charter for DDPs)
- Addressed to
- FPIs, DDPs and custodians, depositories, stock exchanges and clearing corporations
Key facts
| Authority | Securities and Exchange Board of India (SEBI) |
|---|---|
| Instrument | Circular on rationalisation of periodicity of KYC review for FPIs |
| Reference | HO/19/34/14(10)2026-AFD-POD3/I/24814/2026 |
| Issue date | 30 October 2026 |
| Effective date | 1 December 2026 |
| New cycle | Every 8 years or every 2 years, by category, jurisdiction and regulated status (Table 6) |
| Unchanged | GS-FPIs (bank-account KYC periodicity per RBI) and SWAGAT-FI FPIs (10 years) |
| Applies to | FPIs; DDPs and custodians; depositories |
| Status | Issued, not yet in force |
| Last verified | 2 November 2026, against the circular page and PDF on sebi.gov.in |
Frequently asked questions
Does this mean FPIs no longer need to confirm their details?
The circular removes the requirement to intimate changes or submit a no-change declaration at the time of continuance of registration. It does not change the KYC review itself, which still happens on the new 2-year or 8-year cycle.
Which FPIs get the 8-year cycle?
Under the new Table 6, Category I FPIs from non-high-risk jurisdictions, and Category II regulated entities from non-high-risk jurisdictions. In high-risk jurisdictions, only Category I FPIs registered under Regulation 5(a)(i). All other FPIs are reviewed every 2 years.
What happens to FPIs that invest only in government securities?
Nothing changes for the review periodicity of GS-FPIs and SWAGAT-FI FPIs. A GS-FPI follows the periodicity of its bank account KYC as prescribed by RBI, and a SWAGAT-FI FPI is reviewed every 10 years.
When must the continuance fee be paid?
At least 15 days before the current validity of the registration ends, to facilitate a smooth continuance process, according to the substituted sub-paragraph (ii) of para 4 of Part A.
Sources (official)
- SEBI circular HO/19/34/14(10)2026-AFD-POD3/I/24814/2026, Rationalisation of periodicity of KYC review for FPIs, 30 October 2026 (circular page) https://www.sebi.gov.in/legal/circulars/oct-2026/rationalisation-of-periodicity-of-kyc-review-for-fpis_105504.html
- The same circular, PDF on sebi.gov.in https://www.sebi.gov.in/sebi_data/attachdocs/oct-2026/1793358139677.pdf
- SEBI, Master Circular for Foreign Portfolio Investors, Designated Depository Participants and Eligible Foreign Investors, 30 May 2024 (as amended) https://www.sebi.gov.in/legal/master-circulars/may-2024/master-circular-for-foreign-portfolio-investors-designated-depository-participants-and-eligible-foreign-investors-_83689.html
- India
- SEBI
- Capital Market Regulations
- FPI
- KYC review
- DDP
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