The International Financial Services Centres Authority (IFSCA) has issued a consultation paper seeking comments from the public and stakeholders on the draft framework for providing implementation services by Investment Advisers (IAs).
Building on the regulatory landscape established by the IFSCA (Capital Market Intermediaries) Regulations, 2025 (“CMI Regulations”), this proposal seeks to operationalize Regulations 34(12) and 34(13), which permit IAs to provide implementation services subject to specific conditions.
The draft circular, open for comments until December 03, 2025, outlines the specific channels through which IAs can execute transactions for their clients.
Execution Channels based on Product Type
To ensure regulatory oversight and efficient execution, the framework mandates specific intermediaries based on where the financial product is listed:
Foreign Jurisdiction Listings: For financial products listed on stock exchanges in foreign jurisdictions, the IA must provide implementation services through a Global Access Provider registered with IFSCA.
IFSC Listings: If the financial products are listed on a recognized stock exchange within the IFSC, the implementation services must be provided through a Broker Dealer registered with the IFSCA.
Other Foreign Products: For investment products or securities not listed on foreign stock exchanges, the IA is permitted to enter into formal arrangements with platforms or Asset Management Companies (AMCs) that are registered or regulated by a financial sector regulator in a foreign jurisdiction.
Client Obligation and Voluntary Adoption
The draft circular emphasizes client protection and freedom of choice. While providing these services, the Investment Adviser must ensure that the facility is strictly optional.
Advisory clients must not be under any obligation to avail of the implementation services offered by the Investment Adviser, adhering to the requirements of Regulation 34(13) of the CMI Regulations
You can access the full consultation paper here.
Disclaimer: The information published in the above newsletter is collected from various sources in electronic medium and analyzed by the firm. The reader is advised to consult the attorney qualified in their jurisdiction, before acting on any information contained in this newsletter. India Juris excepts no liability what so ever in this regard.
