SEBI FPI KYC Review Periodicity from 1 December 2026: DDP and Custodian Checklist
The exact two-year and eight-year KYC review matrix, unchanged GS-FPI and SWAGAT-FI treatment, and operational actions before 1 December 2026.
Search intent and key terms
Primary keyword: SEBI FPI KYC review periodicity 2026
Intent: Informational regulatory update for foreign portfolio investors, designated depository participants, custodians, depositories, exchanges and clearing corporations.
Direct answer
From 1 December 2026, SEBI’s revised FPI KYC matrix applies two-year or eight-year review cycles according to jurisdiction, FPI category and regulated status. SEBI also removes the change or no-change declaration at registration continuation and requires the continuation fee to reach the DDP at least 15 days before the current registration validity ends.
The circular leaves the periodicity for GS-FPIs and SWAGAT-FI FPIs unchanged. The Best CS Firm In India regulatory approach is to classify every FPI correctly, calculate the next review date, update systems and communicate the revised service timeline before the effective date.
Official circular at a glance
| Item | Verified detail |
|---|---|
| Circular date | 30 October 2026 |
| Circular number | HO/19/34/14(10)2026-AFD-POD3/I/24814/2026 |
| Effective date | 1 December 2026 |
| Primary change | FPI KYC review periodicity rationalised |
| Continuation declaration | Change or no-change requirement dispensed with |
| Continuation fee | At least 15 days before current registration validity |
| Systems duty | Depositories, custodians and DDPs must implement process changes |
| Communication duty | Affected FPIs must be informed |
The revised KYC review matrix
| Jurisdiction | FPI Category I | FPI Category II |
|---|---|---|
| High risk | 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 |
| GS-FPI | RBI-prescribed periodicity for the relevant bank account | RBI-prescribed periodicity for the relevant bank account |
| SWAGAT-FI FPI | 10 years | 10 years |
Registration-continuation changes
An FPI seeking continuation for the next three-year block—or 10 years for SWAGAT-FI—must pay the applicable fee to its DDP. The circular omits the earlier sub-paragraph requiring information-change intimation or a no-change declaration at continuation.
The fee must be paid at least 15 days before the current registration validity ends to support a smooth continuation process. This does not eliminate separate duties to keep KYC information accurate under other applicable provisions.
DDP, custodian and depository checklist
- Classify each FPI by jurisdiction, category, regulated status and special framework.
- Calculate the next KYC review date under the revised matrix.
- Preserve GS-FPI and SWAGAT-FI treatment without applying the standard matrix incorrectly.
- Remove the discontinued continuation declaration from workflows and interfaces.
- Configure fee reminders before the 15-day cutoff.
- Update the investor charter and expected service timelines.
- Test exception handling for missing, inconsistent or changed KYC information.
- Communicate the changes to affected FPIs before 1 December 2026.
Common implementation errors
| Error | Risk | Control |
|---|---|---|
| Treating every FPI as eight-year | High-risk or unregulated cases may be reviewed late | Apply the full matrix |
| Changing GS-FPI periodicity | The circular expressly leaves it linked to RBI bank-account review | Keep a separate rule |
| Removing all change reporting | The circular only dispenses with the continuation requirement described | Map remaining duties |
| Fee reminder on expiry date | Continuation may not be smooth | Trigger before the 15-day minimum |
| No migration audit | Legacy dates may remain incorrect | Recalculate and reconcile records |
Founder / Business Takeaway
Longer review cycles reduce repetitive work only when classification is accurate. FPIs and intermediaries should treat 1 December as a systems-and-data deadline: map the right cycle, remove the discontinued continuation step, protect ongoing KYC accuracy and retain evidence of the migration.
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Sources and verification
https://www.sebi.gov.in/sebi_data/attachdocs/oct-2026/1793358139677.pdf
https://www.sebi.gov.in/legal/circulars/oct-2026/rationalisation-of-periodicity-of-kyc-review-for-fpis_105504.html
https://www.sebi.gov.in/foreign-portfolio-investors.html
https://www.indiacode.nic.in/handle/123456789/1890?view_type=browse
Frequently Asked Questions
When does SEBI’s revised FPI KYC framework take effect?
The circular states that its provisions come into force on 1 December 2026.
What are the new standard FPI KYC review cycles?
Depending on jurisdiction, category and regulated status, the revised matrix applies a two-year or eight-year review cycle, with separate unchanged treatment for GS-FPIs and SWAGAT-FI FPIs.
What changed at registration continuation?
SEBI dispensed with the change or no-change declaration at continuation. An FPI continuing registration must pay the fee to its DDP at least 15 days before current validity expires.
Did the circular change GS-FPI and SWAGAT-FI cycles?
No. GS-FPI review follows the RBI-prescribed periodicity for the relevant bank account, while SWAGAT-FI FPI remains at 10 years.
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