SEBI Mutual Funds Second Amendment Regulations 2026: Fifth Schedule Shift and Fintech Checklist
SEBI’s 8 October 2026 amendment changes where mutual-fund advertising controls are located and gives teams a 180-day implementation window after Gazette publication.
Direct answer
SEBI’s Mutual Funds (Second Amendment) Regulations, 2026 were notified on 8 October 2026. The amendment moves references to the mutual-fund advertising code from the Fifth Schedule of the SEBI (Mutual Funds) Regulations, 2026 to Chapter IIID of the SEBI (Intermediaries) Regulations, 2008; the Fifth Schedule is omitted. The notification says the change takes effect on the 180th day after publication in the Official Gazette.
Read the official SEBI regulation page and the signed notification PDF. A Best CS Firm In India discipline is to treat this as a controlled document-and-workflow migration, not as permission to rewrite investor communications without review.
What changed
| Control point | Position after the amendment | Founder action |
|---|---|---|
| Regulation 28 | Advertising-material reference moves to Chapter IIID of the Intermediaries Regulations, 2008 | Update compliance maps, templates and policy cross-references |
| Regulation 81(l) | Liability reference is aligned to the new cross-reference | Re-test approval and escalation workflows |
| Fifth Schedule | Omitted from the Mutual Funds Regulations, 2026 | Archive the old reference and link teams to the correct live provision |
| Effective timing | 180th day after Official Gazette publication | Calendar the effective date from the Gazette record and work backwards |
Who should act?
- Mutual funds, asset-management companies and trustee companies.
- Fintech, wealthtech, creative, CRM, ad-tech and data vendors producing investor-facing material for regulated entities.
- Founders whose platform distributes, republishes or approves mutual-fund advertisements.
- Compliance, legal, product, marketing and engineering owners of approval or publication systems.
Implementation checklist for a fintech or vendor team
- Identify every screen, campaign, API, PDF, email and social asset that uses mutual-fund advertising text.
- Record the current source provision and the person who approves the content.
- Update the legal cross-reference only after counsel or the regulated client confirms the mapped Chapter IIID provision.
- Version the policy, template and vendor contract so old and new references can be audited.
- Test approvals, disclaimers, source citations, escalation and takedown controls.
- Train marketing, support and implementation teams before the effective date.
Documents to keep ready
| Document | Minimum evidence |
|---|---|
| Regulatory impact note | Old reference, new reference, owner, effective-date calculation and approval |
| Content inventory | Asset URL, channel, client, version, approver and expiry or review date |
| Vendor contract | Responsibility for content, approval, corrections, logs, audit and takedown |
| Test pack | Sample ads, disclosures, rejection cases, logs and sign-off |
| Training record | Attendees, material, date and questions closed |
Deadline and founder impact
The 180-day clock is a planning window, not a reason to delay. A regulated client may require its vendors to update controls earlier. Calculate the date from the Official Gazette publication record, then set internal milestones for impact mapping, policy approval, build, testing and evidence capture.
Mistakes to avoid
- Copying the old Fifth Schedule link into new ads or policy documents.
- Assuming the 180-day period means existing content never needs review.
- Changing a cross-reference without checking the applicable Chapter IIID text.
- Updating a template but not the approval workflow, audit log or vendor SLA.
- Calling a technology vendor “compliant” without a client-specific control sign-off.
Founder / Business Takeaway
For fintech and regulated-entity vendors, the amendment is a small text change with a real control implication. Treat it as a versioned migration: map exposure, confirm the new source, update content and contracts, test the workflow, and preserve proof before the 180-day effective date.
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FAQ
What changed?
Regulation 28 and regulation 81(l) now point to Chapter IIID of the Intermediaries Regulations, and the Fifth Schedule is omitted.
When is it effective?
The notification states the 180th day after publication in the Official Gazette.
What should a fintech vendor do?
Inventory affected assets, confirm the new provision with the regulated client, update controls and contracts, test approval workflows and keep evidence.
