Page 1 of 6 CIRCULAR eF.No. IFSCA-DSI/12/2025-Capital Markets February 12, 2026 To, All Broker Dealers in the International Financial Services Centre (IFSC) All Recognised Stock Exchanges in the IFSC All Global Access Providers (GAPs) in the IFSC Madam/Sir, Subject: Format of Net Worth Certiϐicate and Checklist for con…
CIRCULAR eF.No. IFSCA-DSI/12/2025-Capital Markets
February 12, 2026 To, All Broker Dealers in the International Financial Services Centre (IFSC) All Recognised Stock Exchanges in the IFSC All Global Access Providers (GAPs) in the IFSC
Madam/Sir, Subject: Format of Net Worth Certiϐicate and Checklist for conducting Audit of GAPs
Reference may be drawn to the International Financial Services Centres Authority (Capital Market Intermediaries) Regulations, 2025 (“CMI Regulations”) and circular titled “Regulatory Framework for Global Access in the IFSC” (“GAP Circular”) dated August 12, 2025, in particular clauses 13 and 14 which, inter-alia, provides the requirement of maintaining minimum net worth by GAPs and other broker dealers accessing global markets on proprietary basis through GAPs.
In this regard, the format of the net worth certiϐicate to be submitted by GAPs and other broker dealers accessing global markets on proprietary basis through GAPs is speciϐied in Annexure I hereto.
The net worth certiϐicate shall be certiϐied by an independent member of the Institute of Chartered Accountants of India, and shall be submitted on yearly basis to the Authority via email to cmi-supervision@ifsca.gov.in, latest by September 30th for the preceding ϐinancial year.
Further, reference may also be drawn to clause 49 of the GAP Circular which mandates GAPs and Introducing Broker (IBs) to get its Global Access activities audited annually.
In this regard, it is directed that the annual audit shall be conducted, through a peer reviewed member of the Institute of Chartered Accountants of India or the Institute of Company Secretaries of India or the Institute of Cost Accountants of India, by relying upon the indicative checklist of documents speciϐied in Annexure-II hereto.
This circular is issued in exercise of powers conferred under sections 12 and 13 of the International Financial Services Centres Authority Act, 2019, read with regulation 27 and 45 of the CMI Regulations, and shall come into force with immediate effect.
A copy of this circular is available on the website of International Financial Services Centres Authority at www.ifsca.gov.in.
Yours faithfully, Sd/-
Amit Prajapati Deputy General Manager prajapti.amit@ifsca.gov.in
(see clause 2) Certiϐicate of Net Worth
I (name of certifying authority/member) hereby certify that (name of GAP/ Other Broker Dealer accessing global markets on proprietary basis through GAP), holding authorisation / registration as Global Access Provider/Broker Dealer and conducting proprietary trade / client trade or accessing global markets through GAP:
a) has a net worth of __________ USD as on DD/MM/YYYY; and b) is Compliant with clauses 13 and 14 of IFSCA Circular eF.No. IFSCA-PLNP/80/2024-Capital Markets dated August 12, 2025, titled “Regulatory Framework for Global Access in the IFSC”.
Statement of Computation of Net Worth is as per Annexure ___ attached below.
Name and Signature of Certifying Authority UDIN: Date:
(see clause 5)
| Sr. No. | Compliance Requirement under GAP Circular | Relevant Clauses of GAP Circular | Audit Scope | Relevant Documents to be verified (Indicative) |
|---|---|---|---|---|
| 1 | Net Worth | 13 & 14 | Maintenance of minimum net worth at all times by GAP; segregation of net worth from the net worth requirements applicable for other permitted activities | 1. Financial statements (audited / provisional) 2. Securities / Bank statement |
| 2 | Fit and Proper | 16 | Ensure fit and proper criteria compliance for GAP and its directors, key managerial personnel and controlling shareholders | 1. Independent verification from third party / Public sources 2. Declaration from the KMPs |
| 3 | Compliance Responsibility w.r.t. IFSCA Global Access Circular | 19 | Verify agreement of GAP with Introducing Broker ensure clear demarcation of responsibility of compliance with GAP Circular |
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Browse source laws| Agreement of GAP with Introducing Broker |
| 4 | Permitted Financial products | 20, 21 & 22 | Verify adequate systems and procedures for monitoring of trades w.r.t permitted financial products | Systems and procedures adopted by GAP for trade monitoring |
| 5 | GAP (exchange subsidiary) distribution activity | 23 | Verify GAP (exchange subsidiary) agreements w.r.t distribution for CMI Regulation compliances | 1. Agreement of GAP (exchange subsidiary) w.r.t distribution. 2. Systems and procedures adopted by GAP (exchange subsidiary) for distribution. |
| 6 | Infrastructure, Systems and Resources | 24 | Verify adequate infrastructure, systems and resources based on size / scale / complexity of operations | Conduct a case-to-case analysis of adequacy of infrastructure, systems and resources based on size / scale / complexity of operations to ensure compliance. |
| 7 | Agreement with foreign broker | 25 | Verify regulatory status and compliance standards of foreign broker. | GAP and foreign broker agreement. |
| 8 | Fund routing through IFSC | 27 | Verify all funds are routed through a bank account in the IFSC | Bank Account Maintained by GAP/IB (Verify Audit trail of the funds to IFSC bank account ) |
| 9 | Complaint handling and Risk Management policy of GAP/IB | 26&28 | Verify adequacy and analyse implementation of policies maintained by GAP/IB | 1. Risk Management policy of GAP/IB 2. Complaint handling policy of GAP/IB |
| 10 | Disclosure by GAP/IB | 29 | Verify GAP/IB disclosures to its clients | Onboarding document / periodic communication of GAP/IB for disclosure |
| 11 | Systems and Procedures | 30 | Verify adequate systems and procedures w.r.t monitoring of trades | Systems and procedures for trade monitoring |
| 12 | Agreement with foreign broker | 32 | Verify GAP and foreign broker agreement w.r.t. data sharing provision | Agreement of GAP and foreign broker. |
| 13 | Agreement with Introducing Broker | 33 | Verify GAP and introducing broker agreement w.r.t. data sharing provision | Agreement of GAP and introducing broker. |
| 14 | Fund Segregation | 36 & 37 | Segregation funds for GA and IFSC business; Segregation of client and prop funds for GA | 1. Bank statement for GAP and IFSC business transaction 2. Bank statement for client and prop transaction for GA |
| 15 | Disclosure Requirements at onboarding and during trading | 38 & 39 | Verify all the disclosures requirement during onboarding client and during login | 1. On-boarding documents / disclosure documents acknowledged by client 2. System and infrastructure in web platform to provide disclosures as per IFSCA Circular eF.No. IFSCA-DSI/12/2025-Capital Markets dated November 25, 2025. |
| 16 | KYC, AML and CFT compliance | 40 | Verify compliance w.r.t PML Rules, 2005 and IFSCA (AML, CFT and KYC) Guidelines, 2022 | 1. KYC & CDD documents 2. Bank statement indicating client credit and debit transactions 3. Client wise transaction ledger 4. Other requirements of AML CFT Guidelines and internal policies of CMI in this regard. |
| 17 | Data Storage Arrangements | 41 | Verify data storage and data availability arrangements | Data storage agreement with service provider. (In case of data storage arrangements are outsourced) |
| 18 | Code of Conduct and Advertisement Code | 44 & 45 | Verify compliance with code of conduct and advertisement code | 1. Independent verification from third party / Public sources 2. Declaration from the KMPs |
| 19 | Verification of submission of Quarterly Report | 47 | Verify timely submission and accuracy of data in quarterly reports submitted by GAP. | 1. Quarterly Reports submitted by GAP 2. Any other documents required |
| 20 | Fee Payment | 53 | Verify correct fee payment by GAP | 1. Transaction ledger with all foreign brokers 2. Bank statement indicating correct and timely fee payment to IFSCA |
