AIFs Without Funds Or Schemes Must File 'NIL' Quarterly Reports; SEBI Cancels Two Registrations

The Securities and Exchange Board of India (SEBI) on Friday cancelled the registrations of India Electronic Development Fund and Domus Capital LLP as Alternative Investment Funds (AIFs) for failure to file mandatory Quarterly Activity Reports (QARs).

SEBI's Designated Authority S. Madhusudhanan held that AIFs which have not raised funds or launched schemes are still required to submit NIL quarterly reports within the timelines prescribed under the AIF Regulations and the SEBI Master Circular.

Both entities were registered with SEBI as AIFs under the SEBI (Alternative Investment Funds) Regulations, 2012.

Under Regulation 28 of the AIF Regulations read with Clause 15.1.1 of the SEBI Master Circular dated May 7, 2024, registered AIFs are required to submit quarterly activity reports to SEBI within 15 calendar days from the end of each quarter.

SEBI observed that both AIFs failed to file QARs for the quarters ending March 2025, June 2025, September 2025 and December 2025, following which summary proceedings were initiated.

India Electronic Development Fund told SEBI that it had not yet raised any fund and therefore had not filed quarterly returns. Domus Capital LLP submitted that no funds had been raised since inception, furnished a CA certificate showing NIL balance, and stated that it had attempted to file the QARs after receiving the show cause notice.

Rejecting the explanations, SEBI observed: “Here I note that the Master circular on AIFs does not carve out an exception for AIFs which have not launched any schemes. Thus, in absence of any business, Noticee was still required to file a 'NIL' report with SEBI in timely manner.”

SEBI held in the Domus Capital LLP order that subsequent attempts to remedy the default after receipt of the show cause notice did not cure the past violations.

Holding that violation of the reporting requirements stood established, SEBI found both matters fit for cancellation of registration under Section 12(3) of the SEBI Act read with Regulation 30A of the SEBI (Intermediaries) Regulations, 2008.

Accordingly, SEBI cancelled the registration certificates of both AIFs with immediate effect.

Click here to read/download the SEBI order in the matter of India Electronic Development Fund

Click here to read/download the SEBI order in the matter of Domus Capital LLP