SEBI Cancels AIF Registration of ISF Special Opportunity Fund Over Four Quarters of Non-Compliance

SEBI Cancels AIF Registration of ISF Special Opportunity Fund Over Four Quarters of Non-Compliance

SEBI Cancels AIF Registration of ISF Special Opportunity Fund Over Four Quarters of Non-Compliance​

In a decisive regulatory action, the Securities and Exchange Board of India (SEBI) has cancelled the certificate of registration for ISF Special Opportunity Fund. The Order addresses severe non-compliance by the Alternative Investment Fund (AIF), citing the failure to submit required Quarterly Activity Reports (QARs). This ruling underscores SEBI’s commitment to enforcing diligent regulatory adherence from registered AIFs.

SEBI Initiates Action Against AIF for Missing QAR Filings​

The Order, issued on June 03, 2026, was passed under Section 12(3) of the SEBI Act, 1992 and Regulation 30A of the Intermediaries Regulations, 2008. ISF Special Opportunity Fund, registered with Registration No. IN/AIF1/18-19/0575, was found in violation of AIF regulations regarding reporting activities.

Registered AIFs are mandated to file QARs on a quarterly basis within 15 calendar days from the end of each quarter. Specifically, the Noticee failed to submit QARs for quarters ending March-2025, June-2025, September-2025, and December-2025 with SEBI.

Reviewing the Compliance Failures and Fund’s Defense​

SEBI initiated Summary Proceedings after noting the extensive pattern of non-filing by ISF Special Opportunity Fund. The fund had previously corresponded with SEBI regarding filing issues in 2023, citing technical difficulties related to uploading QARs for earlier quarters.

The Noticee argued that its compliance failures were primarily due to delayed login issues and system limitations during the reporting process. Furthermore, the fund submitted that no monies had been raised till date when prompted by SEBI regarding funds raised and investment made in the fund.

Regulatory Rationale: Why Technical Glitches Were Rejected​

SEBI’s consideration of the matter concluded that technical glitches cited by the Noticee cannot be accepted as a valid ground for prolonged non-compliance. The Board noted that despite engaging with SEBI in 2023, the Noticee failed to take proactive steps to complete its mandatory filings during the subsequent quarters of 2025.

It was also established that even in the absence of business or raised funds, a registered AIF was still required to file a 'NIL' report with SEBI in a timely manner. Therefore, the failure to submit reports was deemed a direct violation of the regulations.

The Final Order and Immediate Effect​

In view of the proven violations of regulatory provisions, SEBI determined that regulatory action was warranted under Section 12(3) of the SEBI Act, 1992. Consequently, the Designated Authority hereby cancelled the certificate of registration of ISF Special Opportunity Fund as an Alternative Investment Fund. This Order is effective immediately.
 

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