IFSCA Framework on Implementation Services for Investment Advisers in GIFT City IFSC
The International Financial Services Centres Authority released a detailed Consultation Paper on 13 November 2025, introducing a structured framework that defines how investment advisers registered in the GIFT City IFSC can support investors with implementation services.
Why the New Framework Matters for the GIFT City Advisory Landscape
GIFT City continues to grow as a global gateway for cross border investing. It connects international institutions, domestic investors, and global markets through a unified regulatory environment.
While IFSCA’s Capital Market Intermediaries Regulations 2025 permit investment advisers to support implementation, there was no comprehensive rulebook explaining how this support should function. The new framework fills this gap by ensuring:
Transparency in execution
Reduced conflict of interest
Clear operational expectations for advisers
Increased reliability for global counterparties
The result is a more resilient advisory ecosystem aligned with leading global financial hubs.
Key Highlights of the IFSCA Draft Framework
Implementation Services Allowed Through Regulated Channels Only
Investment advisers may assist clients in executing investment decisions. However, every transaction must pass through regulated intermediaries.
Foreign listed financial products must be executed through a Global Access Provider registered with IFSCA
IFSC listed products must be executed through an IFSC-registered broker dealer
This prevents informal routes, reduces mis-selling, and ensures market integrity.
Flexibility for Products Not Listed on Foreign or IFSC Exchanges
For products outside recognized exchanges, advisers may collaborate with:
International asset managers
Global investment platforms regulated by foreign authorities
Foreign product creators under recognised financial supervision
This widens investor access while retaining a strong compliance framework.
Implementation Services Are Always Optional
The framework makes it clear that clients must have complete freedom to choose how they wish to implement advice.
Investment advisers cannot compel clients to use any preferred partner or platform. This preserves independence and eliminates forced bundling.
Framework Aligns With IFSCA’s Global Access Regulations
The proposal links seamlessly with earlier Global Access guidelines issued on 12 August and 12 September 2025.
The outcome is a unified structure where advisers use
Global Access Providers for foreign listed assets
IFSC brokers for IFSC listed securities
This maintains supervisory oversight and avoids unregulated cross border execution.
Framework to Become Effective Upon Final Approval
Once finalised, the circular will come into effect immediately. IFSC intermediaries are expected to adjust seamlessly due to the clarity and simplicity of the proposed structure.
Impact on Stakeholders Across the GIFT City Ecosystem
Clear and regulated execution pathways
Higher investor protection and reduced mis-selling
Access to foreign securities and IFSC exchange-listed products
Confidence through the use of licensed intermediaries
The framework supports both retail and institutional clients seeking global diversification.
Impact on Investment Advisers
The draft brings operational certainty by enabling:
End-to-end advisory and execution support within IFSC regulations
Collaboration opportunities with Global Access Providers and foreign-regulated platforms
A streamlined compliance environment
More competitive service offerings aligned with global standards
This positions advisers to serve global clients with greater confidence.
Impact on Global Access Providers and Broker Dealers
These intermediaries will benefit from
Increased transaction volumes routed through their platforms
Stronger partnerships with IFSC Investment Advisers
Expanded participation in the IFSC ecosystem
This strengthens GIFT City’s infrastructure for cross-border investing.
Impact on the Broader GIFT City Ecosystem
Reinforces GIFT City as a world-class advisory and execution hub
Aligns IFSC with global regulatory practices in Singapore, the UK, and Dubai
Encourages global AMCs, custodians, and platforms to partner with IFSC advisers
Builds long-term investor trust in India’s international financial centre
This supports GIFT City’s long-term vision of becoming a global capital markets destination.
The IFSCA Draft Framework for Implementation Services represents a foundational step toward a globally aligned investment advisory environment in GIFT City IFSC.
Transparent and conflict-free advisory models
Compliance aligned with international best practices
Once fully notified, the framework will empower investment advisers to deliver comprehensive and globally connected services, further elevating GIFT City as a trusted international financial hub.
