A Family Investment Fund (FIF) is the GIFT IFSC vehicle for a single family’s own capital. It is registered with IFSCA in the Authorised FME category and may take money only from the family and family-controlled entities. It should have and maintain a minimum investment of USD 10 million within three years of registration, and it may invest in the IFSC, India and abroad, with leverage set by its own risk management policy (Regs. 3(4)(a)(ii), 104, 106, 107, FM Regulations 2025). Being taken on record as an AIF category does not by itself establish pass-through (s. 224, Income-tax Act 2025) or specified-fund (Schedule VI) treatment.

Funding from India is the practical constraint. Meeting IFSCA’s single-family test does not mean the family can fund the FIF from India. The FIF needs USD 10 million within three years (Reg. 104(3)). Resident individuals can remit only USD 250,000 each per financial year under the Liberalised Remittance Scheme (LRS), across all LRS use (LRS MD para 1). Resident trusts and HUFs have no established route. Indian companies can contribute only within their overseas portfolio investment (OPI) or overseas direct investment (ODI) limits under the OI Rules 2022. The routes are set out below.

The rules are in Part C of Chapter VI of the IFSCA (Fund Management) Regulations, 2025 (“FM Regulations”), consolidated to 10 September 2026, read with IFSCA’s FIF circular of 1 March 2023. The wider framework is on the IFSCA regime page.

Table of Contents

What a Family Investment Fund is

The FM Regulations define a family investment fund as “a fund, pooling money only from a single family under one or more investment vehicles” (Reg. 2(1)(l)). The Authorised FME category includes “FMEs set up by a Single Family to manage its Family Investment Fund” (Reg. 3(4)(a)(ii)). IFSCA’s FAQ calls it “a self-managed fund” (FAQ Q123).

No third-party manager. The family’s own vehicle is registered. IFSCA’s fee circular gives the FIF its own registration line (Fee Circular 2026, Sch. I, Part 2, A(ii)).
One family only. An office serving several families cannot use it. A Registered FME (Non-Retail) can offer portfolio management “including for multi-family office” (Regs. 3(4)(b)(ii), 81).
AIF categorisation. The FIF or its vehicle “may be construed as” a Category I, II or III AIF by strategy under Reg. 30, “and shall accordingly be taken on record by the Authority” (Reg. 104(5), Explanation II; last words added w.e.f. 10 September 2026). See Category I, II and III AIFs in GIFT City.

Who counts as a “single family”, and which entities can contribute

The definition has two limbs (Reg. 2(1)(ii)):

Individuals: “lineal descendants of a common ancestor”, their spouses (including widows and widowers, “whether remarried or not”) and children, including stepchildren, adopted and ex-nuptial children.
Entities: a sole proprietorship, partnership firm, company, LLP, trust or body corporate in which “an individual or a group of individuals of a single family exercises control and directly or indirectly hold substantial economic interest”.

“Substantial economic interest” means “at least 90% economic interest” (FIF circular, para 2(a)). IFSCA’s FAQ still applies that test and lists how it may be shown (FAQ Q124):

Contributor	Evidence of the 90% test
Company with share capital (operating or holding company)	Percentage of shareholding
Company without share capital	Right to exercise control
Partnership firm or LLP	Percentage share of profits
Trust	Beneficial interest in the deed (determinate trust) or pro-rata share of trust property (indeterminate trust)

A family operating company, holding company or trust can therefore qualify as a contributor under IFSCA’s rules if it passes both the control and the 90% tests. Whether it can lawfully send the money from India is a separate FEMA question (below). On the numbers, a group company with more than 10% held outside the family would not. IFSCA’s definition has no residence test, so resident and non-resident members can sit in one FIF.

The 2023 circular adds conditions the regulations do not repeat:

No outside money. An FIF “shall not seek money from individuals or entities outside of the single family”. Employees, directors, the FME and service providers may receive economic interest, and contribute for it, up to “twenty percent (20%) of FIF’s profits” in aggregate (para 2(b)).
Minority outsiders in family entities. They must be told the risks and may be offered an exit at not less than a price set by an independent third-party service provider (para 2(d)).
Undertakings. Before investing starts, each contributing member confirms to the Principal Officer that usual investor protections “may not be available to the same extent” (para 2(e)).

The circular was issued under the 2022 Regulations but continues “unless and until… specifically superseded or modified” (Reg. 148(5)); Reg. 148(2) does not supersede it. One point differs: the circular requires “prior approval” for additional vehicles (para 2(c)), while Reg. 104(5) speaks only of “filing documents for such vehicles with the Authority and payment of applicable fee”. The regulation is the later and higher instrument, but the circular survives under Reg. 148(5) unless “specifically superseded or modified”, and no IFSCA text found modifies para 2(c). IFSCA’s FAQ (Q128) restates the filing wording without mentioning approval. IFSCA has not expressly resolved the point. The cautious course is to treat the filing as needing IFSCA’s acceptance before the vehicle is used.

Registering the FIF as an Authorised FME

No entity may carry on fund management in an IFSC without a certificate of registration (Reg. 3(1)). The application follows the First Schedule (Reg. 3(2)). IFSCA may ask for more information, personal representation or an office inspection (Reg. 11), and grants the certificate on payment of the registration fee (Reg. 12).

Reg. 104(2) switches off the FME legal-form and net worth rules (Regs. 5 and 8). The FIF may be a company, a contributory trust or an LLP, or another permitted form. A trust must have identifiable beneficiaries whose shares are “not… at the discretion of the trustee” (Reg. 104(1)). The rest of Chapter II still applies on the text, including:

a “dedicated, secured” office (Reg. 10(2));
employees with relevant experience, stated for Authorised FMEs (Reg. 6(2)(b));
fit and proper status for the applicant, principal officer, directors or partners, KMPs and controlling shareholders (Reg. 9).

IFSCA’s indicative workflow (v1.0, July 2026) runs from office space and incorporation, through one SWIT application to IFSCA and the SEZ Administrator, to the SEZ Letter of Approval, a foreign currency account with an IFSC banking unit, and the certificate of registration through SWIT.

Item	Rule	Source
Fees (from FY 2026-27, 1 April 2026)	Application USD 2,500; registration USD 15,000; flat annual USD 3,000	Fee Circular 2026, Sch. I, Part 2, A(ii)
Minimum size	“a minimum investment of USD 10 million within a period of three (3) years from the date of obtaining certificate of registration”	Reg. 104(3)
Additional vehicles	On filing and fee; counted together for the USD 10 million test	Reg. 104(5), Expl. I
Open or close-ended	Either, “depending upon the requirements of the family”	Reg. 104(4)

The FAQ calls the USD 10 million a “minimum corpus” (Q126). The regulation says “should have and maintain”, so the level is to be kept up after the three years.

Governance: people, policies and reporting

Principal officer. Responsible for “overall activities… including but not limited to fund management, risk management and compliance” (Reg. 7(1)). They must be “based out of IFSC” and meet the qualification and experience rules (Reg. 7(5)). A separate compliance officer is required only for a Registered FME (Reg. 7(2)).
Certification. KMPs and core fund management staff must complete an IFSCA-specified course (circular of 1 April 2026, under Reg. 7(6)). A second course (ICAI) was specified on 10 August 2026. The deadline for both is now 31 December 2026 (circular of 29 September 2026).
Ongoing obligations. Chapter VIII is written for FMEs generally and Reg. 104(2) does not disapply it. On our reading an FIF must follow the Code of Conduct (Reg. 118), keep records for at least eight years (Reg. 119), file IFSCA’s reports (Reg. 120), have “a sound risk management system” (Reg. 123(1)) and get prior approval for any change in control (Reg. 125(1)).
Website. From 1 December 2026, an Authorised FME must keep a public website or a dedicated group webpage. It must show its registration details, principal officer contacts and grievance mechanism (IFSCA circular of 26 August 2026, paras 3(a), 4, 9). The circular has no FIF exception.

Permitted investments and leverage

An FIF may invest “in IFSC, India or foreign jurisdictions” in unlisted and listed securities, money market and debt instruments, securitised debt, units of schemes, derivatives (including commodity derivatives), LLPs, and “physical assets such as real estate, bullion, art, etc.” (Reg. 106). It “may borrow funds and engage in leveraging activities as per their risk management policy” (Reg. 107). No numerical leverage cap for an FIF was found in the published text.

An FIF is a deemed accredited investor (accredited investor circular, 25 January 2024, para 1(f)(vi)). It can therefore enter IFSC venture capital and restricted schemes without the USD 250,000 and USD 150,000 minimums (Regs. 20(2), 32(2)).

For investments back into India, FEMA treats a regulator-recognised IFSC financial institution as “a person resident outside India” (FEMA 339/2015-RB, Reg. 3). Whether a particular FIF falls within this should be confirmed. IFSC schemes and funds that invest in listed Indian securities must register as FPIs under the SEBI FPI Regulations, as IFSCA’s circular of 2 May 2024 (para 1) notes. That circular speaks of FME schemes; it does not say whether an FIF can register as an FPI.

FPI registration brings in SEBI FPI Reg. 4(c). Each NRI, OCI or resident individual constituent must hold below 25% of the corpus; resident individuals may contribute only through LRS and only to funds with Indian exposure below 50%; and these individuals “shall not be in control of the applicant” (Reg. 4(c)(i), (iii), (iv)). The proviso for IFSC funds lifts only the 50% aggregate cap in sub-clause (ii). Under a separate proviso, a resident that is not an individual, such as a family company or trust, may be a constituent of an IFSC AIF or retail scheme only as its fund management entity or associate, up to 10% of the corpus. SEBI’s circular of 27 June 2024 adds conditions for the route above 50%, including a minimum of 20 investors, none above 25%, and an independent fund manager. On the face of these texts, resident family ownership or control sits uneasily with Reg. 4(c). Whether a particular FIF can register as an FPI, and how its resident members count as constituents, must be checked for that vehicle; the texts do not settle it.

FEMA funding routes from India

An IFSC entity with limited liability is a “foreign entity” under the overseas investment rules (r. 2(1)(h), OI Rules 2022). The route depends on the contributor. FEMA is covered more broadly on the GIFT City FEMA page.

Contributor	Route	Limit	Source
Resident individual	LRS, as overseas investment	USD 250,000 per financial year across all LRS use	LRS MD paras 1, 6, 11; OI Rules Sch. III para 1(1)
Indian company, body corporate, LLP or registered firm	OPI in units of an IFSC fund or vehicle; unlisted entities included (RBI circular of 7 June 2024)	50% of net worth (last audited balance sheet)	OI Rules Sch. V para 1(2) proviso (iii), Sch. II para 1(1); OI Directions para 24(1)
Resident private trust or HUF	No express route found in the texts	LRS “not available to… HUF, Trusts”; neither is an “Indian entity”	LRS MD para 1; OI Rules r. 2(1)(j)

Points that arise:

Timing of the corpus. LRS is per person per year. Capital account remittances cannot be clubbed between family members who are not co-owners of the investment (LRS MD para 4).
IFSC parity. RBI’s A.P. (DIR Series) Circular No. 15 of 10 July 2024 (RBI/2024-25/49), now para 11 of the LRS Master Direction, allows remittances to IFSCs “for all permissible purposes under LRS”.
OPI or ODI. A resident “may make contribution to an investment fund or vehicle set up in an IFSC as OPI” (Sch. V para 1(2) proviso (iii)). But an FIF company’s shares are also unlisted equity of a foreign entity, which is ODI under r. 2(1)(q). Resident individuals may make ODI in an IFSC financial services entity (not banking or insurance) without subsidiaries outside the IFSC that they control (proviso (iv)). Which route applies depends on the FIF’s legal form and on what the resident acquires: units of an investment fund or vehicle point to OPI (OI Directions para 24(1)); shares in, or control of, a corporate vehicle point to ODI. The two have different conditions, and neither should be assumed for a family-owned FIF.
Family trusts and HUFs. They can be “single family” entities under IFSCA’s definition, but no matching FEMA route for their contribution was found. Funding through members or family companies is one option; another is a specific view on the trust or HUF route.
Round trips. Resident money returning to Indian assets through the FIF needs a specific overseas investment check; Reg. 106 settles only the IFSCA side.

Onshore, the SEBI AIF Regulations exclude “family trusts set up for the benefit of ‘relatives’” from the definition of an AIF (Reg. 2(1)(b), proviso (i)). So a family trust for relatives sits outside SEBI’s AIF regime, while in GIFT IFSC the family’s pooled vehicle is a registered fund.

Tax headline

Tax follows the AIF category the FIF is construed as, but being taken on record in a category does not by itself settle tax status. Two points are open. Detail is in GIFT City Tax Benefits for Funds and Fund Managers.

Category I or II. Pass-through under s. 224 of the Income-tax Act, 2025 needs “a certificate of registration as a Category I or a Category II Alternative Investment Fund” under the IFSCA 2022 Regulations (s. 224(10)(a)). An FIF’s category is only “taken on record”, and Reg. 104 lacks the deeming words of Regs. 19(2) and 31(2). Reg. 148(4) deems references to the 2022 Regulations in “any act of the Government of India” to refer to the corresponding 2025 provisions, but a regulation cannot amend an Act, and no CBDT statement confirms the reading. Pass-through for an FIF is therefore unsettled. Schedule VI Note 1(g)(i) carries the same 2022 reference, which Finance Act 2026, s. 125 left unchanged when it amended Note 1(g).
Category III. The Schedule VI “specified fund” regime needs all units other than the sponsor’s or manager’s to be held by non-residents, with a 5% allowance for holders who later become resident (Note 1(g), as amended by Finance Act 2026, s. 125). An FIF with resident unit holders from day one does not, on its face, qualify.

GIFT IFSC compared with DIFC, ADGM and Singapore

This table records only each regulator’s or government’s own statement of status and entry threshold.

	GIFT IFSC: FIF	DIFC: Family Office	ADGM: Single Family Office	Singapore: Single Family Office
Regulatory status	IFSCA registration as an Authorised FME (Reg. 3(4)(a)(ii))	“Licenced as such by the Registrar” (Family Arrangements Regulations, in force 31 January 2023, Reg. 4.1.1). DFSA authorisation if it provides “Restricted Services to more than one (1) Family by way of business” (Reg. 4.3.2)	“does not require a financial services permission, but a controlled licence activity” (ADGM website)	Licensing exemption, para 5(1)(ba), Second Schedule, SF(LCB) Regulations; notice “within 14 days of commencement” (MAS FAQs, Q1, Q3)
Entry threshold	USD 10 million within 3 years (Reg. 104(3))	Family net asset value of USD 50,000,000 (Regs. 1.2.6, 4.1.2(c))	Website: “Minimum family net assets of USD 10 million”. This figure was not found in ADGM’s rules; ADGM consulted on SFO changes in June 2024	None for the exemption. Tax incentives: S$20 million (13O/13OA) or S$50 million (13U) in designated investments (MAS)

The DIFC row is a family office licence. The DIFC VCC is covered on a separate page: DIFC VCC. Of the four, only the FIF sits inside India’s regulatory system with an express permission to invest in India (Reg. 106).

Common questions

What is a Family Investment Fund in GIFT City? A self-managed fund pooling money only from a single family, registered with IFSCA as an Authorised FME (Regs. 2(1)(l), 3(4)(a)(ii); FAQ Q123).

Can a family company or trust invest in a GIFT City FIF? Under IFSCA’s rules, yes, if the family controls it and holds at least 90% economic interest. That test does not authorise money to leave India. Under FEMA, an Indian company or LLP needs OPI (or ODI) capacity within the OI Rules limits; for resident trusts and HUFs no express route was found. Onward investment by the FIF into India raises separate FEMA and FPI questions.

What is the minimum corpus for a GIFT City family office? USD 10 million, reached within three years of registration and maintained after that (Reg. 104(3)).

Does an FIF need a compliance officer or minimum net worth? No. Reg. 7(2) applies only to Registered FMEs, and Reg. 104(2) disapplies net worth. It needs a principal officer based in the IFSC (Reg. 7).

Sources

International Financial Services Centres Authority (Fund Management) Regulations, 2025, as amended up to 10 September 2026 (consolidated): Regs. 2, 3, 5–13, 20, 32, 81, 104–107, 118–125, 148. IFSCA, 14 September 2026. ifsca.gov.in
IFSCA (Fund Management) (Second Amendment) Regulations, 2026 (IFSCA/GN/2026/015), cl. 42. IFSCA, 31 August 2026 (Gazette uploaded 10 September 2026). ifsca.gov.in
Clarifications in relation to Family Investment Funds (F. No. 333/IFSCA/FIF/2022-23). IFSCA, 1 March 2023. ifsca.gov.in
FAQs on IFSCA (Fund Management) Regulations, 2025 (information updated to 30 June 2026): Q123–Q129. IFSCA, 3 August 2026. ifsca.gov.in
Fee structure for the entities undertaking or intending to undertake permissible activities in IFSC (IFSCA-DTFA/1/2026). IFSCA, 2 March 2026. ifsca.gov.in; applicable for FY 2026-27 and onwards (para 16)
Step-by-step workflow for setting up in IFSC on the SWIT portal (v1.0). IFSCA, 7 July 2026. ifsca.gov.in
Specification of Certification Course for KMPs/Employees under the IFSCA (Fund Management) Regulations, 2025 (IFSCA/13/2026-Capital Markets/1). IFSCA, 1 April 2026. ifsca.gov.in
Extension of timeline for completion of Certification Course by KMPs and employees of FMEs (F. No. IFSCA-AIF/127/2026-Capital Markets/1). IFSCA, 29 September 2026. ifsca.gov.in
Requirement for Fund Management Entities (FMEs) to maintain a website or webpage (IFSCA-SOF/2/2026-Capital Markets). IFSCA, 26 August 2026. ifsca.gov.in
Accredited Investors in IFSC (F. No. IFSCA-IF-10PR/1/2023-Capital Markets). IFSCA, 25 January 2024. ifsca.gov.in
Facilitating investments by NRIs and OCIs into Indian securities through Schemes / Funds in an IFSC. IFSCA, 2 May 2024. ifsca.gov.in
Master Direction – Liberalised Remittance Scheme (FED Master Direction No. 7/2015-16), updated as on 6 September 2024, paras 1, 4, 6, 11. RBI. rbi.org.in
Remittances to IFSCs under the LRS (A.P. (DIR Series) Circular No. 15, RBI/2024-25/49). RBI, 10 July 2024. rbi.org.in
Foreign Exchange Management (Overseas Investment) Rules, 2022 (G.S.R. 646(E)), r. 2(1)(h), (j), (q); Sch. II para 1; Sch. III para 1(1); Sch. V para 1(2). Ministry of Finance, 22 August 2022. rbi.org.in ; also incometaxindia.gov.in
Foreign Exchange Management (Overseas Investment) Directions, 2022 – Investments in Overseas Funds (A.P. (DIR Series) Circular No. 09, RBI/2024-25/41), substituting para 24(1) of the OI Directions. RBI, 7 June 2024. rbi.org.in
Foreign Exchange Management (International Financial Services Centre) Regulations, 2015 (FEMA 339/2015-RB). RBI, 2 March 2015. rbi.org.in
SEBI (Alternative Investment Funds) Regulations, 2012, last amended 14 July 2026, Reg. 2(1)(b). SEBI. sebi.gov.in
Income-tax Act, 2025, s. 224. Income Tax Department. incometaxindia.gov.in
Income-tax Act, 2025, Schedule VI, read with Finance Act, 2026, s. 125. Income Tax Department. incometaxindia.gov.in
DIFC Family Arrangements Regulations (in force 31 January 2023; file “updated August 2023”), Regs. 1.2.6, 4.1.1, 4.1.2(c), 4.3.2. DIFC, linked from the DIFC Legal Database. assets.difc.com
“Establish Your Family Office in ADGM” (page metadata: published 26 August 2024). Abu Dhabi Global Market, accessed 26 October 2026. adgm.com
“The Registration Authority of ADGM publishes consultation paper on Single Family Offices and Company Charges”. ADGM, 14 June 2024. adgm.com
FAQs on Licensing Exemption Framework for Single Family Offices. Monetary Authority of Singapore, issued 12 June 2026. mas.gov.sg
Fund Tax Schemes for Family Offices. Monetary Authority of Singapore, page last updated 22 September 2026. mas.gov.sg
SEBI (Foreign Portfolio Investors) Regulations, 2019, as amended up to July 2026, Reg. 4(c) and provisos. SEBI.
Participation by NRIs, OCIs and Resident Indian individuals in SEBI registered FPIs based in IFSCs in India (SEBI/HO/AFD/AFD-POD-2/P/CIR/2024/89). SEBI, 27 June 2024.
Corrigendum to fee circular (IFSCA-DTFA/2/2026). IFSCA, 13 March 2026. Official URL not located

Family Investment Fund in GIFT City: Registration and Rules