SEBI’s June 2026 AIF Master Circular: What Changes for Fund Valuation

SEBI’s June 2026 Master Circular for Alternative Investment Funds (AIFs) consolidates the valuation, reporting and compliance framework that applies to every SEBI-registered AIF in India into a single reference document. For fund managers, trustees and independent valuers, the practical question is narrower than the circular itself: what changes for how an AIF’s portfolio is valued, and by when must those changes be reflected in the next valuation cycle. This note sets out what the June 2026 update means specifically for AIF valuation, alongside the December 2025 update to the IPEV Guidelines that Indian valuers are now expected to apply.

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1. What SEBI issued, and when

On 3 June 2026, the Securities and Exchange Board of India (SEBI) issued a fresh Master Circular for Alternative Investment Funds, consolidating the circulars, clarifications and operational instructions issued since the previous Master Circular of 7 May 2024. The new circular brings together guidance on Private Placement Memoranda, valuation norms, investor due diligence, governance standards, and regulatory reporting into one document, rather than requiring stakeholders to track multiple standalone circulars. A further update on 16 June 2026 added provisions on winding up and retention of proceeds for funds awaiting resolution of pending tax or litigation matters.

For valuation purposes, the significance of the June 2026 circular is less about new methodology and more about consolidation and timeline changes to how valuation output feeds into regulatory reporting, discussed below.

2. What the Master Circular consolidates on valuation

The valuation framework for AIFs was originally introduced through SEBI’s June 2023 circular on the standardised approach to valuation of investment portfolios, and subsumed into the May 2024 Master Circular. The June 2026 Master Circular carries this framework forward with the following core elements intact:

  • Independent valuation — specified assets must be valued by an independent valuer, not an associate of the manager, sponsor or trustee, holding IBBI registration together with the requisite professional membership (ICAI, ICSI, ICMAI or CFA Institute).
  • Method by asset type — securities for which valuation norms already exist under the SEBI (Mutual Funds) Regulations, 1996 continue to be valued under those norms; unlisted and thinly traded securities are valued per the IPEV Guidelines.
  • Frequency — Category I and II AIFs value their investments at intervals not exceeding six months under Regulation 23, with many funds valuing quarterly as practice; Category III AIFs, holding more liquid portfolios, value more frequently.
  • PPM disclosure — the valuation methodology and approach for each asset class must be disclosed in the fund’s Private Placement Memorandum, and any change in methodology must be disclosed to investors even where it is not treated as a Material Change.

The consolidation itself does not alter these core obligations. What has moved is the reporting timeline that sits downstream of the valuation exercise.

3. The performance benchmarking timeline

AIFs are required to report valuation and cash flow data, based on audited figures for investee companies, to performance benchmarking agencies. Under the original 2023 framework, this reporting was due within six months of the financial year end — that is, by 30 September for accounts as at 31 March. SEBI subsequently extended this timeline to seven months, meaning the deadline for reporting audited valuation data as at 31 March now falls on 31 October. The extension responds to a structural mismatch: investee companies have up to six months under the Companies Act, 2013 to complete their statutory audit, which left AIFs with little practical room to report audited figures within the original six-month window.

For funds and valuers, the practical implication is a firmer expectation that benchmarking submissions are based on audited investee data, not management accounts or provisional figures, since the additional month is intended to close that gap rather than simply extend the deadline for its own sake.

Not sure if your fund is on track for the 31 October deadline?

Download our AIF Valuation Compliance Checklist — a one-page self-check covering valuer eligibility, methodology, the IPEV 2025 edition and the benchmarking reporting timeline.

Or share your fund’s category, financial year end and current benchmarking-agency reporting date at crm@marckenconsulting.com and we will tell you, at no charge, whether your reporting timeline and audit schedule are aligned with the seven-month window.

4. The IPEV Guidelines: December 2025 edition

Separately from the SEBI circular, the International Private Equity and Venture Capital Valuation (IPEV) Board published a new edition of its guidelines in December 2025, superseding the December 2022 edition. The updated guidelines are considered in effect for quarterly reporting periods beginning on or after 1 April 2026 — that is, FY 2026-27 onwards.

SEBI’s Master Circular does not itself name a specific IPEV edition; it endorses “the IPEV Guidelines” as adopted by an eligible AIF industry association, a role filled in India by the Indian Venture and Alternate Capital Association (IVCA) as IPEV’s India country partner. Because IVCA’s adoption operates at the level of the framework rather than a fixed edition, Indian AIF managers and their appointed valuers are, in practice, expected to apply the December 2025 edition for valuation reports covering periods from 1 April 2026 onward. Fund managers should confirm with their valuer that reports for the first quarter of FY 2026-27 reference the current edition, particularly for portfolios involving complex capital structures, hybrid instruments or recent secondary transactions, where the 2025 edition’s treatment differs most from the 2022 edition.

Please note: This note reflects the position stated as at July 2026. SEBI circulars and IPEV guidance are updated periodically; the applicable provisions, methodology and reporting deadlines should be confirmed against the current Master Circular and the fund’s own PPM before relying on them for a specific engagement. This is not a substitute for professional advice.

5. What fund managers and valuers should check now

  • Confirm the fund’s PPM disclosure of valuation methodology is current, and that any methodology change since the last PPM update has been disclosed to investors — even if it falls short of a Material Change.
  • Build the seven-month benchmarking timeline (31 October, for 31 March data) into the fund’s compliance calendar, and confirm with investee companies that audit timelines support it.
  • Confirm with the appointed independent valuer that valuation reports for periods from 1 April 2026 reference the December 2025 IPEV edition, particularly where the portfolio includes hybrid instruments, complex capital structures or recent secondary transactions.
  • Verify the independent valuer’s eligibility — IBBI registration and the relevant professional membership — remains current, since this is a recurring inspection focus area. For how this credential differs from a SEBI Merchant Banker’s role, see IBBI Registered Valuer vs SEBI Merchant Banker.

For the underlying valuation methodologies themselves — NAV, DCF, market multiple, asset-based and IPEV-aligned fair value — and how to choose between them, see our companion guide to Fund Valuation Methodologies. For when a valuation is legally required across the Companies Act, FEMA, Income-tax and SEBI frameworks, see Fund Valuation Applicability in India.

6. Frequently asked questions

Does the June 2026 Master Circular change how AIF investments are valued?

Not in terms of methodology. The core valuation framework — independent valuer eligibility, method by asset type, minimum frequency, and PPM disclosure — carries forward from the 2023 circular and the May 2024 Master Circular. The June 2026 update consolidates this into a single document and reflects the extended benchmarking reporting timeline.

By when must audited valuation data be reported to benchmarking agencies?

Audited valuation and cash flow data as at 31 March must now be reported to performance benchmarking agencies within seven months of the financial year end, that is, by 31 October, extended from the original six-month timeline.

Which edition of the IPEV Guidelines applies to Indian AIF valuations?

SEBI’s Master Circular endorses the IPEV Guidelines as a framework rather than a fixed edition. With the IPEV Board’s December 2025 edition in effect for periods from 1 April 2026, and IVCA’s adoption operating at the framework level, Indian AIF managers and valuers are expected to apply the December 2025 edition for valuation reports from FY 2026-27 onward.

Who can act as an independent valuer for an AIF?

An independent valuer must not be an associate of the manager, sponsor or trustee, must have at least three years’ experience valuing unlisted securities, and must either hold IBBI registration together with membership of ICAI, ICSI, ICMAI or the CFA Institute, or be a holding company or subsidiary of a SEBI-registered credit rating agency.


About Marcken Consulting

Marcken Consulting LLP is a valuation advisory and corporate compliance firm that assists funds, companies and investors in India with independent, defensible valuations and the regulatory compliance that surrounds them. Our work includes Registered Valuer reports under the Companies Act, SEBI AIF and portfolio valuations, Income-tax valuations under Rule 11UA / Rule 57, FEMA valuations for cross-border transactions, and merchant-banker-style DCF and comparable-company analyses. Where a transaction also requires a Merchant Banker’s certificate, that certificate is issued by a SEBI-registered Category-I Merchant Banker within the same coordinated engagement.

Work with us

Need your fund’s valuation policy or benchmarking calendar reviewed against the June 2026 Master Circular? Visit marckenconsulting.com to arrange a no-charge 30-minute consultation.

Disclaimer

This article has been prepared by Marcken Consulting LLP for general information and educational purposes only. It does not constitute professional, valuation, legal, tax or investment advice and should not be relied upon as a substitute for advice tailored to specific facts. The regulatory references are stated as at July 2026; SEBI circulars and IPEV guidance are amended periodically, and the applicable provisions and deadlines should be confirmed for the specific fund and reporting period.

Marcken Consulting is an IBBI Registered Valuer (Securities or Financial Assets) and works alongside SEBI Category-I Merchant Bankers to deliver coordinated valuation reports across the Companies Act, IBC, Income-tax Act, and FEMA. To discuss a specific requirement, book a no-charge 30-minute consultation.

Reach out to us at: marckenconsulting.com
Marcken Consulting LLP — IBBI-Registered Valuer (Securities or Financial Assets) | Ahmedabad
Phone: +91 99980 59923 / +91 99985 39902
Email: crm@marckenconsulting.com

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