Master Circular for Broker Dealers and Clearing Members

The International Financial Services Centres Authority (IFSCA) has released a new Master Circular consolidating and updating the regulatory framework for Broker Dealers and Clearing Members operating within International Financial Services Centres (IFSCs). This circular not only streamlines previous guidelines but also aligns them with the recently introduced IFSCA (Capital Market Intermediaries) Regulations, 2025 (CMI Regulations).

A Unified Regulatory Framework

IFSCA first introduced regulations for capital market intermediaries in October 2021. However, the framework has since evolved with the notification of the CMI Regulations, 2025, which offer a more coherent and structured approach to regulating entities such as Broker Dealers and Clearing Members.

The new Master Circular serves as a comprehensive reference document that integrates all relevant regulatory instructions, thereby eliminating fragmentation and improving operational clarity for market participants in IFSCs.

Consolidation of Past Circulars

Over the years, IFSCA has issued several circulars addressing different aspects of broker dealer and clearing member operations—ranging from market access, fees, and net worth requirements to disaster recovery and settlement processes.

The new Master Circular brings together all these earlier directives, making compliance easier by providing one unified source of all applicable regulations.

Some notable circulars now consolidated under this Master Circular include:

  • Market Access through Authorized Persons (2020, 2022)
  • Fee Structure for MIIs and Participants (2021)
  • Refund of Security Deposits upon Surrender of Membership (2022)
  • Disaster Recovery Operational Guidelines (2023)
  • Settlement of Client Funds (2024)
  • Reporting Norms for Capital Market Intermediaries (2024)
  • Net Worth Maintenance Requirements (2024)

By merging these into a single regulatory document, IFSCA aims to enhance transparency, reduce compliance burdens, and support ease of doing business within IFSCs.

Supersession of Earlier Guidelines

Significantly, the Master Circular supersedes all earlier circulars—including those from SEBI prior to October 1, 2020—relating to Broker Dealers and Clearing Members functioning under IFSCA’s jurisdiction.

However, the circular includes important transitional provisions:

  • Actions or decisions already taken under earlier circulars remain valid.
  • Pending applications made under previous guidelines will be treated as applications under the corresponding provisions of the new Master Circular.

This ensures regulatory continuity and minimizes disruption for intermediaries adjusting to the updated framework.

Legal Authority and Effective Date

The circular has been issued under Sections 12 and 13 of the International Financial Services Centres Authority Act, 2019, along with Regulation 45 of the new CMI Regulations.

It becomes effective immediately from the date of issuance—November 29, 2025.

Looking Ahead

As India continues to position its IFSCs—especially GIFT City—among leading global financial hubs, regulatory clarity and consistency are crucial. The 2025 Master Circular is a significant step in enhancing oversight while also promoting a simplified compliance environment.

Market participants are encouraged to review the full circular, available on the IFSCA website, and ensure alignment with the updated regulatory requirements.

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