The short answer
- Deadline: from 1 January 2027, only a person who holds the NISM Series-III-C certification can be appointed as, or continue to act as, the compliance officer of an AIF manager.
- Certification: NISM Series-III-C: Securities Intermediaries Compliance (Fund) Certification Examination.
- Who it covers: the compliance officer of every AIF manager, including people already in the role today.
- Who checks it: the trustee, sponsor or manager must cover it in the manager’s Compliance Test Report.
- Source: SEBI circular HO/19/(8)2025-AFD-POD1/I/1266/2025 dated 30 December 2025.
What SEBI actually said
SEBI’s circular dated 30 December 2025 (HO/19/(8)2025-AFD-POD1/I/1266/2025) requires compliance officers of AIF managers to obtain the NISM Series III-C: Securities Intermediaries Compliance (Fund) Certification.
From 1 January 2027, only certified individuals can be appointed as compliance officers, or continue in the role. It covers people already in the job as well as new appointments. And the responsibility sits with the AIF manager, which has to make sure its compliance officer gets the certification and keeps it current.
Who this touches
- The compliance officer of every AIF manager, whatever the category of fund.
- People already in the role. They need the certificate by the deadline to stay in it.
- Anyone you plan to appoint from 1 January 2027 onwards.
- The manager itself, which carries the obligation.
A simple plan for this quarter
None of this is complicated. The risk is leaving it until December and finding the exam slots, or your compliance officer’s calendar, don’t cooperate.
- Write down who is formally designated as compliance officer for each manager entity.
- Check certification status today and book the exam early.
- Name a certified backup, so the role is never empty if someone leaves or falls ill.
- Track the validity date. The obligation is to get the certificate and to keep it.
- Keep the evidence together: certificate, dates, the appointment note. You will be asked for it.
- Put the requirement into your compliance calendar and periodic reporting.
The bigger point
This rule is small on its own, but it fits a pattern. SEBI has also reworked AIF reporting into quarterly and annual activity reports, and LPs are asking sharper questions in operational due diligence. The thread running through all of it is evidence. It isn’t enough to do the right thing. You need to be able to show who did what, when, and under which policy.
That is where many managers struggle. Approvals, IC decisions and compliance sign-offs still happen over email, so every audit turns into an archaeology project. Moving those processes onto a governed workflow, with maker-checker, role-based access and a proper audit trail, means the evidence builds itself as people work.
This article summarises a public SEBI circular for general information. It is not legal or regulatory advice. Always check the latest SEBI circulars and speak to your compliance advisers.
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Frequently asked questions
Is NISM certification mandatory for AIF compliance officers?
Yes. Under SEBI’s circular dated 30 December 2025, compliance officers of AIF managers must hold NISM Series III-C: Securities Intermediaries Compliance (Fund). From 1 January 2027, only certified individuals can be appointed or continue as compliance officers.
Which NISM exam do AIF compliance officers need?
NISM Series III-C: Securities Intermediaries Compliance (Fund) Certification Examination.
Does it apply to compliance officers already in the role?
Yes. Existing compliance officers also need the certification by 1 January 2027 to continue.
Who is responsible for making sure it happens?
The AIF manager. It has to ensure its compliance officer acquires and maintains the certification within the timeline.