RBI circular on AIF December 2023

The RBI circular on AIF, December 2023, has introduced important changes to the way regulated entities (REs) invest in Alternative Investment Funds (AIFs).

These changes aim to prevent misuse of investment routes and increase financial discipline among banks and other regulated institutions.

For SSC aspirants, understanding this topic is essential, as it connects to financial regulation, economic reforms, and current affairs.

Let’s explore this important update in detail.

What Is an Alternative Investment Fund (AIF)?

An Alternative Investment Fund (AIF) refers to any fund that collects money from investors for investing in assets outside the traditional categories, like stocks or bonds. These include private equity, hedge funds, venture capital funds, etc.

RBI’s Role and the December 2023 Circular

The RBI circular on AIF December 2023 was issued to tighten oversight over how REs—such as banks, NBFCs, and financial institutions—interact with AIFs.

The primary concern was downstream investment compliance rules, where an AIF, after receiving funds from a bank, would invest that money into companies that already had loan or credit relationships with the same bank.

This created risks of indirect exposure through AIF schemes, leading to potential conflicts of interest and regulatory circumvention.

Key Highlights of the December 2023 Circular:

• REs are barred from investing in AIF schemes that have downstream investments (directly or indirectly) in companies to which the RE had loan or investment exposure in the previous 12 months.

• If an RE is found invested in such an AIF scheme, it must exit the fund within 30 days.

• If the RE fails to exit, it must make 100 percent provisioning AIF exposure, meaning it must set aside the entire investment amount as a buffer against potential loss.

This was a significant step toward enforcing regulated entities' investment restrictions and maintaining transparency in financial dealings.

Priority Distribution Model and Capital Dedication Rules

The RBI Circular on AIF December 2023 also addressed the priority distribution model, which the RBI views as a risk-enhancing mechanism.

• In this model, certain investors receive payouts before others, potentially leading to unfair risk distribution among stakeholders.

• According to the RBI Circular on AIF December 2023, investments made by regulated entities (REs) in subordinated units—those that get paid last in a waterfall payout—must undergo full capital deduction.

• This means the value of such investments is fully deducted from the bank’s Core Equity Tier 1 (CET1) capital, reducing their usable capital base.

• This stringent measure, as specified in the RBI Circular on AIF December 2023, applies even to sponsor units, reinforcing capital discipline and risk sensitivity.

• These changes are designed to ensure that REs avoid excessive risk-taking through complex AIF structures.

Updated Guidelines in March 2024 and Draft in 2025

Building on the RBI Circular on AIF of December 2023, the RBI released a follow-up circular in March 2024 to further refine the framework:

• Downstream investments now exclude equity shares but include all other instruments, such as hybrid securities.

• Provisioning is required only for the portion of an RE’s investment that is linked to a debtor company.

Continuing the momentum of the RBI Circular on AIF in December 2023, the RBI published revised draft guidelines in May 2025, currently open for public feedback until 8 June 2025 through the ‘Connect 2 Regulate’ portal.

Key proposals under the draft include

• A maximum of 10% investment by a single RE in any AIF scheme.

• All REs combined cannot invest more than 15% of the total corpus of a single scheme.

• Unrestricted investment if the RE’s contribution is up to 5% of the scheme’s total corpus.

• If investment exceeds 5% and the AIF has downstream debt exposure to a borrower linked to the RE, then the RE must make 100% provisioning for its portion of the exposure.

Some AIFs may be exempted from these rules if they serve strategic purposes, but only through consultation between the RBI and the government.

Coordination Between RBI and SEBI

Another important outcome of the RBI Circular on AIF December 2023 is the enhancement of inter-agency coordination. The RBI and SEBI joint regulatory framework now offers a robust oversight mechanism for AIF investments.

SEBI has already enforced rules requiring specific due diligence on both the investors and investment targets of AIFs. This aligns with the spirit of the RBI Circular on AIF, December 2023, which aims to curb the misuse of financial channels for indirect or non-transparent exposures.

This collaborative framework ensures that every rupee invested through an AIF is traceable, accountable, and compliant with India’s broader financial regulatory norms.

Final Thoughts

The RBI circular on AIF, December 2023, marks a significant step in tightening financial regulations and ensuring transparency in investments made by regulated entities.

For SSC aspirants, this topic is not just current affairs but also a vital piece of financial awareness that can appear in exams.

Understanding these guidelines, along with related regulatory terms, will strengthen your preparation for both objective and descriptive sections of competitive exams.