SEBI's ₹5 crore accredited investor test is live. Futures don't count
Since 5 November, a fund manager can accredit you itself, for three years. The final list of what counts towards ₹5 crore is shorter than the one SEBI's board discussed in September.
SEBI's circular of 5 November 2026 puts the accredited investor changes into force. An individual, HUF or family trust qualifies with ₹5 crore in demat securities, mutual fund folios, unlisted demat shares, overseas securities or NPS. Proof is a depository eCAS or a CA certificate, at most six months old. An AIF, SIF or PMS manager can now accredit a client for three years across its group.
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SEBI amended the AIF Regulations on 15 October 2026. On 5 November it issued the circular that says how the changes work. It came into force the same day.
Compound covered the proposal in October, in ₹5 crore in shares and funds is becoming a route to accredited investor status. This piece covers what the final rules say, and where they differ from the proposal.
Who qualifies on holdings
The holdings test needs at least ₹5 crore for an individual, a Hindu Undivided Family, a family trust or a sole proprietorship. A company, or a trust that isn't a family trust, needs ₹20 crore.
Five kinds of holding count, by paragraph 5.2 of the circular:
- securities held in demat form
- mutual funds held in folios
- unlisted securities held in demat form
- investments in overseas securities markets
- National Pension System investments
The three older tests, on income, net worth, or both, still apply. The holdings test is a fourth way in.
What fell out of the final list
SEBI's board papers in September listed futures positions at notional value, taken from a broker's statement. The circular's list doesn't include them.
The proof changed too. The board papers named a depository eCAS or a broker's statement. The circular names an eCAS summary generated by a depository, or a certificate from a practising chartered accountant. Either must be at most six months old.
NPS went the other way. The board papers said it "may be considered". The circular counts it.
Illustration. An investor holds ₹3 crore in mutual funds, ₹1.6 crore of listed shares and ₹60 lakh in NPS. That is ₹5.2 crore, so the test is met. Futures positions with a notional value of ₹2 crore would add nothing.
The statement that proves it
For anything in demat, the value used is the one printed on the depository's eCAS on its statement date.
Unlisted shares and overseas holdings that the eCAS doesn't value need a CA's certificate. It has to name the securities, the valuation date and the value.
Your fund manager can now accredit you
Until now, a certificate came from an accreditation agency. That route stays open.
The new route is optional. The manager of an AIF, the AMC running a SIF, or a portfolio manager can check your documents and record you as accredited. It must confirm this to you in writing, with the date and how long it lasts.
- It lasts three years from that date.
- It holds across the AIF, SIF and PMS businesses of the same corporate group.
- A manager outside that group has to check again from the start.
An investment adviser or research analyst can't accredit anyone. One can rely on an accreditation done by a manager in its own group.
An agency certificate works with any manager. A manager has to accept it while it is valid and can't run its own check on top. Certificates issued before 5 November stay valid for the rest of their term.
The checks on the manager
In September, SEBI noted the concern that a manager earns more when more of its clients qualify. The circular sets out what a manager that accredits must do:
- keep accreditation separate from sales and distribution, under a written policy
- run a process for investors who dispute a decision
- keep the records for at least five years after the investor leaves, open to SEBI's inspection
- document each decision so someone else can review it
Once you're in a scheme
An investor accredited when they joined a scheme counts as accredited for the rest of that scheme's life. A fall in holdings later doesn't change that.
SEBI's board papers list what accreditation opens, including AIFs, PMS and SIFs without their usual minimum investment. They also describe these products as carrying "lesser regulatory oversight" than those for retail investors.
Non-residents and LLPs
A person resident outside India under FEMA is deemed accredited, with no certificate and no check. The manager records why it treats the investor as non-resident. Anti-money-laundering checks still apply in full.
A limited liability partnership is accredited when each partner qualifies on their own.
Still open
- Joint holdings. The circular doesn't say how a jointly held folio or demat account is counted, or for whom.
- Prices between statements. The eCAS value is fixed on its statement date, and markets move after it. The circular uses the printed value and doesn't ask for a later one.
- How managers apply it. Each manager's accreditation policy will set out its own process. Those policies aren't public yet.
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Questions
- Can my fund manager make me an accredited investor?
- Yes, since 5 November 2026. The manager of an AIF, the AMC running a SIF, or a portfolio manager can check your documents and record you as accredited, valid for three years across its corporate group. Investment advisers and research analysts cannot.
- What counts towards the ₹5 crore accredited investor test?
- Securities in demat, mutual fund folios, unlisted securities in demat, overseas securities market investments and NPS, by paragraph 5.2 of SEBI's circular of 5 November 2026. Futures positions are not on the list.
- What proof do I need for the ₹5 crore holdings test?
- A depository eCAS summary statement, or a certificate from a practising chartered accountant, either at most six months old. Unlisted or overseas holdings the eCAS doesn't value need the CA certificate.
- How long does accredited investor status last?
- Three years from the date of accreditation, whether a manager or an accreditation agency grants it. An investor accredited when joining a scheme stays accredited for that scheme's life.
- Are NRIs accredited investors?
- A person resident outside India under FEMA is deemed accredited and needs no certificate or check, by paragraph 9 of the circular. Anti-money-laundering checks still apply.
Sources
- SEBI circular HO/19/34/11(6)2026-AFD-POD1/I/25244/2026, Review of the framework for Accredited Investors (5 Nov 2026)
- SEBI, circular text (PDF, 5 Nov 2026)
- SEBI, circulars listing, checked 9 Nov 2026
- Compound, ₹5 crore in shares and funds is becoming a route to accredited investor status (20 Oct 2026), for the board papers of 24 Sep 2026
Compound is analysis, not investment advice. Reva Money is not a SEBI-registered investment adviser.
