What Are Specialised Investment Funds (SIFs)? The SEBI Framework Explained
SEBI introduced specialised investment funds in April 2025, designed to sit between traditional mutual funds and portfolio management services. For investors who have outgrown standard fund structures but find PMS thresholds prohibitive, understanding what a SIF is and how the framework operates is worth your time. Learn what these funds are and how they function with our comprehensive guide.
What Is a Specialised Investment Fund?
A specialised investment fund (SIF) is a SEBI-regulated investment category, effective April 1, 2025. It was introduced under amendments to the SEBI (Mutual Funds) Regulations, 1996. It allows asset management companies (AMCs) to offer strategy-driven schemes with greater portfolio flexibility than conventional mutual funds. The SIF does not replace mutual funds but operates alongside them under the same AMC, with a separate regulatory treatment. SEBI uses the term "investment strategy", not "scheme", for products launched within this framework.
Why SEBI introduced SIFs:
- To bridge the gap between mutual funds and AIF & PMS
- To provide a regulated alternative for investors seeking sophisticated strategies
- To reduce the gravitational pull of unregistered, unauthorised investment entities
Minimum investment threshold:
- ₹10 lakh per investor, measured at the PAN level across all SIF strategies within one AMC
- This threshold applies exclusively to SIF investments and does not include regular mutual fund investments with the same AMC
- Accredited investors are exempt from this minimum
The SEBI Regulatory Framework for SIFs
SEBI's regulatory framework for SIFs was published via circular dated February 27, 2025, and came into force on April 1, 2025. AMFI was directed to issue operational guidelines by March 31, 2025.
AMC Eligibility: Two Routes
Route 1: A Good Track Record:
- Mutual fund in operation for at least three years
- Average AUM of not less than ₹10,000 crore in the preceding three years
- No regulatory action initiated or taken under Section 11, 11B, or 24 of the SEBI Act during the last three years
Route 2: Alternate Route:
- CIO for SIF must have a minimum of 10 years of fund management experience and have managed average AUM of at least ₹5,000 crore
- An additional fund manager with at least 3 years of fund management experience and average AUM of ₹500 crore
- Same regulatory clean-record requirement as Route 1 applies
Portfolio and Concentration Limits
SEBI has set defined investment limits for SIF strategies:
- Maximum 20% of NAV in AAA-rated debt and money market securities from a single issuer
- Maximum 16% in AA-rated securities from a single issuer
- Maximum 12% in securities rated A and below from a single issuer
- These limits may be extended by up to 5% with prior approval from fund trustees and AMC board
- Maximum 25% of NAV in debt and money market securities of any one sector SIFs may hold up to 25% of net assets in unhedged, exchange-traded derivative positions for non-hedging purposes, a feature not available in traditional mutual funds.
Branding and Disclosure Requirements
SEBI requires SIFs to maintain distinct brand identities:
- Separate brand name, logo, and dedicated website or webpage
- For the first five years, the sponsor or mutual fund brand name may appear in communications, but must be accompanied by phrases such as "brought to you by" or "offered by"
- SIF brand name in promotional materials must be equal to or larger in size than the mutual fund brand name
- Portfolio disclosure on alternate months, within 10 days of month close
- NAVs disclosed by 11:00 PM on the same business day (T day)
- Risk classified into five bands (Risk Band 1 to 5), reviewed monthly
Investment Strategies Permitted Under SIF
SEBI has approved seven subcategories of investment strategy under three broad categories. Only one strategy per subcategory is permitted per AMC.
Equity-Oriented Strategies
1. Equity Long-Short Fund: Invests a minimum of 80% in equity and equity-related instruments. Allows both long and short positions, with unhedged derivative exposure up to 25% of net assets. Designed for investors seeking equity returns alongside active downside risk management through short positioning.
2. Equity Ex-Top 100 Long-Short Fund: Focuses on stocks outside India's top 100 companies by market capitalisation. Targets mid- and small-cap segments where market inefficiencies may be more pronounced. Also permits short positions via derivatives up to 25% of net assets.
3. Sector Rotation Long-Short Fund: Tactically allocates across a maximum of four sectors based on the fund manager's market outlook. Combines long positions in favoured sectors with short positions via derivatives, with sector concentration limits applying as per SEBI norms.
Debt-Oriented Strategies
4. Debt Long-Short Fund: Invests in debt instruments across different durations. Allows unhedged positions in exchange-traded debt derivatives. Structured as an interval fund with a redemption frequency of once a week or less. Carries risks around interest rate movements, credit defaults, and reinvestment yields.
5. Sectoral Debt Long-Short Fund: Concentrates on debt instruments within specific sectors. Minimum of two sectors in the portfolio, with a maximum of 75% in any single sector. Maximum naked derivative position of 25% in debt instruments held in the portfolio. Also an interval fund structure.
Hybrid Strategies
6. Active Asset Allocator Long-Short Fund: Provides broad flexibility to dynamically rebalance across asset classes, including equity, debt, equity and debt derivatives, REITs/InvITs, and commodity derivatives. Maximum 25% unhedged derivative exposure across equity and debt. Structured as an interval fund with a redemption frequency of twice a week or less. This is the closest to a dynamic asset allocation strategy within the SIF framework.
7. Hybrid Long-Short Fund: Maintains a minimum of 25% each in equity and debt instruments. Allows tactical short positioning and rebalancing across asset classes. Structured as an interval fund. Designed for investors seeking multi-asset exposure with active risk management built in.
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How SIFs Differ from Mutual Funds and PMS
| Parameter | Mutual Funds | SIF | PMS |
|---|---|---|---|
| Minimum Investment | As low as ₹500 (SIP) | ₹10 lakh (PAN level) | ₹50 lakh |
| Regulator | SEBI | SEBI | SEBI |
| Short Positions | Not permitted | Up to 25% via derivatives | Permitted |
| Dynamic Allocation | Strategy-specific | Permitted across strategies | Full flexibility |
| Regulatory Framework | MF Regulations | MF Regulations (distinct licence) | PMS Regulations |
| Pooled / Segregated | Pooled | Pooled | Segregated |
| Disclosure Standards | High | High (alternate monthly portfolio) | Moderate |
SIFs are not a substitute for PMS; they are a regulated middle ground offering more strategy flexibility than mutual funds at a lower minimum ticket than PMS.
Who Are SIFs Suited For?
Branding and Disclosure Requirements
SEBI specialised investment funds are generally relevant for:
- Those who meet the ₹10 lakh minimum and are prepared for higher risk relative to conventional mutual funds
- Experienced investors comfortable with derivatives exposure, long-short positioning, and interval-based liquidity
- Investors evaluating dynamic asset allocation through an actively managed, multi-asset framework
- Investors seeking regulated alternatives to unregistered investment schemes or unauthorised portfolio products
SIFs carry relatively higher risk than traditional mutual funds, including potential capital loss, liquidity constraints, and market volatility. Investors should review the investment strategy information document (ISID) for each strategy before committing capital.
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Key Risks to Understand Before Investing
- Market risk: SIF returns are market-linked and not guaranteed. Long and short positions can both generate losses simultaneously depending on market conditions.
- Liquidity risk: Interval fund structures have fixed redemption windows. Investors must be prepared for periods of restricted access to capital.
- Execution and strategy risk: Complex strategies such as sector rotation and long-short equity depend on fund manager judgement. Poor timing or incorrect positioning can result in underperformance.
- Derivatives risk: Unhedged positions in derivatives amplify both potential gains and losses relative to a long-only portfolio.
- Limited performance history: As a category launched in April 2025, SIFs carry no long-term track record. Evaluation must rely on strategy design, fund manager credentials, and backtested data where disclosed.
Conclusion
Specialised investment funds represent a structurally distinct category within India's regulated investment space. Under SEBI's framework, they give eligible AMCs the tools to construct strategy-driven portfolios, long-short equity, active asset allocation, sector rotation, and hybrid approaches within a disclosure and governance structure aligned with mutual fund standards. For investors who understand the strategies involved, meet the ₹10 lakh threshold, and are prepared for the risk profile these instruments carry, SIFs are worth evaluating as part of a broader portfolio framework. As with any market-linked investment, outcomes depend on strategy execution and market conditions, and careful review of fund-level documents remains essential.
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