IFSCA Framework on Implementation Services for Investment Advisers in GIFT City IFSC

The International Financial Services Centres Authority released a detailed Consultation Paper on 13 November 2025, introducing a structured framework that defines how investment advisers registered in the GIFT City IFSC can support investors with implementation services.

This proposed framework matters because advisory activity in IFSC was already enabled, but the execution processes were not clearly defined. The proposal is expected to significantly enhance trust and regulatory transparency within the evolving GIFT City ecosystem.

Why the New Framework Matters for the GIFT City Advisory Landscape

GIFT City continues to grow as a global gateway for cross border investing. It connects international institutions, domestic investors, and global markets through a unified regulatory environment.

While IFSCA’s Capital Market Intermediaries Regulations 2025 permit investment advisers to support implementation, there was no comprehensive rulebook explaining how this support should function. The new framework fills this gap by ensuring:

• Transparency in execution

• Stronger investor choice

• Reduced conflict of interest

• Clear operational expectations for advisers

• Increased reliability for global counterparties

The result is a more resilient advisory ecosystem aligned with leading global financial hubs.

Key Highlights of the IFSCA Draft Framework

Implementation Services Allowed Through Regulated Channels Only

Investment advisers may assist clients in executing investment decisions. However, every transaction must pass through regulated intermediaries.

This structure includes:

• Foreign listed financial products must be executed through a Global Access Provider registered with IFSCA

• IFSC listed products must be executed through an IFSC-registered broker dealer

This prevents informal routes, reduces mis-selling, and ensures market integrity.

Flexibility for Products Not Listed on Foreign or IFSC Exchanges

For products outside recognized exchanges, advisers may collaborate with:

• International asset managers

• Global investment platforms regulated by foreign authorities

• Foreign product creators under recognised financial supervision

This widens investor access while retaining a strong compliance framework.

Implementation Services Are Always Optional

The framework makes it clear that clients must have complete freedom to choose how they wish to implement advice.

Investment advisers cannot compel clients to use any preferred partner or platform. This preserves independence and eliminates forced bundling.

Framework Aligns With IFSCA’s Global Access Regulations

The proposal links seamlessly with earlier Global Access guidelines issued on 12 August and 12 September 2025.

The outcome is a unified structure where advisers use

• Global Access Providers for foreign listed assets

• IFSC brokers for IFSC listed securities

This maintains supervisory oversight and avoids unregulated cross border execution.

Framework to Become Effective Upon Final Approval

Once finalised, the circular will come into effect immediately. IFSC intermediaries are expected to adjust seamlessly due to the clarity and simplicity of the proposed structure.

Impact on Stakeholders Across the GIFT City Ecosystem

Impact on Investors

Investors gain:

• Clear and regulated execution pathways

• Higher investor protection and reduced mis-selling

• Access to foreign securities and IFSC exchange-listed products

• Confidence through the use of licensed intermediaries

The framework supports both retail and institutional clients seeking global diversification.

Impact on Investment Advisers

The draft brings operational certainty by enabling:

• End-to-end advisory and execution support within IFSC regulations

• Collaboration opportunities with Global Access Providers and foreign-regulated platforms

• A streamlined compliance environment

• More competitive service offerings aligned with global standards

This positions advisers to serve global clients with greater confidence.

Impact on Global Access Providers and Broker Dealers

These intermediaries will benefit from

• Increased transaction volumes routed through their platforms

• Stronger partnerships with IFSC Investment Advisers

• Expanded participation in the IFSC ecosystem

This strengthens GIFT City’s infrastructure for cross-border investing.

Impact on the Broader GIFT City Ecosystem

The draft framework:

• Reinforces GIFT City as a world-class advisory and execution hub

• Aligns IFSC with global regulatory practices in Singapore, the UK, and Dubai

• Encourages global AMCs, custodians, and platforms to partner with IFSC advisers

• Builds long-term investor trust in India’s international financial centre

This supports GIFT City’s long-term vision of becoming a global capital markets destination.

Strategic Takeaway

The IFSCA Draft Framework for Implementation Services represents a foundational step toward a globally aligned investment advisory environment in GIFT City IFSC.

It ensures:

• Complete investor choice

• Clear execution channels

• Transparent and conflict-free advisory models

• Compliance aligned with international best practices

Once fully notified, the framework will empower investment advisers to deliver comprehensive and globally connected services, further elevating GIFT City as a trusted international financial hub.