✅ Doing Business in GIFT City: Everything You Need to Know About BATF Regulations (2024)
- GIFT CFO
- Jul 17
- 4 min read
Updated: Jul 24
📌 Introduction: Why GIFT City Matters for Global Financial Services
GIFT City (Gujarat International Finance Tec-City) has emerged as India’s premier International Financial Services Centre (IFSC), offering a globally competitive regulatory environment under the International Financial Services Centers Authority (IFSCA). Among its newest developments are the BATF Regulations, 2024 — reshaping how financial, accounting, and compliance services operate in this special economic zone.
If you're a startup, investor, NRI, or a financial services provider eyeing opportunities in GIFT City, these FAQs will answer your top questions.
💼 Can a company in GIFT City offer both BATF and Ancillary Services?
Yes. Companies can be registered under BATF Regulations and simultaneously operate under the Ancillary Services Framework (dated 10 Feb 2021). However, they must maintain separate permissions and compliance under each framework.
❌ Can BATF-registered companies provide tax advice to Indian residents?
No. BATF services are strictly limited to non-residents, including other IFSC units. As per Regulation 19(1), providing tax advice to Indian businesses is not allowed.
🔁 What’s the process to transition from Ancillary Services to BATF Services?
Follow the guidelines in Regulation 4 and the Second Schedule of the BATF Regulations for a smooth transition. This includes applying for a new registration and complying with ring-fencing and reporting norms.
⏳ Can existing Ancillary Service Providers continue offering services during the transition?
Yes, they may continue their non-BATF services under pre-existing agreements during the transition, provided they’re in line with the original Ancillary Services authorization.
📊 How should a company separate BATF services from others?
Maintain separate books of accounts
Ensure distinct resource allocation
Segregate revenues and employee functions
Follow ring-fencing as per BATF’s Second Schedule
👥 Are there limits on employee transfers from India-based companies?
Yes. No more than 20% of a BATF Service Provider’s workforce in IFSC can be transferred from group entities in India.
🤝 Can BATF companies outsource or sub-contract to India?
No. BATF Services cannot be outsourced or subcontracted to any Indian entity, even to its own group companies.
🔄 Can BATF and Ancillary units in IFSC share resources?
Only during the transition period. Once fully transitioned, no resource-sharing is allowed to comply with the requirement of operational separation.
🧾 Does offering Fund Accounting Services require BATF registration?
No. If you offer Fund Accounting under Administration Services as per the Ancillary Framework, separate BATF registration is not required.
🏢 Should a company set up a new IFSC unit for BATF?
Not necessary. Existing IFSC units can offer BATF services upon obtaining registration. New setups are optional.
🔐 What does “ring-fencing” mean for BATF operations?
It means:
Maintaining separate financials for BATF vs. other services
Segregated compliance and reporting structures
No mixing of contracts or revenues
📝 Who needs to register under the BATF Regulations?
Any entity intending to provide Book-keeping, Accounting, Taxation, or Financial Crime Compliance services in IFSC must obtain an IFSCA Registration Certificate.
🛠️ What’s the process to register?
Refer to the IFSCA Circular dated June 28, 2024 for step-by-step application details and form requirements.
🛑 Are there exceptions to the registration requirement?
No. All service providers must register. Transitional relief was given only to existing Ancillary Service Providers for a period of up to 3 years.
🎓 What are the qualifications required for KMPs?
Defined in Regulation 11(3) of the BATF Regulations. Qualifications vary based on the services offered and roles assigned.
Can Indian businesses restructure to enter IFSC?
Not allowed. BATF applicants must not be formed by:
Splitting existing Indian businesses
Restructuring or reorganizing Indian operations
Taking over contracts from Indian group companies
🌍 Who can receive BATF services?
Only non-residents and IFSC units. Clients from FATF high-risk jurisdictions are strictly prohibited.
📑 What are the compliance obligations?
BATF entities must comply with:
Regulation 14 of BATF Regulations
IFSCA AML, CTF & KYC Guidelines, 2022
Periodic reporting and disclosures
👨💼 Can existing PO and CO serve both units?
Yes, but only during the 3-year transition period or until full migration.
🛎️ What steps should Ancillary Providers take now?
Apply for BATF registration within 3 years
Ring-fence BATF operations
Pay non-refundable registration and annual fees
🏢 What’s the office space requirement?
At least 60 sq. ft. per employee in IFSC premises.
💱 Which currencies can BATF companies operate in?
BATF Service Providers can transact in major foreign currencies including:
USD, EUR, GBP, JPY, SGD, AUD, CAD, CHF, AED, and others.
They may maintain an INR account for admin expenses only.
💸 What are the registration and annual fees?
Application Fee: $1,000 per activity
Registration Fee: $5,000 per activity
Annual Fee:
$5,000 (up to 500 employees)
$7,500 (501–1000 employees)
$10,000 (1001+ employees)
🏦 How to make fee payments?
USD Payments: To ICICI Bank via SWIFT
INR Payments (for India-based entities): To SBI using RBI exchange rates (7-day prior reference)
❓ Where can I get help with BATF regulations?
You can reach out to the Division of Ancillary Services, GIC & BATF at IFSCA for support.
📣 Conclusion: Ready to Establish in GIFT City?
The BATF Regulations of 2024 offer a structured framework for global service providers to operate with clarity and compliance in GIFT IFSC. Whether you're an NRI investor, Indian startup, or global finance firm — this is the time to leverage the regulatory transparency and strategic advantages offered by GIFT City.
👉 Need expert support? Reach out to GIFT CFO for end-to-end advisory, setup, and compliance solutions in GIFT City.
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