SEBI’s revised periodic know-your-customer (KYC) review framework for foreign portfolio investors (FPIs) takes effect on 1 December 2026. Review periods depend on the jurisdiction’s risk classification as well as the FPI’s category and regulated status; it is not a universal eight-year cycle.
Jurisdiction and FPI category both matter
| Jurisdiction / treatment | FPI category | KYC review period | Official evidence |
|---|---|---|---|
| High-risk jurisdiction | Category I registered under Regulation 5(a)(i) | Every 8 years | SEBI circular dated 30 October 2026 |
| High-risk jurisdiction | Other Category I | Every 2 years | SEBI circular dated 30 October 2026 |
| High-risk jurisdiction | Category II | Every 2 years | SEBI circular dated 30 October 2026 |
| Non-high-risk jurisdiction | Category I | Every 8 years | SEBI circular dated 30 October 2026 |
| Non-high-risk jurisdiction | Regulated Category II entities | Every 8 years | SEBI circular dated 30 October 2026 |
| Non-high-risk jurisdiction | Other Category II | Every 2 years | SEBI circular dated 30 October 2026 |
| Existing separate treatment | GS-FPI | As applicable to their bank accounts under RBI directions | SEBI circular dated 30 October 2026 |
| Existing separate treatment | SWAGAT-FI FPI | Every 10 years | SEBI circular dated 30 October 2026 |
Registration continuance is a separate timetable
An FPI wishing to continue registration for a subsequent three-year block, or a ten-year block for SWAGAT-FI, must pay the applicable fee to its designated depository participant (DDP). The fee is due at least 15 days before the current registration validity ends. This is separate from the periodic KYC-review table.
The circular removes the separate change-information requirement at registration continuance. It does not say that all other applicable KYC or disclosure duties disappear. DDPs, custodians and depositories must update their systems and notify the affected FPIs.
What to check before the effective date
The practical task is to match each FPI’s jurisdiction risk, category and regulated status to the correct row. GS-FPI bank-account KYC follows applicable RBI periodicity; SWAGAT-FI FPI KYC remains every ten years. These preserved exceptions should not be confused with the general two- and eight-year rows.
Correction, 4 November 2026: The earlier table did not retain the circular’s high-risk/non-high-risk jurisdiction distinction. The table and explanation now show both jurisdiction and FPI category. The fee-continuance wording has also been made precise. Original publication date is unchanged.
Official source rechecked: 2026-11-03T19:40:41.982Z. SEBI circular dated 30 October 2026.
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