Fee Structure for Setting Up a Payment System Operator in IFSC

Fee Structure for Payment System Operators (PSO) / Applicants desirous to setup a PSO in IFSC”, issued by IFSCA on April 2, 2025:

Purpose:

To define the applicable fee structure for Payment System Operators (PSOs) operating in or intending to operate in the International Financial Services Centre (IFSC).

Applicable Entities & Fees:

For all categories below:

CategoryAuthorisation FeeAnnual Recurring Fee
Real-time or Deferred Large Value Payment Systems$15,000$10,000
Trade Repository$5,000$5,000
Issuers of Legal Entity Identifier (LEI)$10,000$5,000
Card Payment Networks$15,000$15,000
TREDS Platforms (under PSS Act, 2007)$5,000$10,000
Any Other PSOs$15,000$10,000

Implementation:

The International Financial Services Centres Authority (IFSCA) issued a circular on April 4, 2025, amending the Guidelines on Corporate Governance and Disclosure Requirements for a Finance Company under the IFSCA (Finance Company) Regulations, 2021.

Key highlights of the amendment:

07 April 2025: Amendment to the Framework for Ship Leasing and Related Circulars

Key Changes:

  1. Currency for Conduct of Business:
    • Lessors must now issue invoices in any foreign currency listed in the IFSCA (Banking Regulations), 2020.
    • Payments must be received in a foreign currency account with an IFSC Banking Unit.
    • Lessors are allowed to open SNRR accounts with authorized dealers in India (outside IFSC) for business transactions outside IFSC, under FEMA rules.
  2. Restriction on Transactions with Indian Residents:
    • Lessors or applicants under the Ship Leasing Framework (SL Framework) holding a Certificate of Registration (CoR) cannot facilitate ownership or leasehold transfers of ships from Indian residents to IFSC entities if the ship is used solely to serve Indian residents in a single financial year.
  3. Exception:
    • This restriction does not apply if the ship being transferred is a new vessel acquired from an Indian shipyard.

These amendments are effective immediately and aim to refine regulatory clarity and foreign exchange alignment in IFSC ship leasing operations.

The “Framework for Finance Company/Finance Unit undertaking the activity of Global/Regional Corporate Treasury Centres (GRCTC)”, issued by the International Financial Services Centres Authority (IFSCA) on April 4, 2025, outlines the updated regulatory structure for entities operating or intending to operate as GRCTCs in IFSCs

Purpose and Scope

Key Provisions

1. Registration Requirements

2. Permissible Activities (Clause 13 & Annex II)

GRCTCs can:

Note: Factoring requires separate registration under the IFSCA Factors Regulations, 2024.

3. Governance & Compliance

4. Operational Guidelines

5. Fee Structure

6. Repeal & Transition

IFSCA Framework for Transition Bonds – Date: April 2025

Background

India’s commitment to the Paris Agreement necessitates mobilizing over USD 10 trillion in climate investments by 2070. While ESG-labelled debt markets have grown significantly (USD 5.4 trillion globally), financing remains skewed toward low-carbon sectors.
Hard-to-abate sectors—including steel, cement, aviation, and shipping—are responsible for ~40% of global GHG emissions and lack access to adequate capital despite long-term decarbonization goals.

Why Transition Finance?

IFSCA’s Proposed Framework Overview

Based on the Expert Committee’s input, the framework aims to provide regulatory clarity, boost investor confidence, and reduce greenwashing risks.

Key Components

  1. Eligible Activities
    Must align with recognized global/regional taxonomies (e.g., EU, ASEAN, Japan, India).
  2. Credible Transition Plan
    • Entity-level decarbonization strategy.
    • Aligned with Paris Agreement (well below 2°C; aim for 1.5°C).
    • Includes clear targets, timelines, and progress metrics.
  3. Independent External Review
    • Mandatory for each issuance.
    • Forms: Second-party opinion, certification, scoring, or rating.
    • Must assess scientific alignment and disclosure quality.
  4. Disclosures
    • Initial: Transition strategy, emissions targets, CapEx plans, governance oversight.
    • Annual: GHG progress, Scope 3 emissions, carbon credit usage, and project updates.
    • Reference to ICMA Climate Transition Finance Handbook is encouraged.

Public Consultation

Strategic Implication

This framework is a critical enabler for India’s transition finance ecosystem, especially within GIFT IFSC, positioning it as a regional hub for sustainable finance. It will help channel capital into high-impact, emissions-intensive sectors essential for meeting net-zero goals.

8 April 2025: Revision in IBU Governance Meeting Requirements

The International Financial Services Centres Authority (IFSCA) has revised the governance norms for IFSC Banking Units (IBUs). Effective immediately, the governing body of each IBU must convene at least once every quarter during the financial year, with the flexibility to hold additional meetings as required. This replaces the earlier stipulation under the Governance Directions in the IFSCA Banking Handbook (GEN V 5.0). The change has been made under Sections 12 and 13 of the IFSCA Act, 2019, and aims to enhance regulatory clarity while ensuring continued oversight.

08 April 2025: The IFSCA has announced the transition to the new Fund Management Regulations, 2025, effective from February 19, 2025, replacing the 2022 regulations. 

Key changes include:

  1. Validity of Private Placement Memorandums (PPMs): Extended from 6 to 12 months for Venture Capital and Restricted Schemes.
  2. Minimum Corpus Requirement: Reduced from USD 5 million to USD 3 million for eligible schemes.
  3. Transition Provision: Schemes filed under the 2022 regulations can launch under the new regime if:
    • Taken on record within 6 months before Feb 19, 2025, or
    • Had valid extensions extending beyond Feb 19, 2025.
  4. One-Time Re-Filing Opportunity: FMEs may re-file expired PPMs (prior to Feb 19, 2025) within 3 months under specific conditions, with a 50% reduced filing fee.
  5. No Processing Fee: Changes mandated due to regulatory updates or Authority action are exempt from processing fees.

This circular is effective immediately and aims to facilitate a smooth transition while providing relief to FMEs with lapsed schemes.

17 April 2025: Amendments to  the “Framework for enabling Ancillary Services at International Financial Services Centres

The amendment expands the scope of “Trusteeship Services” in response to market requests. Specifically, Clause 4.3 of Annexure I to the IFSCA (Ancillary Services) Framework, 2021 has been revised to include Trusteeship Services for various financial structures, including Alternative Investment Funds (AIFs), Investment Trusts (e.g., InvITs, REITs), Family Investment Funds (FIF), and Security Trust arrangements. The amendment also extends Trusteeship Services to retail schemes launched by Fund Management Entities (FMEs), subject to compliance with relevant regulations.

This amendment takes effect immediately and does not affect other provisions of the original framework. The circular is issued under the powers granted by the IFSCA Act, 2019.

22 April 2025: Clarification on conducting Customer Due Diligence (CDD) and Maintenance of Supply Chain Integrity by the Vault Managers

This circular provides clarification regarding the conduct of Customer Due Diligence (CDD) and maintenance of supply chain integrity by Vault Managers in the International Financial Services Centre (IFSC), as outlined under the IFSCA (KYC/AML-CFT) Guidelines, 2022, and the Bullion Guidelines.

  1. Customer Due Diligence (CDD) for Vault Managers:
    • Vault Managers, as regulated entities, must conduct CDD on customers, including ultimate beneficial owners of Bullion Depository Receipts (BDRs). This applies to both domestic and international customers, such as suppliers, buyers, and members of the Bullion Exchange.
    • The Vault Manager may rely on CDD conducted by the Bullion Depository, but must also independently verify the due diligence of customers they onboard.
    • Vault Managers must ensure that agreements with overseas logistics service providers require them to undertake CDD on bullion suppliers in accordance with FATF guidelines or the regulatory framework of the supplier’s jurisdiction.
  2. Maintenance of Supply Chain Integrity:
    • Vault Managers are responsible for ensuring the integrity of the bullion supply chain, ensuring that the bullion remains under custody of the Vault Manager or its authorized logistics partners from the point of origin to receipt in the vault.
    • Custodial arrangements must be formalized in contracts, ensuring continuous custody of the bullion through transportation, storage, and delivery.
  3. Compliance Responsibility:
    • The Bullion Depository is responsible for ensuring that Vault Managers comply with the supply chain integrity requirements.

The circular, effective immediately, is issued under the powers of the International Financial Services Centres Authority Act, 2019, and related regulations.

Clarifications on Fee Structure for Entities in IFSC

On April 23, 2025, the International Financial Services Centres Authority (IFSCA) issued a circular to clarify and amend certain provisions of the fee structure outlined in the previous circular (IFSCA-DTFA/1/2025 dated April 8, 2025) for entities operating in the International Financial Services Centres (IFSC) or seeking guidance under the Informal Guidance Scheme.

Key Clarifications and Amendments:

  1. Processing Fees for Fund Management Entities (FME):
    • A fee of USD 500 will be applicable for modifications to scheme documents launched by FMEs.
  2. Late Fees for Periodic Returns:
    • Late fees for failure to submit periodic returns will apply per activity for each Regulated Entity (RE).
  3. Changes in Key Managerial Personnel (KMP):
    • A fee of USD 250 will apply for intimation of changes in KMPs, Directors, Designated Partners, Trustees, or similar positions in FMEs.
  4. Payment Service Providers (PSP) and Payment System Operators (PSO):
    • Clarifications were made on the application, license, registration, and recurring fees for various PSP and PSO activities, including services like account issuance, e-money issuance, escrow, cross-border money transfers, etc.
    • For Significant Payment Service Providers (SPSP), the annual fee for each activity will be USD 10,000.
  5. Finance Companies:
    • Clarified that fees for Finance Companies undertaking permissible core activities will apply separately for each activity.
  6. Recurring Fees:
    • The annual recurring fees for certain entities (like PSOs and PSPs) will be payable starting the financial year immediately following the issuance of their registration certificate.
  7. Turnover-Based Fees for Stock Exchanges:
    • For stock exchanges with turnover exceeding USD 150 billion, a conditional fee of USD 150,000 plus a percentage of the excess turnover will apply.
  8. Implementation Timeline:
    • The revised fees will apply for FY 2025-26. Entities that have already paid fees before the issuance of the circular may need to pay differential fees by May 10, 2025, or the due date specified in the original Fee Circular.

These changes aim to streamline and clarify the fee structure for entities engaged in permissible activities within IFSCs, ensuring alignment with current operational realities. The circular is effective immediately.

29 April 2025: Amendment to the “IFSCA Operating Guidelines on Bullion Exchange, Bullion Clearing Corporation, Bullion Depository and Vault Manager – Dispensation of net-worth requirement for ‘Customers.

The International Financial Services Centres Authority (IFSCA) has amended the Operating Guidelines on Bullion Exchange, Bullion Clearing Corporation, Bullion Depository, and Vault Manager. This amendment, effective immediately, dispenses with the net worth requirement for all classes of ‘Customers’ participating in the bullion market at the International Financial Services Centre (IFSC). This change follows a representation from India International Bullion Exchange (IIBX) to broaden participation across various products.

However, the net worth requirements for Qualified Suppliers and Qualified Jewellers, as specified in previous circulars (18th August 2022 and 11th December 2023), remain in place. The amendment is issued under the authority of the International Financial Services Centres Authority Act, 2019.

Press release dated 29 April 2025: Infusing Vibrancy into GIFT IFSC’s Bullion Ecosystem

The International Financial Services Centres Authority (IFSCA), established by the Government of India, is spearheading efforts to position GIFT IFSC in Gujarat as a premier global hub for bullion trading. Central to this vision is the India International Bullion Exchange (IIBX), launched in July 2022, through which over 101 tonnes of gold and 1,100 tonnes of silver have been imported, reflecting early traction.

To deepen market vibrancy and accessibility, IFSCA recently introduced the Bullion Market Regulations, 2025, focusing on improving price discovery, governance, participation, and consumer protection. Complementing this regulatory push, IIBX has extended its spot trading hours to 12.5 hours (9 AM–9:30 PM), aligning better with international markets and enhancing same-day trade settlement efficiency—especially for Qualified Suppliers and CEPA TRQ holders.

Crucially, IFSCA has eliminated net worth requirements for most customer categories, lowering entry barriers and enabling broader participation, including from retail investors. Eligibility criteria remain for key players such as Qualified Jewellers and Suppliers. These reforms are poised to make bullion trading more cost-effective, inclusive, and liquid, strengthening India’s foothold in the global bullion landscape via GIFT IFSC.

17 April 2025: Public Comments on Draft IFSCA (KYC Registration Agency) Regulations, 2025

The primary concerns and suggestions revolve around clarity, compliance alignment, operational efficiency, and global competitiveness.

Key Themes & Recommendations:

  1. Terminology & Definitions: Clarification sought on terms like “Foreign Jurisdiction” and “change in control”. Suggestions include using “Recognized Foreign Jurisdiction” and defining control parameters.
  2. Registration & Eligibility:
    • Stakeholders request detailed guidance on application formats, registration fees, and fund allocation norms.
    • Proposals include allowing MIIs to act as KRAs for a transitional period and exempting them from additional net worth or fit-and-proper criteria.
  3. AML/CFT Compliance:
    • Stronger alignment with FATF, PMLA, SEBI guidelines.
    • Clear requirements for independent KYC validation, AML audits, and sanctions screening (e.g., OFAC lists).
  4. Data Protection & Cybersecurity:
    • Inclusion of the Digital Personal Data Protection Act, 2023, and GDPR compliance where applicable.
    • Proposals for automation, audit trails, and secure data sharing standards across KRAs.
  5. Operational Framework:
    • Defined roles for Principal and Compliance Officers, with relaxed qualifications for experienced professionals.
    • Emphasis on staff training, SOPs, disaster recovery, business continuity, and internal audits.
    • Calls for recognizing CFP® as an eligible qualification for key roles.
  6. Interoperability & Global Integration:
    • Push for system compatibility with SEBI KRAs, CKYCR (India), and international KYC platforms.
    • Recommendations to develop GIFT IFSC as a global KYC hub.
  7. Client & RE Handling:
    • Specific procedures for onboarding, de-linking, re-KYC, and KYC feed sharing.
    • Requirement for unique client identifiers and clearer timelines for KYC uploads and updates.
  8. Governance, Compliance, and Dispute Resolution:
    • Suggestions for investor grievance committees, whistleblower mechanisms, dispute resolution frameworks (akin to SEBI), and flexibility in enforcement for innovation.
  9. Miscellaneous:
    • Uniformity in formatting, regulatory references to PMLA, clarification on the status of KRAs as reporting entities, and roles of RTAs.

These inputs underscore the importance of regulatory clarity, global alignment, robust governance, and adaptability for operational and technological evolution in the IFSC ecosystem.

17 April 2025: The IFSCA published a draft of the Capital Market Intermediaries (CMI) Regulations, 2025, inviting public comments. 

The proposed framework introduces new categories of intermediaries, adjusts net worth requirements, and redefines roles and qualifications, particularly for ESG Rating and Data Product Providers (ERDPPs).

 The comments received reflect strong support for regulatory modernization, accompanied by concerns about implementation challenges, potential overregulation, and operational feasibility within the IFSC (particularly GIFT City).

Key Public Comments

1. Registration & Categories

2. Principal Officer (PO) Requirements

3. Net Worth Requirements

4. Broker-Dealers – Global Access

5. Operational & Compliance Flexibility

6. Code of Conduct & Risk Management

7. Miscellaneous

Overall Stakeholder Sentiment

Revised Framework for International Trade Finance Services (ITFS) Platform as updated on April 11, 2025 by the IFSCA:

The IFSCA has issued updated guidelines for the establishment and operation of the International Trade Finance Services (ITFS) Platform, under the IFSCA (Finance Company) Regulations, 2021. These revised norms aim to enhance the regulatory clarity and operational efficiency for ITFS operators and participants at International Financial Services Centres (IFSCs).

Key Highlights:

  1. Scope & Applicability:
    • Applicable to both existing ITFS operators and new applicants seeking registration.
    • Covers exporters, importers, financiers, insurance/credit guarantee institutions, and payment service providers.
  2. Registration & Eligibility:
    • Applicants must be newly incorporated companies with at least three years of experience in financial market infrastructure or fintech platforms.
    • A minimum owned fund requirement of USD 0.2 million is mandated.
    • Applicants must satisfy stringent ‘fit and proper’ criteria.
  3. Permissible Activities:
    • ITFS can facilitate a range of trade finance services, including factoring, reverse factoring, bill discounting under LC, supply chain finance, pre-shipment credit, and forfaiting.
    • Secondary market transactions of these services are also allowed.
  4. Operational Framework:
    • Platforms must support transparent, real-time bidding with robust MIS and ensure participant anonymity.
    • Financiers must have USD 5 million in AUM or loan book and capital, along with credit recovery capability.
    • ITFS operators must not assume credit risk and must establish a grievance redressal mechanism.
  5. Technology & Outsourcing:
    • Mandatory annual IT/IS audits, disaster recovery systems, and business continuity plans.
    • Critical operations such as participant onboarding and daily platform management cannot be outsourced.
  6. Currency & Settlement:
    • Books to be maintained in USD; transactions can occur in any specified foreign currency.
    • Clearing and settlement functions require additional authorization under payment regulations.
  7. Governance:
    • Requires board-approved corporate governance policy and ongoing compliance with fit and proper standards.
    • Strong compliance obligations under AML/KYC, FATF, and IFSCA directions.
  8. Transition & Repeal:
    • Supersedes the previous framework issued on July 9, 2021.
    • Existing actions taken under the old framework are deemed valid under the new guidelines.

IFSCA Fee Circular (April 8, 2025)

The International Financial Services Centres Authority (IFSCA) has issued a comprehensive circular outlining the fee structure for entities operating in or intending to operate in IFSCs, or those seeking guidance under the Informal Guidance Scheme, 2024. The circular applies to all applicants, regulated entities (REs), and guidance seekers.

Key Highlights:

  1. Categories of Fees:
    • Application Fees
    • License/Registration/Authorization Fees
    • Annual Recurring Fees (Flat and Conditional based on turnover/employees)
    • Activity-Based Fees
    • Processing Fees (for modifications, relaxations, and leasing approvals)
    • Late Fees
    • Informal Guidance Scheme Fees
  2. Annual Recurring Fees:
    • Calculated pro-rata in the year of registration.
    • Conditional fees adjust annually based on actual turnover/employee count.
    • Flat fees are due by April 30 each year.
  3. Late Payments:
    • Subject to 0.75% monthly interest.
    • Delay in return filing incurs $100 per month per instance.
  4. Informal Guidance:
    • $1,000 per request.
    • 75% refund if the request is non-compliant.
  5. Special Processing Fees:
    • Substantive modifications attract 20% of original license fees.
    • Aircraft/ship leasing resource utilization applications incur a $2,500 one-time fee.
  6. Refund & Waiver Policy:
    • No refunds once fees are paid, except for overpayments which may be adjusted.
    • Waivers possible in exceptional cases.
  7. Payment Details:
    • USD remittance through ICICI Bank (SWIFT and NOSTRO provided).
    • INR option for Indian applicants not yet operational in IFSC.
  8. Supersession:
    • Several earlier circulars are repealed; Schedule-I of the July 3, 2024 circular ceases to be effective.
  9. Sector-Specific Schedules:
    • Detailed fee structures provided for Banking, Capital Markets, Commodities, Insurance, FinTech, Ancillary Services, and more.
  10. Implementation:
    • Effective immediately under the authority of Sections 12 & 13 of the IFSCA Act, 2019

Public Comments on Revised framework for Global/Regional Corporate Treasury Centres (GRCTCs) in the International Financial Services Centre (IFSC), issued by the  IFSCA.

The feedback reflects comprehensive industry engagement and provides detailed recommendations to enhance clarity, flexibility, and attractiveness of the framework. Below are the key highlights:

1. Definitions and Scope

2. Eligibility and Restrictions

3. Permissible Activities

4. Operational Flexibility

5. Governance and Risk Management

6. Regulatory and Procedural Aspects

7. Legal and Compliance Considerations

Conclusion

The comments emphasize a strong industry demand for greater regulatory flexibility, clarity, and operational leeway to make GRCTCs in IFSC globally competitive. Stakeholders advocate for a framework that aligns with international best practices while supporting ease of doing business for both Indian and multinational enterprises.

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