Who May Launch a SIF — AMC Eligibility
Not every fund house may launch a SIF. This lesson sets out the two eligibility routes, the clean-record condition and SEBI's approval, and explains what eligibility does and does not tell an investor.
A gate at the level of the fund house
A Specialized Investment Fund (SIF) may be launched only by a mutual fund, through its AMC, that has SEBI's approval and meets one of two eligibility routes. The test is applied to the fund house, not to any strategy it later offers.
Route 1: track record and size
Route 1 requires at least three years of operation and average assets under management (AUM) of at least ₹10,000 crore over the preceding three years. Both parts are needed: three years of operation without the AUM figure does not qualify under this route.
Route 2: experienced people
Route 2, the alternative, depends on the experience of the AMC's people. It requires a Chief Investment Officer with at least 10 years' experience who has managed average assets of at least ₹5,000 crore, and a fund manager with at least 3 years' experience who has managed average assets of at least ₹500 crore. Both persons are required.
Clean record and SEBI's approval
Each route also requires that no action has been initiated or taken against the sponsor or the AMC under sections 11, 11B or 24 of the SEBI Act in the previous three years. Broadly, these are the provisions under which SEBI exercises its regulatory powers, issues directions and proceeds against offences. The condition covers action initiated as well as action taken.
Meeting a route is not enough by itself: SEBI's approval is needed under either.
What eligibility does not tell you
Eligibility is a test of the AMC, not of any strategy. SIFs began only after February 2025, so none has a long record, whichever route its AMC used. A large or experienced fund house can still run a strategy that loses money: every SIF carries a warning that investments in a SIF involve relatively higher risk including potential loss of capital, liquidity risk and market volatility.
Rules at a glance
Three fund houses
Assume three fund houses, each with a clean regulatory record. Fund house P has operated for six years, with average AUM of ₹14,000 crore over the preceding three years: it meets Route 1.
Fund house Q has operated for four years with average AUM of ₹3,000 crore, so Route 1 is out of reach. But its Chief Investment Officer has 12 years' experience and has managed average assets of ₹6,000 crore, and a fund manager has 4 years' experience and has managed average assets of ₹700 crore: it meets Route 2.
Fund house R has average AUM of ₹2,000 crore. Its Chief Investment Officer meets the Route 2 test, but its fund manager has only 2 years' experience: it meets neither route. P and Q still need SEBI's approval.
Key points
- A SIF may be launched only by a mutual fund/AMC that meets SEBI's eligibility conditions and has SEBI's approval.
- Route 1: at least three years of operation and average AUM of at least ₹10,000 crore over the preceding three years.
- Route 2: a Chief Investment Officer with at least 10 years' experience who has managed average assets of at least ₹5,000 crore, plus a fund manager with at least 3 years' experience who has managed average assets of at least ₹500 crore.
- No SEBI action under sections 11, 11B or 24 of the SEBI Act against the sponsor or AMC in the previous three years.
Common misunderstandings
- Eligibility is not a rating of a strategy: it tests the AMC, and capital can be lost in a SIF from any eligible AMC.
- Route 2 needs both people: a Chief Investment Officer and a fund manager, each meeting the stated experience test.
- The clean-record condition is not limited to action already taken: it also covers action initiated.
Questions people ask
Does the ₹10,000 crore figure refer to the size of the SIF?
No. It is the mutual fund's average AUM over the preceding three years, a Route 1 condition. The minimum for an investor is a separate figure: ₹10 lakh.
Whose record is examined under the clean-record condition?
The sponsor's and the AMC's, over the previous three years.
Does meeting a route mean SIFs have a tested history?
No. SIFs began only after February 2025, so no SIF has a long track record.
What this lesson relies on
- SEBI Master Circular for Mutual Funds, 20 March 2026, Chapter 21 (Specialized Investment Funds)
- Securities and Exchange Board of India Act, 1992 (sections 11, 11B and 24)
This lesson was reviewed independently against these sources on 8 October 2026. Rules change: check the current regulation, scheme document or policy wording before relying on any figure. This is education, not advice.