Global Access via IFSC: Structuring Cross-Border Investment Services for Brokers
Unlock overseas investment opportunities through GIFT City’s evolving regulatory gateway. Here’s how brokers and intermediaries can align with IFSCA’s Global Access Framework post-August 2025.
What Is Global Access in IFSC and Why It Matters
In August 2025, the International Financial Services Centres Authority (IFSCA) released a landmark circular launching the Global Access Framework, setting the stage for brokers and capital market intermediaries (CMIs) registered in GIFT City to offer cross-border investment services in a structured and compliant manner.
This framework enables IFSC broker-dealers and eligible intermediaries to facilitate trading in overseas securities—foreign equities, ETFs, and debt instruments—for their clients, including resident investors using RBI’s LRS (Liberalised Remittance Scheme), NRIs, and eligible foreign clients. By regulating this channel, IFSCA has created a powerful alternative to informal or unregulated foreign access arrangements.
The move not only enhances investor protection but firmly positions GIFT City as a credible investment gateway for cross-border financial products.
Eligibility: Who Can Become a Global Access Provider or Introducing Broker?
IFSCA recognises two key roles under this framework:
Global Access Provider (GAP)
An IFSC-registered broker-dealer or a subsidiary of an IFSC-recognised stock exchange that establishes direct access to global exchanges or foreign brokers.
Introducing Broker (IB)
An intermediary registered in the IFSC that facilitates access for clients via an arrangement with a GAP. It does not directly execute trades but serves as the onboarding and relationship entity.
Both must be registered under the IFSCA (Capital Market Intermediaries) Regulations, 2025, and separately authorised for Global Access activity.
Step-by-Step: How to Structure Your IFSC Entity for Global Access
Registration and Licensing Requirements
- Apply for authorization from IFSCA using the SWIT portal.
- Ensure you hold a valid broker-dealer license as a CMI.
- Minimum net worth requirements:
- USD 500,000 for GAPs serving clients
- USD 200,000 for proprietary GAPs
- USD 100,000 for Introducing Brokers
Fund Flow Mechanism – Banking Units vs. PSPs
Client funds must be routed through:
- IFSC Banking Units (as per original circular), or
- IFSCA-authorised Payment Service Providers (PSPs) — permitted from September 12, 2025 onward via official amendment.
Each provider must maintain:
- Separate accounts for client funds
- Segregated accounts for Global Access vs. other activities
- Full transparency in routing and reconciliation
Client Eligibility and LRS Considerations
- Indian residents must invest under LRS within the permitted USD 250,000 limit.
- NRIs and foreign clients are allowed subject to FEMA rules.
- Robust KYC/AML checks are mandatory, including FATCA/CRS where applicable.
Product Restrictions and Permissible Instruments
Global Access can be used for:
- Foreign stocks, ETFs, mutual funds, and bonds
Not allowed: - Crypto assets or derivatives
- Products already listed on IFSC exchanges (e.g., Nifty derivatives, USD-INR contracts)
Disclosure, Risk Management & Compliance Duties
- Written client disclosures (product risks, fees, jurisdictions)
- Periodic reporting to IFSCA
- Annual audit by a CA/CS
- Marketing to follow IFSCA’s advertisement code and ethical guidelines
Operational Checklist for IFSC Brokers Offering Cross-Border Access
| Requirement | Status |
|---|---|
| Global Access Authorization | Must apply to IFSCA |
| Net Worth Threshold Met | USD 100K–500K as applicable |
| Dedicated Bank/PSP Accounts | Segregated and IFSC-based |
| Client Agreements and Disclosures | Aligned with framework |
| Internal Compliance Policies (KYC, AML) | Must be implemented |
| Quarterly Reporting and Annual Audit | Mandatory |
Business Opportunity: Why This Matters to Indian and Global Brokers
The Global Access framework opens new growth avenues for:
- Domestic brokers looking to serve Indian investors seeking international diversification.
- Foreign brokerages setting up IFSC presence to tap into India’s LRS-driven capital flow.
- Fintechs and wealth managers offering global baskets, ETFs, and thematic portfolios.
- Traditional firms evolving toward advisory-cum-execution models with cross-border reach.
Backed by regulatory clarity and flexible fund flow models (thanks to the PSP amendment), GIFT City now competes with global hubs like Singapore and Dubai for cross-border capital markets activity.
How We Help: Advisory, Structuring, and Compliance Support
With over 15 years of experience in capital markets, transaction advisory, and regulatory compliance, our firm operates directly from GIFT IFSC and has assisted multiple brokers and fintechs in navigating the IFSCA landscape.
Our team of Chartered Accountants and Company Secretaries offers end-to-end support including:
- Entity structuring and licensing
- Global Access authorization filing
- PSP/banking setup and fund routing design
- SOP drafting for client onboarding and compliance
- Audit and ongoing compliance reporting assistance
Final Thoughts
Global Access via IFSC is not just a compliance obligation, it’s a strategic opportunity to expand your firm’s global reach through a secure, regulated, and internationally credible jurisdiction. The August and September 2025 frameworks by IFSCA offer a robust playbook for brokers, CMIs, and fintechs ready to lead in the next phase of global investing from India.
Ready to set up your Global Access desk in GIFT City?
Partner with Nexpective Advisors, India’s trusted IFSC advisory team, and build a fully compliant, scalable, and client-ready Global Access platform.
