IFSCA Net Worth Certification and Annual Audit Framework for Global Access Providers
The International Financial Services Centres Authority has reinforced its supervisory oversight over Global Access Providers operating in GIFT IFSC. Through its circular dated 12 February 2026 prescribing a standard Net Worth Certificate format and issuing an indicative annual audit checklist, the regulator has strengthened capital monitoring, audit consistency, and governance expectations across the Global Access ecosystem.
This article provides a structured, compliance-focused overview of the framework, covering regulatory scope, ongoing net worth obligations, certification requirements, and the mandatory annual audit applicable to GAPs and certain broker dealers.
Regulatory Framework and Applicability
Global Access Providers facilitate access to overseas securities markets for eligible IFSC participants through regulated cross-border structures. Given the complexity and risk profile of such arrangements, IFSCA has adopted a capital-driven and systems-based regulatory model under the IFSCA Capital Market Intermediaries Regulations, 2025.
The February 2026 circular derives authority from:
- Sections 12 and 13 of the IFSCA Act, 2019
- Regulations 27 and 45 of the CMI Regulations, 2025
- The Regulatory Framework for Global Access in the IFSC dated 12 August 2025
The requirements apply to:
- All registered Global Access Providers
- Broker dealers accessing overseas markets on a proprietary basis through GAP structures
The circular formalises two principal compliance obligations:
- Annual Net Worth Certification
- Mandatory Annual Audit of Global Access operations
Net Worth Maintenance – Continuous Prudential Obligation
The prescribed net worth requirement is not limited to initial registration. It is an ongoing prudential safeguard that must be maintained at all times in accordance with clauses 13 and 14 of the GAP Circular.
Regulatory expectations include:
- Continuous adherence to minimum net worth thresholds
- Clear segregation of capital attributable to Global Access operations
- Availability of reliable and verifiable financial documentation
The objective is to ensure:
- Financial resilience of intermediaries
- Reduction of systemic and counterparty risk
- Strengthened market integrity in cross-border trading
Capital adequacy must remain aligned with the scale, structure, and complexity of operations undertaken by the GAP.
Net Worth Certification – Format and Submission
To standardise reporting and enhance independent assurance, IFSCA has prescribed a uniform Net Worth Certificate format to be issued by an independent Chartered Accountant.
Key Certification Requirements
The certificate must:
- State the net worth amount in USD as of a specified date
- Confirm compliance with clauses 13 and 14 of the GAP Circular
- Clearly identify the concerned GAP or broker dealer
- Be supported by a detailed Statement of Net Worth Computation
The certificate must also include:
- Name and signature of the certifying professional
- UDIN
- Date of issuance
Submission Timeline
- Required annually
- To be filed by 30 September for the preceding financial year
- Submitted directly to IFSCA through the prescribed regulatory channel
Management remains responsible for ensuring the accuracy and completeness of information forming the basis of certification.
Mandatory Annual Audit of Global Access Activities
In addition to net worth certification, IFSCA mandates a comprehensive annual audit of Global Access activities under clause 49 of the GAP Circular. This requirement applies to GAPs and, where applicable, Introducing Brokers.
Eligible Audit Professionals
The audit must be conducted by a peer-reviewed member of:
- The Institute of Chartered Accountants of India
- The Institute of Company Secretaries of India
- The Institute of Cost Accountants of India
The peer-review requirement reflects the regulator’s emphasis on audit quality and professional accountability.
Indicative Audit Scope – Core Areas of Review
IFSCA has issued an indicative audit checklist outlining the minimum scope expected during annual reviews. While not exhaustive, it provides a structured compliance benchmark.
1. Financial and Prudential Compliance
- Verification of minimum net worth and its segregation
- Review of financial statements
- Examination of securities holdings and bank records
- Confirmation of timely payment of regulatory fees
2. Fit and Proper Assessment
- Evaluation of directors, KMPs, and significant shareholders
- Independent background verification
- Review of governance declarations
3. Contractual and Compliance Responsibilities
- Examination of agreements with Introducing Brokers
- Clear demarcation of regulatory obligations
- Review of arrangements with foreign brokers
4. Permitted Products and Trade Controls
- Assessment of systems restricting trades to permitted products
- Review of monitoring mechanisms
- Escalation and internal control procedures
5. Infrastructure and Operational Readiness
- Adequacy of technology systems
- Business continuity arrangements
- Sufficiency of skilled personnel and segregation of duties
6. Fund Flow and Segregation Controls
- Routing of funds exclusively through IFSC bank accounts
- Audit trails for fund movements
- Segregation between IFSC and Global Access business activities
- Segregation of client funds and proprietary funds
7. Risk Management and Client Protection
- Review of risk management framework
- Complaint handling procedures
- Verification of client disclosures and communication standards
8. AML, KYC, and Regulatory Reporting
- Compliance with PML Rules, 2005
- Adherence to IFSCA AML, CFT, and KYC Guidelines, 2022
- Review of onboarding documentation and transaction monitoring
- Verification of quarterly regulatory filings
The audit checklist reinforces the expectation that compliance must be structured, system-driven, and demonstrable at all times.
Conclusion
IFSCA’s strengthened framework for net worth certification and annual audits represents a significant step toward enhanced prudential oversight of Global Access Providers. Continuous capital adequacy, formalised certification processes, and comprehensive annual audits are now integral to compliant and sustainable Global Access operations within IFSC.
