Market regulator Securities and Exchange Board of India (SEBI) has cancelled the certificate of registration (CoR) of Firstcapital Alternate Investment Trust after finding that the alternative investment fund (AIF) repeatedly failed to file its mandatory quarterly activity reports (QARs) for four consecutive quarters in 2025, despite being required to do so under the AIF Regulations and SEBI's reporting framework.
In the order, SEBI said the AIF failed to submit QARs for the quarters ended March 2025, June 2025, September 2025 and December 2025. Under Regulation 28 of the SEBI (Alternative Investment Funds) Regulations, 2012, read with SEBI's Master Circular dated 7 May 2024, all registered AIFs are required to submit quarterly activity reports within 15 calendar days from the end of each quarter through the SEBI intermediary (SI) portal.
Following the non-compliance, SEBI initiated summary proceedings under Regulation 30A of the SEBI (Intermediaries) Regulations, 2008, and issued a show-cause notice (SCN) to the fund on 27 April 2026. Since the notice sent through registered post and email remained undelivered, SEBI affixed the SCN at the fund's last known address in June 2026.
In its response, Firstcapital Alternate Investment Trust admitted the delay in filing the reports. It argued that it had neither raised capital nor made any investments or onboarded investors since registration and, therefore, the pending reports were 'NIL' returns. The fund also cited personal and medical issues faced by key personnel and technical problems with the SI Portal as reasons for the delay. It further informed SEBI that it had attempted to file the pending reports and had submitted the XML files to the regulator.
SEBI, however, rejected these submissions. The regulator observed that the AIF Regulations do not exempt funds with no business activity from filing quarterly reports. It held that the obligation to submit QARs is a statutory requirement linked to holding a valid AIF registration and continues until the registration is formally surrendered and accepted by SEBI.
The market regulator also noted that subsequent attempts to file the pending reports could not erase the earlier violations. It emphasised that mandatory reports must be filed through the SI Portal in accordance with the regulations, and that procedural lapses affecting regulatory reporting cannot be ignored merely because the fund had no investors or investments.
Holding that the violations had been established, SEBI exercised its powers under Section 12(3) of the SEBI Act, 1992, read with Regulation 30A of the SEBI (Intermediaries) Regulations, 2008, and cancelled the certificate of registration of Firstcapital Alternate Investment Trust.
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