When SEBI's board met on 24 September 2026, it approved the largest change to the accredited investor India framework since the status entered the AIF Regulations in August 2021. Portfolio managers, AIF managers and the asset managers that run Specialized Investment Funds will be allowed to accredit clients themselves. A new route will open for anyone holding at least ₹5 crore in securities market assets, and every person resident outside India will be treated as accredited by default. The changes need amended regulations before they apply, but clients who expect to qualify are already asking about them.
The question those clients ask is usually whether accreditation opens doors abroad. For Indian products such as AIFs and PMS, accreditation matters a great deal, because it removes minimum ticket sizes and opens products reserved for accredited investors. For money going outside India, it changes very little. The client's overseas investment still moves under the Liberalised Remittance Scheme, still attracts TCS, and still has to meet US securities rules that make no reference to a SEBI certificate. Raveum's guide to GIFT City mutual funds and other global routes sets out where each overseas route sits, and accreditation does not move any of them.
What the accredited investor India rules say today
Under the AIF Regulations, an individual, HUF, family trust or sole proprietorship can qualify today in one of three ways, according to SEBI's consultation paper of 13 August 2026. The first is annual income of at least ₹2 crore, and the second is net worth of at least ₹7.5 crore, of which ₹3.75 crore sits in financial assets. The third combines annual income of at least ₹1 crore with net worth of at least ₹5 crore, including ₹2.5 crore in financial assets. Body corporates and trusts other than family trusts need net worth of at least ₹50 crore.
The certificate comes from one of two SEBI-recognised accreditation agencies, CDSL Ventures and NSDL Database Management, and clients currently choose between a two-year and a three-year certificate, according to SEBI's board memo on the proposals. The memo counts 4,492 accredited investors on 28 August 2026, against 649 on 29 May 2025, and puts their holding of AIF units at about ₹2.31 lakh crore on 31 July 2026.
What SEBI's board approved in September
The press release from the 24 September meeting lists four changes. First, AIF managers, portfolio managers and asset managers offering SIFs will be permitted to accredit investors, while the agency route continues alongside them. Individuals, HUFs, family trusts and sole proprietorships will be able to qualify on securities market exposure of at least ₹5 crore, and body corporates and other trusts on ₹20 crore. Persons resident outside India, as defined under FEMA, including foreign portfolio investors, will be deemed accredited, and LLPs will qualify where every partner is accredited.
Accreditation under either route will be valid for three years, and status granted by a manager will be portable across AIF, SIF and PMS products within the same group. The consultation paper makes clear that the new route does not let a client certify their own status. A manager must assess evidence such as a recent income tax return, a CA's net worth certificate or broker statements.
Two practical points follow. The securities market route counts holdings rather than net worth, so a client with a large demat portfolio and significant borrowings can still qualify. The law firm LKS made this point when it wrote that the test "may overstate an investor's ability to absorb losses". NRI clients, for their part, will no longer need a certificate once the change is notified, because the deeming rule covers every person resident outside India.
What accreditation opens up inside India
Accreditation earns its value in Indian products. According to SEBI's consultation paper, accredited investors can invest in AIFs, PMS and SIFs without the minimum ticket sizes that apply to other clients, and special situation funds accept them at a lower threshold. Angel funds, co-investment vehicles, schemes reserved for accredited investors and large value funds are open only to them.
The same board meeting approved new Portfolio Managers Regulations, 2026, which will enable investment in foreign securities under both discretionary and non-discretionary PMS. The press release lists listed equity, debt, REITs, overseas mutual funds, ETFs, index funds and foreign government debt, all governed by FEMA and the RBI's LRS. That matters for clients weighing a PMS route abroad, which the earlier note on PMS overseas investment covers in more detail, but the overseas leg stays tied to the client's remittance limit.
Why accreditation does not change the overseas rules
Every rupee a resident client sends abroad still counts against the RBI's LRS limit of USD 250,000 per resident individual per financial year. Accreditation does not raise that ceiling, and it does not change TCS either. Under Section 394 of the Income-tax Act, 2025, LRS remittances above ₹10 lakh attract TCS of 20 per cent where the purpose is not education or medical treatment, as the guide to TCS on foreign remittance explains.
For example, a newly accredited client who remits ₹1.5 crore for an overseas investment in tax year 2026-27, within the year's LRS limit, would have TCS of 20 per cent collected on the ₹1.4 crore above the threshold. That comes to ₹28 lakh. The client can claim it as a credit in the income tax return, but the cash is tied up until then, and accreditation plays no part in the calculation.
The US side works the same way. The SEC defines an accredited investor in its own rules. For an individual, the financial tests are net worth above USD 1 million excluding the primary residence, or income above USD 200,000, or USD 300,000 with a spouse or partner, in each of the prior two years. A Rule 506(c) offering requires every purchaser to be accredited under that definition and the issuer to take reasonable steps to verify it. Because those tests make no reference to SEBI, a client accredited in India still has to meet them separately wherever a 506(c) offering applies.
For most clients living in India, the more relevant US rule is Regulation S, which covers offers and sales that take place outside the United States. The question there is where the sale happens and who the buyer is, and each offering's own documents then set out who is eligible. Indian clients who invest in private US commercial real estate this way typically do so through a US corporation, known as a blocker, which holds the property interest, and they typically receive Form 1042-S for US tax withheld. The guide to US commercial real estate investment for advisors explains that structure.
None of this makes an investment less risky. Private US real estate can lose capital, stays illiquid for years, and depends on property values holding up and tenants staying. Sponsors can cut or stop distributions, and leverage, currency movements and concentration in a few properties add to those risks. Accreditation shows that a client passed an income, wealth or holdings test. It does not show whether the client can afford to have the money locked up or reduced.
What advisors should do before the changes take effect
The first step is to sort clients by route. Those already accredited through an agency should note when their certificate expires and ask the manager which rules will apply at renewal. Clients near the ₹5 crore securities market line can gather recent eCAS or broker statements now. NRI clients should be told that the deeming rule is approved but not yet notified, so AIF and PMS managers will apply the current rules until SEBI issues the amended regulations.
The second step is to keep the overseas plan separate from the accreditation file. LRS headroom, the TCS cash flow and the CA's view on Schedule FA reporting decide what the client can do abroad. Advisors who introduce eligible clients through Raveum's partner page will see the same separation in practice. Eligibility for a US offering is checked against that offering's own rules, Raveum handles KYC, the agreements and the US tax forms, and the client's Indian tax position stays with the client and their CA.
SEBI's September decisions will make accreditation easier to obtain and more widely held, and the number of accredited investors has already grown almost sevenfold in fifteen months. The status is best read as a pass to India's private markets, not to overseas ones. Clients who assume the word accredited opens the rest of the world need the distinction explained before a remittance is planned around it. The guide to GIFT City mutual funds and other global routes remains the place to start that conversation, because the route, the remittance and the tax cost are what decide an overseas plan.
Frequently asked questions
What is the eligibility criteria to become an accredited investor in India?
An individual qualifies today with annual income of at least ₹2 crore, net worth of at least ₹7.5 crore with ₹3.75 crore in financial assets, or ₹1 crore of income plus ₹5 crore of net worth with ₹2.5 crore in financial assets. SEBI's board has also approved a ₹5 crore securities market route, which applies once notified.
How does a client get accredited investor status in India?
Today a client applies to one of the two SEBI-recognised accreditation agencies, CDSL Ventures or NSDL Database Management, with evidence of income or net worth. Once SEBI notifies its September 2026 decisions, AIF managers, portfolio managers and SIF managers will also be able to assess and accredit clients, with the status valid for three years.
Are NRIs treated as accredited investors under SEBI's new rules?
SEBI's board decided on 24 September 2026 that persons resident outside India, as defined under FEMA, including foreign portfolio investors, will be deemed accredited without a certificate. The change takes effect only after SEBI amends the relevant regulations, so AIF and PMS managers continue to apply the current rules to NRI clients until then.
Does SEBI accredited investor status count in the United States?
No. The SEC sets its own accredited investor tests in US dollars, based on income or on net worth excluding the primary residence, and those tests make no reference to SEBI status. A client living in India who invests in a US private offering usually does so under Regulation S, where the offering's own documents set out eligibility.
How long is an accredited investor certificate valid in India?
Under the current agency route, clients choose between a two-year and a three-year certificate, according to SEBI's board memo. The September 2026 board decisions set validity at three years under both the agency route and the new manager route, with manager-granted status portable across AIF, SIF and PMS products within the same group.
Is a product for accredited investors suitable for every client who qualifies?
Not necessarily. Accreditation shows that a client has passed an income, wealth or holdings test, not that the client can absorb losses or tie up money for years. Products reserved for accredited investors often carry illiquidity, leverage and concentration risks, so suitability still depends on the client's goals, cash needs and wider portfolio.
This article is for general education and is not tax, legal or investment advice. Rules change and depend on individual circumstances. All investing involves risk, including loss of capital, illiquidity and currency movements. Offerings on Raveum are available to eligible investors only and are not open to the general public.
