Part 36 addresses a governance layer specific to AIFs that operate multiple distinct schemes under a single registration — a structure covered at a fund-life-cycle level in Part 17 of this series, but here examined specifically at the scheme level.
Q1. What is the difference between an "AIF" (as a SEBI registration) and a "scheme" launched under that AIF?
An AIF registration is the overarching regulatory approval granted to the sponsor/manager to operate as an alternative investment fund; a "scheme" is a specific investment vehicle or fund launched under that registration, with its own PPM, investor base, and investment strategy — SEBI permits a single AIF registration to launch multiple distinct schemes over time.
Q2. Can one scheme under a multi-scheme AIF wind up while other schemes under the same registration continue operating?
Yes — schemes are generally intended to operate with a degree of independence from each other, meaning one scheme reaching the end of its tenure (or being wound up for other reasons) doesn't require winding up the AIF's other active schemes or the overall AIF registration itself.
Q3. Does the winding-up process for an individual scheme follow the same mechanics discussed for full fund winding-up in Part 17 of this series?
Yes, broadly — the process of exiting remaining portfolio investments, applying the distribution waterfall, settling scheme-level liabilities, and final audit applies at the individual scheme level, even though the overall AIF registration (and any other active schemes under it) continues.
Q4. Is deregistration of the entire AIF required when only one scheme under it is wound up?
No — deregistration of the AIF's overall SEBI Certificate of Registration is only relevant when the manager intends to cease operating as an AIF entirely (i.e., all schemes have concluded and no further schemes are planned); winding up a single scheme while retaining the AIF registration for other current or future schemes is a distinct, more limited process.
Q5. How is "ring-fencing" between schemes maintained under a single AIF registration?
Through segregated scheme-level accounting, distinct bank account arrangements or clear accounting-level segregation (see Part 35 of this series), separate PPMs for each scheme defining its own investment strategy and investor base, and governance practices ensuring one scheme's liabilities or losses don't inappropriately affect another scheme's assets or investors.
Q6. Can investors in one scheme of a multi-scheme AIF be exposed to liabilities arising from a different scheme under the same AIF?
Proper ring-fencing is specifically intended to prevent this — investors in one scheme should not, if segregation is properly maintained, bear liabilities or losses attributable to a different, independently operated scheme under the same overarching AIF registration; this is precisely why the segregation practices discussed in Part 35 matter so much for multi-scheme structures.
Q7. Does each scheme under a multi-scheme AIF need its own separate Annual Activity Report and Quarterly Activity Report filing?
Regulatory reporting under the current AAR/LQAR framework (see Part 9 of this series and our AIF Compliance Calendar article) is generally structured to capture scheme-level activity within the overall AIF's reporting, though the precise mechanics of how multi-scheme reporting is consolidated or separated should be confirmed against the current SEBI reporting format and guidance for multi-scheme AIFs.
Q8. Can the investment manager charge different fee structures to different schemes under the same AIF?
Yes — since each scheme has its own PPM, fee structures (management fee basis, carry terms) can and often do differ scheme to scheme, reflecting different strategies, vintages, or investor negotiations, provided each scheme's specific terms are clearly disclosed in that scheme's own PPM.
Q9. Does the trustee's oversight role (for trust-structured AIFs) extend across all schemes under the AIF, or is it scheme-specific?
The trustee's overarching fiduciary oversight role (see Part 22 of this series) typically extends across all schemes operated under the AIF's trust structure, though the trustee's practical review would naturally engage with each scheme's specific PPM, investors, and portfolio individually.
Q10. Can a new scheme be launched under an existing AIF registration without a fresh SEBI registration process?
Generally yes — launching an additional scheme under an already-registered AIF doesn't require a fresh full registration application in the way the initial AIF registration did, though the new scheme's PPM and terms still need to comply with applicable regulatory requirements and, depending on the nature of the scheme, may require appropriate intimation or approval processes.
Q11. What happens to the investment manager's or sponsor's obligations if the AIF has some schemes still active and others already wound up?
The manager and sponsor's ongoing obligations (compliance, reporting, sponsor commitment where applicable) continue in respect of each active scheme independently — a wound-up scheme's conclusion doesn't reduce the manager's responsibilities toward other schemes still operating under the same AIF registration.
Q12. Why might a sponsor choose to launch a new investment strategy as an additional scheme under an existing AIF registration, rather than establishing an entirely new AIF?
Operational and regulatory efficiency — reusing an already-registered AIF platform for a new scheme avoids repeating the full initial registration process, while still allowing the new scheme its own distinct PPM, investor base, and (with proper ring-fencing) independent risk profile from the manager's other schemes.
Structuring and Governing Multi-Scheme AIF Platforms
We advise fund managers operating or planning multi-scheme AIF platforms on scheme-level segregation, ring-fencing, and governance practices that protect each scheme's investors independently.
This FAQ is for general informational purposes and does not constitute regulatory advice specific to any multi-scheme AIF's structure.