The International Financial Services Centres Authority (IFSCA) has released a consultation paper and draft Master Circular aimed at creating a unified regulatory framework for Broker Dealers and Clearing Members operating in IFSCs. This initiative follows the replacement of the 2021 Capital Market Intermediaries Regulations with the updated CMI Regulations, 2025, which empower the Authority to issue norms and guidelines through circulars. The proposed Master Circular consolidates and supersedes all earlier circulars issued by SEBI (before October 1, 2020) and IFSCA relating to these intermediaries, covering areas such as market access through authorized persons, fee structures, security deposit refunds, disaster recovery operations, settlement of client funds, reporting norms, and net worth requirements. While old circulars will cease to apply, actions already taken under them will remain valid. IFSCA has invited stakeholders to submit comments on the draft by December 20, 2025, using the prescribed format to refine and finalize the comprehensive regulatory framework.
International Financial Services Centres Authority
Consultation Paper on Master Circular for Broker Dealers and Clearing Members
Objective
1. The objective of this consultation paper is to seek comments / views from public on the draft master circular for Broker Dealers and Clearing Members in IFSC.
Background
2. IFSCA had notified IFSCA (Capital Market Intermediaries) Regulations, 2021 in October 2021 which have subsequently been replaced by the IFSCA (Capital Market Intermediaries) Regulations, 2025 (CMI Regulations). CMI Regulations provide for the unified framework for the regulation and supervision of the Capital Market Intermediaries including Broker Dealers and Clearing Members in the IFSC.
3. Regulation 45 of the CMI Regulations empowers IFSCA to specify norms, procedures, manners or guidelines by way of circulars to the Capital Market Intermediaries including Broker Dealer and Clearing Members.
4. A master circular, superseding all the circulars and guidelines of SEBI and IFSCA with respect to Broker Dealers and Clearing Members has been prepared and is attached herewith.
Public Comments
5. The comments are invited from public and stakeholders on the proposed master circular. The comments may be sent by an email to Shri Praveen Kamat, General Manager at kamat@ifsca.gov.in, Shri Shubham Goyal, Assistant General Manager at goyal.shubham@ifsca.gov.in and Shri Abhinav Kadyalwar, Assistant Manager at abhinav.sk@ifsca.gov.in with subject line “Comments on the Master Circular for Broker Dealers and Clearing Members” latest by December 20, 2025.
The comments should be provided in the following format:
| Name and Designation | ||||
| Contact No. and email address | ||||
| Name of organisation | ||||
| S. No. | Para/clause no. of the master circular |
Text of the clause |
Comments/Suggestions | Detailed rationale |
MASTER CIRCULAR
IFSCA/CMD/MIIT/MCBDCM/2025 November 29, 2025
To,
All Stock Exchanges in the International Financial Services Centres
All Clearing Corporations in the International Financial Services Centres
All Broker Dealers in the International Financial Services Centres
All Clearing Members in the International Financial Services Centres
Madam/Sir,
Subject: Master Circular for Broker Dealers and Clearing Members
1. IFSCA had notified IFSCA (Capital Market Intermediaries) Regulations, 2021 in October 2021 which have subsequently been replaced by the IFSCA (Capital Market Intermediaries) Regulations, 2025 (CMI Regulations). CMI Regulations provide for the unified framework for the regulation and supervision of the Capital Market Intermediaries including Broker Dealers and Clearing Members in the IFSC.
2. In the past, IFSCA has issued various circulars relating to Broker Dealers / Clearing Members, as under:
| Sr. No. |
Date | Circular No. | Subject |
| 1 | October 14, 2020 | F. No. 68/IFSCA/MRD-AP/2020-21 | Market Access through Authorized Persons |
| 2 | April 13, 2021 | F. No. 286/IFSCA/Policy Matters (CMD-DMIIT)/2021
|
Fee structure for Market Infrastructure Institutions (MIIs) and Participants |
| 3 | April 29, 2022 | IFSCA/CMD-DMIIT/AP/2022- 23/1 | Market Access through Authorized Person |
| 4 | June 28, 2022 | IFSCA/CMD-DMIIT/BD/2022-23/1 | Refund of security deposit to Broker Dealers on surrender of membership |
| 5 | May 09, 2023 | IFSCA/CMD-DMIIT/BCP- DR/2023-24/001 | Status of operations at Disaster Recovery (DR) Site of the Broker Dealers and Clearing Members registered with IFSCA |
| 6 | March 14, 2024 | IFSCA/CMD-DMIIT/SOF/2023- 24/001 | Ease of doing business: Settlement of Client’s Funds lying with Broker Dealer |
| 7 | February 08, 2024 | F. No. 1/IFSCA/CMI Supervision/2023-24 | Reporting Norms for Capital Market Intermediaries |
| 8 | September 05, 2024 | F. No.: IFSCA-DSI/4/2024- Capital Markets | Maintenance of Net Worth by Capital Market Intermediaries |
3. This Master Circular shall supersede all the circulars and guidelines issued by SEBI (prior to October 01, 2020) and IFSCA in respect of Broker Dealer and Clearing Members registered by the IFSCA (the Authority).
4. Notwithstanding such supersession,
a. anything done or any action taken or purported to have been done or taken under the superseded circulars, prior to such supersession, shall be deemed to have been done or taken under the corresponding provisions of this Master Circular;
b. any application made to the Authority under the superseded Master Circular, prior to such supersession, and pending before it shall be deemed to have been made under the corresponding provisions of this Master Circular;
5. This Master Circular is being issued in exercise of powers conferred by Sections 12 and 13 of the International Financial Services Centres Authority Act, 2019 read with regulation 45 of the CMI Regulations and shall come into force from the date of its issuance.
A copy of this circular is available on the website of the International Financial Services Centres Authority at www.ifsca.gov.in.
Yours faithfully
Praveen Kamat
General Manager
praveen.kamat@ifsca.gov.in
Division of Market Infrastructure Institutions & Technology
Capital Markets Department
