"Just Submit a CDSL Form": What Registering an Accredited Investor Actually Requires
A client who manages a ₹12 crore portfolio rang last month with a straightforward question: his AIF manager had told him he needed to become an "accredited investor" to access a new fund, and had forwarded a CDSL Venture
Harun Raaj
Chartered Accountant · Harun Raaj & Associates
"Just Submit a CDSL Form": What Registering an Accredited Investor Actually Requires
A client who manages a ₹12 crore portfolio rang last month with a straightforward question: his AIF manager had told him he needed to become an "accredited investor" to access a new fund, and had forwarded a CDSL Ventures link with instructions to "just fill in the form." Three days later he was back. The portal wanted a net worth certificate from a Chartered Accountant. What did that mean exactly? What was the CA certifying? And had the format changed recently?
All fair questions. The accredited investor framework has been live since 2021, but the January 2026 SEBI circular changed how CAs issue the core certificate — and most practitioners have not updated their workflow.
What "Accredited Investor" Actually Means
SEBI introduced the accredited investor category through an amendment to the SEBI (Alternative Investment Funds) Regulations, 2012, notified on August 3, 2021. The amendment also extended the framework to SEBI (Portfolio Managers) Regulations and SEBI (Investment Advisers) Regulations.
An individual qualifies as an accredited investor if they meet any one of the following criteria as of the date of application:
- Annual income of ₹2 crore or more in the most recent financial year; or
- Net worth of ₹7.5 crore or more, of which at least ₹3.75 crore must be in financial assets (not real estate); or
- Both income of ₹1 crore and net worth of ₹5 crore (with ₹2.5 crore in financial assets).
For body corporates, the threshold is a net worth of ₹50 crore or more.
The Three Accreditation Agencies
SEBI has notified three accreditation agencies: CDSL Ventures Limited (CVL), BSE Administration & Data Services (BAADS), and NSDL. The client applies through one of these portals. The certificate is valid for one year and is portable across all SEBI-registered intermediaries.
What Changed in January 2026
SEBI Circular No. HO/19/34/11(9)2025-AFD-POD1/I/2286/2026 dated January 9, 2026 changed the CA certificate format. The circular dispensed with the requirement to state the actual net worth figure and the mandatory detailed break-up annexure. What the CA must still do: certify that the applicant's net worth meets the specified threshold — a binary fact, not a quantum disclosure.
The CA Workflow
Step 1: Determine which threshold applies (income ₹2Cr / net worth ₹7.5Cr with ₹3.75Cr financial assets / combined ₹1Cr + ₹5Cr). Step 2: Prepare net worth statement — the financial asset sub-threshold calculation still happens internally; it is just not disclosed in the certificate. Step 3: Issue certificate on CA letterhead referencing the January 9 2026 circular, confirming threshold is met, with UDIN, without stating actual NW figure. Step 4: Client applies on CVL or BAADS portal. Step 5: Certificate issued in 3–5 working days, portable to any AIF or portfolio manager.
What Accreditation Unlocks
Access to AI-Only Funds, Large Value Funds (₹25Cr minimum ticket), and angel funds (all investors must be accredited post-September 2025 amendment, minimum ₹10L per investment). Accreditation does not change tax status, FEMA position, or ITR obligations.
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