Fee Structure for Entities Undertaking Permissible Activities in IFSC

The International Financial Services Centres Authority (IFSCA) has recently issued Circular outlining the updated fee structure for entities operating or intending to operate within the International Financial Services Centres (IFSC). This detailed guidance pertains not only to regulated entities (REs) but also to applicants seeking various licenses, registrations, or seeking advice under the IFSCA’s Informal Guidance Scheme. The circular, dated April 8, 2025, introduces a comprehensive framework for the payment of different fees associated with the application, authorization, and ongoing regulatory processes within IFSCs.

Purpose of the Circular

The purpose of the circular is to establish a clear and organized fee structure to be followed by applicants, regulated entities, and those seeking informal guidance from IFSCA. This transparency aims to streamline the process of applying for licenses, registrations, and other authorizations, while also ensuring that the entities involved comply with the regulatory framework set out by the IFSCA.

Types of Fees

The circular categorizes the fees into seven broad categories, which are as follows:

Application Fees – This is the fee paid at the time of making an application to IFSCA. The application must include the relevant fee; otherwise, it will not be processed. Applications for different financial services need to be submitted separately and will attract separate fees.

Licence/Registration/Recognition/Authorization Fees – Once an application receives provisional or in-principle approval from the IFSCA, the applicant must pay the requisite fees within 15 days. This category also covers situations where licenses are granted directly without provisional approval.

Annual Recurring Fees – These fees are paid annually by the regulated entities or any applicant who has received a license or authorization. This ensures that entities remain compliant with the ongoing regulatory requirements.

Activity-Based Fees – These fees are imposed based on the specific activities the entity undertakes within the IFSC. Each activity might have different costs associated with it, thus ensuring that the fees are proportional to the level of engagement and regulatory oversight required.

Processing Fees – This is a fee for processing applications or requests made to the IFSCA. It covers administrative costs and ensures that the application review process is efficient and streamlined.

Late Fees – Applicants or regulated entities who fail to meet payment deadlines will be subject to late fees. This category is designed to incentivize timely payments and ensure the smooth operation of IFSCA’s regulatory functions.

Informal Guidance Fees – The IFSCA’s Informal Guidance Scheme allows entities or individuals to seek clarification or guidance regarding regulations or the regulatory environment. This fee applies to those utilizing this service.

Key Considerations for Applicants

Separate Applications for Different Services: Entities seeking to offer different financial services in IFSC must submit separate applications for each. Each application will attract its corresponding application fee as outlined in the schedule.

Payment Timelines: Once provisional approval is granted, applicants must remit the required licensing, registration, or authorization fees within a specified timeline. Failure to do so within the stipulated period could result in the rejection of the application. This highlights the importance of adhering to the deadlines to avoid unnecessary complications or delays in the approval process.

Non-Refundable Fees: In cases where the IFSCA decides not to grant a license or authorization, the fees paid will not be refunded. This policy ensures that entities are committed to the process and that the regulatory body is compensated for its efforts in reviewing and processing the application.

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