Public comments received on proposed IFSCA (Electronic Trading Platforms) Regulations, 2026

Comments received on proposed IFSCA (Electronic Trading Platforms) Regulations, 2026 S.No Para Comments / Suggestions / Suggested Rationale Modifications 1 Page 2, We note that the requirement mandates the While we fully appreciate the regulatory objective of para 5 ETP Operator to maintain its electronic ensuring effective supervisory access and operational systems physically within IFSC. resilience, a strict requirement for the physical localisation of trading systems and data within the IFSC may present We respectfully request reconsideration of operational, resilience, and market-quality challenges for this requirement given the costs associated global ETP operators that rely on centralised, with relocating existing trading systems are cross-jurisdictional infrastructures.

substantial and may render operations In this regard, a principles-based approach that emphasises economically unviable. Additionally, we note data accessibility, auditability, and robust regulatory that most offshore jurisdictions do not oversight rather than physical location alone may more impose similar localization requirements.

effectively support the IFSC’s objective of attracting global liquidity and established ETP operators and encourage participants such as us to establish an ETP presence in the IFSC.

2 Page 2, We note that the ETP Operator is required While we appreciate the regulatory objective of supervisory para 5 to have its electronic system physically access and resilience, a strict requirement for physical located in IFSC. localisation of trading systems and data in IFSC may pose operational, resilience and market-quality challenges for We humbly request you to reconsider this global ETPs that operate centralised, cross-jurisdictional requirement given the costs associated with infrastructures.

transferring the trading systems is very high A principle-based approach focusing on data access, and may lead it not being economically auditability and regulatory control, rather than physical feasible.

location, may better support IFSC’s objective of attracting global liquidity and established ETP operators an encourage players like us to establish an ETP set up in IFSC.

3 Page 2, While flexibility is important, completely decentralised It is suggested that broad principles for para 7(c) membership criteria may result in inconsistent standards membership eligibility criteria besupplemented with minimum baseline across ETPs, potentially allowing weaker participants to requirements prescribed by the Authority enter certain platforms. A baseline regulatory standard will ensure minimum financial and operational robustness of all trading members.

4 Page 4- 1(1) Suggested Modification: As these Regulations may envisage authorisation of more

(1) These regulations may be called the than one ETPs, the term ‘Platforms’ (plural) may be International Financial Services Centres considered.

Authority (Electronic Trading Platforms) Regulations, 202X.

5 Page 4, Comment: Algorithmic trading is widely prevalent in the market in some para 2 A definition for ‘Algorithmic Trading’ or ‘Algo instruments, and hence may be provided for in these Trading’ may be provided. Further, Regulations framework governing Algo Trading may be incorporated as part of Para 14 – Risk Management.

6 Page 4, Suggestion: As part of Risk Management obligations, an ETP Operator para 2(1) A suitable definition of Market Abuse and a is obligated to identify, deter and prevent Market Abuse and framework for dealing with the same may be report the same to the Authority. A framework on the

provided in these Regulations. meaning and scope of Market Abuse and the corresponding actions on the part of ETP Operator may be provided to bring certainty and uniformity in practice across all ETP Operators and the market alike.

7 Page 4, Suggestion: The term ‘authorisation’ is used in Chapter II - authorisation, 2(1)(a) The term ‘authorisation’ may be considered and the same may be used for consistency. in place of the term ‘recognition’ 8 Page 4, Definition of ‘Eligible Instruments’- The ‘Eligible Instruments’ includes securities, money market para 2(1)(c ) We request clarification that the definition of instruments, foreign exchange instruments, derivatives, or “Eligible Instruments” is intended to cover other instruments of like nature.

only instruments in the nature of OTCderivatives. As a corollary, we understand that it would not extend to exchange-traded derivatives such as foreign exchange and interest rate futures listed on non-Indian exchanges nor to spot transactions.

9 Page 4, Definition of ‘Eligible Instruments’- We The term ‘Eligible Instruments’ refers to securities, money para 2(1)(c ) humbly recommend clearly stipulating market instruments etc. It will be prudent to clarify whether whether INR or INR linked products are within the securities will also cover INR linked products that are settled in foreign currency. For example, Indian Government the scope of these Directions or not.

bonds settled in foreign currency or Indian INR USD NDFs While given IFSCA deals with freely settled in USD or INR linked overnight index swap settled in convertible currency this may seem like foreign currency.

stating the obvious. The absence of clarity on INR linked products that are settled in foreign currency may deter some market participants.

10 Page 4, Definition of ‘Eligible Instruments’- The ‘Eligible Instruments’ includes securities, money market para 2(1) (c ) instruments etc. It will be prudent to clarify whether the We humbly recommend that the Directions reference to securities is intended to include INR-linked clearly specify whether INR-denominated or products that are settled in foreign currency. By way of INR-linked products fall within their scope.

illustration, this may include instruments such as Indian While we acknowledge that the IFSCA INR–USD NDFs settled in USD, or INR-linked overnight framework is generally oriented towards index swaps that are settled in a foreign currency.

freely convertible currencies, the absence of explicit clarity particularly with respect to INR-linked products that are settled in foreign currency may create uncertainty and could deter certain market participants from participating.11 Page 4, Suggested Modification: Minor drafting update.

para 2(1)(d) “Eligible jurisdictions” shall mean the jurisdictions referred to in Schedule I of these regulations.

12 2(1)(d) Para 2(1)(d) read with proviso to Para 3(2). We request the reference to Eligible Jurisdiction may be considered/viewed in line with the principle of reciprocity.

Reference ‘Eligible Jurisdiction’.

13 2(1)(e) Comment: a) The definition may be kept broad to cover derivatives, The reference to ETP enabling the ‘clearing money market, securities and foreign exchange and settlement’ may be dropped. Further, instruments (such as repo, triparty repo, options, etc.), the definition may be kept simple.

as specified by the Authority. The reference term

Suggested modification: ‘contract’ is adequately covered under the definition of “Electronic Trading Platform (ETP)” shall Eligible Instruments. Hence, including all reference mean an electronic system, located in IFSC, other than a recognised stock exchange, may lead to amendments in future, if the nature of an through which transactions in Eligible instrument changes. For ex., borrowing and lending of Instruments are contracted. through which instruments is presently not covered.

offers for exchange, sale or purchase of one b) Clearing and Settlement may be enabled through the or more eligible instrument/s is regularly arrangement approved by the Authority under Para 15. made by trading members and which, on The trades executed on an ETP would flow to the entity such offer being accepted, may enable the clearing and settlement of such eligible permitted in such arrangement.

instruments between such trading members c) Reference of Clearing and Settlement may be dropped through such electronic system or as the same implies various facets (multilateral/bilateral) otherwise; and are also adequately addressed in Para 15.

To clarify that an ETP is not a stock exchange, as also discussed in Sr. 22 below.

14 2(1)(i) Suggested modification: definition provided under the Companies Act, 2013 already “Key managerial personnel” shall have the includes the latter reference under Section 2(51)(v) as ‘such meaning assigned to it in sub-section 51 of other officer, not more than one level below the directorssection 2 of the Companies Act, 2013 (as who is in whole-time employment, designated as key amended) and any other person whom the managerial personnel by the Board’, and the same may be Payment Service Provider may declare as a applied for the company acting as an ETP Operator.

key managerial personnel; Further, the reference ‘Payment Service Provider’ may be revisited in the context of these regulations, as the same may not be applicable.

15 2(1)(j) Comment: As the term is a clarification/explanation and used only in This reference which is now part of the Regulation 13, the same may be provided thereunder. definitions, may be provided as clarification in Para 13.

16 2(1)(j) It is suggested that the term “material The current definition of “material change” is principle-based change in operating rules” be further and open-ended, which may lead to varied interpretation clarified by the Authority through indicative across ETP Operators. In absence of clear guidance, parameters, thresholds, or an illustrative list operators may either under-report significant changes or of changes that would qualify as “material” over-report minor modifications, leading to regulatory for the purpose of requiring prior approval. inefficiencies and compliance uncertainty. Providing illustrative guidance, such as changes impacting trading logic, risk management framework, membership criteria, or system architecture, will ensure consistency in interpretation, improve compliance, and facilitate smoother regulatory oversight.

17 2(1)(l) Terms ‘Member’, ‘Trading Member’ and The term ‘Participant’ may enable flexibility as to the ‘Person’ are used inter-changeably. The participation criteria to be prescribed by IFSCA, or by the term ‘Trading Member’ may be replaced ETP Operator with approval of IFSCA. The same would with ‘participants’ throughout. cover a broader participation structure, including the trading

Suggested Definition: member, constituents, etc. ‘Participant’ shall mean a person transacting in the Eligible Instruments through an ETP.

18 2(1)(l) Definition of ‘trading members’ Clarifying the scope of “trading member” is important to ensure regulatory certainty on who may directly access andtrade on an ETP. In the absence of clarity, it is unclear We request you to humbly clarify whether whether participation is restricted to regulated institutional “trading member” includes only institutional entities or also extends to proprietary trading firms, funds, participants or also proprietary trading firms, family offices and treasury centres, and whether end‑clients funds, family offices, and treasury centres;

may access the ETP through a member or as members and whether “member” includes clients themselves. Such clarification would help ETP operators accessing as a constituent. design appropriate membership criteria, access models and Request you to also clarify whether the compliance frameworks in a manner consistent with trading members can include Indian IFSCA’s regulatory intent.

residents (even if ETP is in IFSC)? As regards Indian residents, many a class of such residents are permitted under FEMA provisions to transact outside India in some of the eligible instruments.

19 2(1)(l) Explicitly permitting GIFT City entities to participate on Definition of ‘trading members’ global ETPs that do not have a physical presence in IFSC is We humbly request clarification on whether important to preserve their ability to access deep, global the term “trading member” is intended to liquidity pools and competitive price discovery, particularly cover only institutional participants, or for products that are predominantly traded offshore. Absent whether it also includes proprietary trading such clarity, the provision could be read restrictively, firms, funds, family offices, and treasury potentially constraining treasury centres, banks and funds in centres. We further seek clarification on IFSC from efficiently managing risk or executing trades on established international venues. A clear stipulation would whether the term “member” extends to therefore support market development, risk management clients accessing the ETP as constituents.

efficiency and IFSC’s positioning as a globally integrated We also request clarification on whether financial centre, without diluting regulatory oversight within trading members may include Indian IFSC.

residents, notwithstanding that the ETP is established in the IFSC.

20 3 We respectfully suggest that the following The proposed requirement of local presence may not be proviso be added to Regulation 3 (1) to practical or commercially viable for all platform operators bring clarity and alignment with the IFSCA’s and could inadvertently restrict access to globally

broader regulatory approach:established liquidity pools. "provided further that an operator located outside IFSC and providing services to an The suggested clarification ensures that the authorisation entity in an IFSC shall not be required to requirement applies primarily to entities establishing a obtain authorisation as an ETP Operator physical presence within GIFT IFSC, while allowing IFSC under these regulations, unless such entities to access offshore ETPs. This approach is operator establishes an office or unit in an consistent with the IFSCA’s earlier position as set out in its IFSC for offering such services." circular dated February 2, 2021, which permitted transactions on ETPs not incorporated locally.

Adopting such a framework would support ease of doing business, preserve the IFSC’s open and globally integrated operating model, and avoid unintended extraterritorial implications. Mandatory registration or local incorporation requirements for offshore ETP operators may otherwise deter global participation and impact market efficiency 21 3(2) Suggested Modification: Para 3(2) states that an entity seeking authorisation shall be

Provided that, an entity authorised to act as required to be a Company within IFSC. an ETP Operator (by whatever name called) Hence, the ‘proviso’ may only cover the instance of enabling in an eligible jurisdiction may seek the ‘branch’ of an entity to seek authorisation and the authorisation as an ETP Operator either as reference stating that a company in IFSC may seek a Company with its registered office in IFSC authorisation as an ETP may not be required.

or as a branch of the entity.

Further, an entity authorised to act as an ETP operator in other jurisdictions may not seek authorisation, as the same would be done by the subsidiary which would be incorporated in IFSC. As such, the said subsidiary would seek authorisation and not the entity authorised as an ETP operator in another jurisdiction as stated in the first proviso.

As the language is already covered in the principle clause i.e. Para 3(2), the portion “” in the first proviso may not beappropriate contextually and is not the comparable structure to that of a branch.

The same is already addressed in Para 3(2) as: “(2) An entity seeking authorisation as an ETP Operator shall be required to be incorporated as a Company with its registered office in IFSC” In case of a Parent Entity incorporating a subsidiary in IFSC, such subsidiary would be seeking the authorisation.

Language may be revisited for clarity.

22 4(1)(a) Suggested Modification: In case of newly set up entity, the entity itself may not have a) track record, management expertise and required track record. Hence, the track record of its promoter financial soundness of the applicant or its may be considered.

promoter(s);

23 4(1)(b) and Existing :- To have Standarized and Uniform Industry Practices in the 4(1)(c ) The Regulation Prescribes employing GIFT City Ecosystem sufficient numder of employees with adequate professional experience and Fit and Proper Criteria for Key Managerial Personnels

Suggestion :- With Respect to employee

(1) The Regulation should prescribe Broad Criteria such as -> Some minimum educational qualifications -> Professional expereince -> Certifications -> specific skill set For the uniformity and standardization of industry norms(2) The Regulation should also prescribe the Broad Criteria towards Fit and Proper criteria for the Key Managerial Personnel also which should be uniform across the Gift Eco System.

24 4(1) (c ) Comment: For clarity on whether the term ‘persons exercising control Clarity may be provided whether the term over the entity’ would include shareholders within the ‘persons exercising control over the entity’ ‘Relevant Persons’.

refers to the shareholders? 25 6(1) suggested modification: An enabling provision may be provided for the Authority to

(1) If the Authority is of the opinion that the provide any additional rectification time beyond the 30 days authorisation cannot be granted to an period, considering the nature of deficiency and time application submitted under sub-regulation required for rectification of the same on a case-to-case 3 of regulation 3, it shall communicate the basis.

deficiencies to the Applicant giving it thirty

(30) days’ or such further time as may be allowed by the Authority time to rectify them.

26 6(4) Suggested Modification: The provision only refers to the fresh application being

(4) The applicant whose application is permitted within 6 months from the date of refusal but does refused under sub-regulation (2) or not include the provision to enable a fresh application, on withdrawn under sub-regulation (3) may account of a withdrawal of application.

submit a fresh application for authorisation after a period of six months from the date of communication of refusal of the application by the Authority under sub-section (2) or on account of withdrawal under sub-regulation

(3), as the case may be.

27 9(1) Suggestion: The entities seeking authorisation has to adopt a serious The prescribed minimum net worth may be and committed approach, towards fulfilling its role and reviewed and enhanced to a substantially responsibilities as an ETP Operator under these material amount. Regulations. More importantly when jurisdictions other than India and IFSC are being permitted.28 9(3) It is suggested that a clear framework or Absence of defined triggers for enhanced capital objective criteria be provided for prescribing requirements may create uncertainty for operators and higher net worth requirements by the impact business planning. A transparent framework (e.g., Authority. based on volume, product complexity, cross-border exposure) would improve regulatory clarity.

29 9(4) Suggestion: To provide clarity on the timeline for submission of Net worth A timeline may be prescribed for annual Certificate and ensuring compliance by the ETP Operators submission of Net Worth certificate. within a specified time.

30 9(4) Existing :- Better Risk Mitigation An ETP shall submit an audited Net Worth certificate on a Yearly basis to the authority

Suggestion :- The regulation may prescribe the interim checks and mandatory prescriptions where in due to the adverse event which has bearing upon the Net Worth of ETPs should be reported to the authority mandatorily.

31 10 It is suggested that the regulation explicitly Given the possibility of ETP Operators or their group entities require ETP Operators to establish and acting as participants on the platform, there exists a risk of maintain a comprehensive conflict of preferential treatment, information asymmetry, or biased interest management framework, including execution practices. In the absence of a formal conflict identification, mitigation, disclosure, and management framework, such situations may undermine monitoring of conflicts, particularly in market integrity and participant confidence. Global situations where the ETP Operator or its regulatory frameworks governing ATS/MTFs typically affiliates may directly or indirectly participate mandate robust conflict of interest policies to ensure as Trading Members on the platform. fairness, transparency, and neutrality of the trading venue.

32 10(i) Entity-level identification through LEI could assist market It may be beneficial to consider the use of operators and regulators in monitoring trading patterns and LEI within surveillance systems to help understanding market exposures more effectively. The LEIaggregate trading activity at the entity can also support aggregation of exposures and trading level. activity across market infrastructures, thereby assisting regulators and market operators in monitoring risks at the entity level.

33 10(i)(a) to Existing :- 10(i) (d) The regulation Prescribes the general obligation of an ETP Operator to lay down transparent rules and maintain a necessary infrastructure it also prescribes to maintain objective criteria for the efficient execution of orders To ensure and encourage the Standard rules and

Suggestion :- regulations amongst ETP Participants Broad Standard Modalities should be

provided towards standardization of the rules and regulations of the ETP ecosystem else there may be a scenario where there will be conflicting rules and regulations amongst ETP's and other participating entities 34 10(1) (e ) Suggestion :- To ensure Market Discipline and to Establish best market The regulation should prescribe some pratices standard modalities and minimum eligibility criteria such as 1 ) The constitution of a participating entity i.e. Company, Private Company , Limited Liability Company etc..

2) Uniformity in rules & criteria's while determining the eligible instruments that can be traded on the ETP ( Comment for 10 E )35 10(1)(h) Suggested modification: To clarify that the trades may either be executed on ETP h) make available to its members a screen- through placing the orders, or trades negotiated bilaterally based trading system for execution/ and submitted on ETP, as the case may be.

submission of trades on to the ETP;

36 10(1)(i) Comment: The existing provision mandates real-time surveillance, There is no provision for escalation and primarily focusing on detection of unusual price, volume or actions to be taken in connection with a position movements.

surveillance alert. Strengthening the provisions to include defined procedures

Suggestion: for handling identified surveillance cases will ensure that A framework may be provided to specify the surveillance outcomes are acted upon in a structured procedures to be followed upon manner and appropriate escalation, investigation and identification of a surveillance instance, regulatory reporting mechanisms are in place including escalation, investigation, reporting to the regulator, etc.

37 10(1)(l) Suggested Modification: The trades accepted for settlement will have implications of have in place adequate grievance redressal finality and as such shall be dealt in accordance with the mechanism and arbitration mechanism to framework of the clearing and settlement entity’s dispute resolve disputes arising out of trades resolution framework.

undertaken on the ETP; As there is an overlap in most cases, it is desirable to make

Provided however that, any dispute arising a clear distinction of the same. from or in relation to the trade accepted for settlement shall be dealt in accordance with the dispute resolution framework provided for under the clearing and settlement service provider/ payment system.

38 11 Participation on ETP Explicit clarification permitting GIFT City based entities to We request clarity with regards to participate on global ETPs that do not maintain a physical Participation on ETP stipulating that a GIFT presence in the IFSC would be important to preserve their City entity can undertake transactions on access to deep and liquid global markets, as well as to global ETPs as well who do not have a competitive price discovery—particularly for products that presence in GIFT. are predominantly traded offshore. In the absence of such clarity, the provision may be interpreted narrowly, potentiallyconstraining treasury centres, banks, and funds located in the IFSC from efficiently managing risk or executing transactions on established international venues.

A clear stipulation in this regard would support market development, enhance risk management efficiency and reinforce IFSC’s positioning as a globally integrated financial centre, without diluting the regulatory oversight within IFSC.

39 11(2) LEI reference data includes verified entity information such The Authority may consider enabling ETP as legal name, address, and jurisdiction. The data are operators to leverage LEI reference data publicly available, standardized and machine-readable during onboarding and due diligence of enabling automated verification of legal entities and trading members. facilitating integration across onboarding, existing KYC and due diligence processes, and regulatory systems .

40 11(2)(a) Suggestion: It may not be feasible to determine with certainty if the Reference to ‘sufficient good repute’ may be participant is of ‘sufficient good repute’, as the same is dropped. subjective. Hence, the same may be dropped.

41 11(2)(b) Comment: The ‘competence and experience’ of the participants with The reference to ‘Eligible Instruments’ may respect to Eligible Instruments may not be possible in the be revisited.

following cases: a) An entity, previously undertaking transactions in the financial market other than Eligible Instruments, now wishes to transact in the Eligible Instruments.

Ex.: Entity A was trading only in Capital Markets.

Presently, Entity A wants to trade in Triparty Repo. b) Introduction of a new instrument as an Eligible Instrument, for which entities in general may not have any prior experience.

Ex.: Introduction of specific repo/ options product that was not traded earlier.42 11(2)(c ) Minimum eligibility criteria for Trading Trading Members bear bilateral settlement risk. If eligibility Members, such as net worth, financial is completely operator-dependent, entities with weak soundness, technical capability, and financial or operational strength may enter some ETPs, compliance history may be prescribed at a increasing probability of settlement failure. A minimum regulatory level rather than left entirely to regulatory threshold will promote safety and consistency individual ETP Operators. Moreover, it is across all ETPs.

suggested that minimum KYC/AML standards for onboarding of Trading Members be prescribed or aligned with internationally accepted frameworks such as FATF guidelines, including requirements relating to beneficial ownership identification, risk categorisation, and ongoing due diligence.

43 11(3) The Authority may consider encouraging the use of the Legal Entity Identifier (LEI) LEI is a globally recognised identifier (ISO 17442) used as a unique identifier for trading members widely across financial markets. Encouraging its use may participating on the ETP, while continuing to support consistent identification of legal entities and allow domestic identifiers such as PAN for facilitate interoperability with global market participants.

domestic regulatory purposes where required.

44 11(3) It may be helpful to clarify that Given the cross-border nature of IFSC markets, the use of international institutional participants globally recognised identifiers such as LEI may simplify accessing ETPs may use LEI as their participation for foreign institutions and support harmonised primary identifier. identification practices.

45 13 We understand that the regulatory intent is to ensure that We humbly recommend instructing ETPs to the rules, regulations, and operating manuals of the ETP are make the rules, regulations to be uploaded readily accessible to existing and prospective members. In on the website. this regard, it may be considered appropriate to stipulate that the ETP operator is required to publish and maintainthese documents on its official website, thereby ensuring transparency and ease of access.

46 13(1) Suggestion: To enable the ETP Operator to include provisions pertaining It is desirable for the Operating Rules to to membership, liability framework, restrictions, comprehensively enable and empower the requirements etc. as part of the Operating Rules.

ETP Operators and the participants on the To bring uniformity in the broad framework of operating rules following lines (indicative only): of ETP Operators.

(c) well documented rules and regulations including but not limited to, on-boarding, suspension and cessation of membership, roles and responsibilities of the members and the operator, liability framework for its users in case of breach of rules and regulations, restrictions or other requirements that may apply for using the ETP, processing and execution of orders, risk management and control.

47 14 Suggestion :- To Ensure the seamless and fraction free conducive Dispute Resolution Mechanism is missing in Infrastructure the Regulation 48 14(1) to It is suggested that the Authority introduce a The regulation currently places full discretion with each ETP 14(6) standardized minimum risk management Operator, which may lead to inconsistent risk controls and framework for ETPs, including guidelines on regulatory arbitrage. Uniform baseline controls are important pre-trade risk controls, circuit breakers, because ETPs handle large institutional and OTC-like error trade policies, and market abuse products without CCP protection. Standardisation will surveillance. prevent weaker platforms from compromising market integrity.

49 15 Suggested Modification: The enabling arrangement for Clearing and Settlement

(1) An ETP Operator enabling the clearing entered by the ETP Operator with any entity, shall be and settlement of transactions in eligible approved by the Authority.instruments between two or more trading members through such electronic system shall ensure that there are satisfactory arrangements in place for securing the timely discharge of the rights and liabilities of the parties to transactions conducted on or through its electronic system and must shall inform its trading members of details relating to such arrangements and changes thereto.

(2) The enabling arrangement shall be entered into with an entity as may be approved by the Authority 50 15(1) It is suggested that the regulations Since ETPs operate without a central counterparty, bilateral prescribe a comprehensive and clearly settlement exposes participants to direct credit and defined framework for bilateral settlement operational risk. The current regulations do not define how risk, covering: (a) treatment of unsettled disputes, failed settlements, or default-related losses are to trades and partial settlements; (b) a be handled. The absence of a clear fallback process, default structured default-management and loss- waterfall, and liability allocation may lead to ambiguity, legal allocation waterfall; and (c) explicit disputes, and reduced participant confidence. A transparent, delineation of liability between the ETP rule-based framework-aligned with global ATS/MTF Operator and Trading Members in cases of practices, will enhance predictability, ensure orderly trade failure, system disruption, erroneous handling of defaults, and provide institutional comfort by trades, or counterparty default. clearly allocating responsibilities between the Operator and Trading Members.

51 15(1) The Authority may explore the possibility Using a globally recognised entity identifier may support of using LEI for identifying transparency and improve traceability of transactions within counterparties in clearing and the trading ecosystem.

settlement processes where applicable.

52 15(1) (1 ) ETP's should function as a Market Place / Market

Existing :- infrastructure Entity only and should not functions as aThe Regulation allows ETPS to undertake Clearing / Settlement Intermediary due to Conflict of clearing and settlement of transaction as Interest.

well along with the functionality as a Market (2 ) Similar to the control mechanism put in place in other Place/ Market Infrastructure Entity Financial Centres such as Singapore & USA.

Suggestions:- The role of the ETPs should be exclusive to the functionality of acting as a Market Place / Market Infrastructure Entity only While Clearing and Settlement should be the prerogative of other Recognised Market Operators on an arm's length basis akin to the pratice prevailing in many established markets.

53 16(1) Comments: 1) Data localisation within the Indian jurisdiction would

1) An option to have the data centre outside continue to enable effective supervisory control, including of IFSC but within Indian boundaries, inspections and audits of IT facilities and deployments. with approval of the Authority, may kindly Currently, datacenter infrastructure within GIFT-IFSC is be considered. limited and many IT services and solutions are cloud- An ETP Operator having the Disaster hosted environments. Hence, the same may be allowed to Recovery Site outside of IFSC may kindly be located anywhere in India (including non-IFSC area).

be considered. To clarify that the Disaster Recovery Site may be outside of IFSC area, as the same is required to be present in a different seismic zone and geographical location.

54 17(2) A provision may be added requiring the ETP In order to facilitate submission of report of IT/IS audit to the Operator to submit the report of IT/IS audit Authority in timely manner. by a specific due date.

55 19(1) ETP operators may consider maintaining Maintaining such information may support improved data LEI-linked information as part of the standardisation and facilitate regulatory reporting where entity-level data retained for trading required.

members.56 20(1) Where applicable, returns and reports submitted to the Authority could include Inclusion of LEI in regulatory reporting may enhance the LEI identifiers for institutional trading quality and comparability of entity-level market data.

members.

57 20(1) Comment:

The time period for furnishing the returns, To clarify and avoid uncertainty of time limit to furnish statements and particulars may be returns, statements and particulars by the ETP Operator(s). prescribed in the Regulations 58 20(3) Comment:

The term ‘returns’ may kindly be reviewed as per the requirement, and may be explicitly mentioned if those are required.

Suggested modification:

(3) An ETP shall furnish to the Authority its annual financial statements and returns To provide clarity on the specific ‘returns’ expected to be thereto every year. furnished.

59 23(1) Comment: The term ‘securities’ mentioned under Section 45U of the In the heading, the reference may be RBI Act, 1934 does not cover all instruments governed corrected to Regulation 4(1)(c). under Section 45W, under which these Regulations will be issued 60 24 Suggested Modification: Inspection and Investigation is the domain and power of the The Authority may appoint an auditor to Authority. The Auditor appointed by the Authority may not audit inspect or investigate, into the books have the power equal to Authority’s powers. Delegation may of account, records, documents, be suitably examined.infrastructures, systems and procedures or The Auditor may ‘audit’ the ETP Operator, in the form, affairs of an ETP, as directed by the manner and scope specified by the Authority.

Authority.

61 New Suggested modification [New Clause]: (1) As these Regulations governs the ETP in relation to the regulation to 28. Regulations not to apply to stock instruments covered under the Chapter III-D of the RBI Act, be inserted exchanges 1934, this clarification may be required to demarcate the after 27 (1) The ETP(s) authorised under these scope of these Regulations from the scope of the Regulations are not stock exchange under Regulations issued under the SCRA, 1956 (ex. the IFSCA the Securities Contracts (Regulation) Act, (Market Infrastructure Institution) Regulations, 2021).

1956 and any rules, regulations, directions, (2) Clarificatory provision needed to avoid any ambiguity on etc. issued thereunder by the Authority for application of existing provisions of any other law such as stock exchanges in IFSC shall not be SCRA, 1956 or the regulations made thereunder, to ETPs applicable to ETPs authorised under these regulated under these Regulations.

Regulations.

(2) Nothing contained in these Regulations shall apply to the stock exchanges authorised under the Securities Contracts

(Regulation) Act, 1956.

62 Pg. 16 – Reference to offences against ‘Securities Any offence in connection with the financial market laws Schedule II , Laws’ is provided, the same may be would cover the reference to RBI Act, including Section 45W 4b(i) reviewed and the reference ‘financial of the same market laws’ may be considered.

63 Page 16, Comment: The intended reference appears to be Regulation 4(1)(c). schedule II In the heading, the reference may be corrected to Regulation 4(1)(c).

64 Page 16, Reference to ‘Financial Regulatory To ensure uniformity of references. schedule II- Authority’ is provided in some instances, 4(b)(ii) however, in other instances reference to ‘regulatory authority’ is provided.65 Pg. 17 – Comment/Suggestion: As ‘Relevant person’ is defined, using the same term clarify Annex to The reference ‘functionaries’ may be the requirements and might include the functionaries Schedule II clarified, and the reference ‘Relevant associated with the entity.

Persons’ may be considered in place of the Para 1 to 12 same.

66 Pg. 17 – Comment/Suggestion: Explanation in brackets defines term 'associated with' to Annex to The requirement for obtaining confirmation include past directorships as well. There may be instances Schedule II from relevant persons should be applicable where the Directors may have ceased to be directors of only for their tenure in the entity with whom other entity before this application, thus confirmation can be Para 1 they were associated. Thus, the phrase 'at given by them only about entities where they are currently any time prior to this application' may be directors, and so far as the past directorships in other replaced with 'during their tenure with such entities are concerned, confirmation may be provided only entities'. for their relevant tenure.

67 Pg. 17 – Comment: Any Relevant Person may not be said to be ‘not fit & proper’ Annex to It may be clarified whether Relevant Person only on the ground that he is or was a Non-Executive Schedule II can be treated as fit & proper even if a Director of such defaulting entity unless he was directly disclosure is made by them in this para, and responsible for such default.

Para 2 there is no direct involvement of the concerned Relevant Person where such person is only a Non-Executive Director in the said entity which has defaulted.

68 Pg. 17 – Suggestion: This will help to obtain accurate disclosure from the relevant Annex to The term 'substantial interest' may be persons about entities where they have substantial interest.

Schedule II defined.

Para 4 69 Pg. 17 – It may be clarified whether ‘Relevant Any Relevant Person should not be said to be ‘not fit & Annex to Person’ can be treated as fit & proper even proper’ only on the ground that he is or was a Non-Executive Schedule II if a disclosure is made by them in this para Director of any entity and is involved in any investigation and there is no conclusive order against him being such Director.

Para 5 from the regulatory / judicial authority and Relevant Person is or was a mere Non-Executive Director and is involved in any investigation being such Director.

70 Pg. 17 – Confirmation about entities where relevant Confirmation can be given by Relevant Persons only about Annex to person 'were' associated may be kept entities where they are currently hold office and for past Schedule II limited to the association of such person directorships in other entities for their relevant tenure.

'during their tenure in those entities' Para 6

IFSCA Response: The inputs / comments received from the public consultation were suitably considered. The said inputs / comments along with draft notification of IFSCA (Electronic Trading Platforms) Regulations, 2026, were placed before the Authority in the meeting held on July 24, 2026.