SEBI's 2012 rule still separates commitment from capital

The record

India's Securities and Exchange Board (SEBI) notified the Securities and Exchange Board of India (Alternative Investment Funds) Regulations, 2012 in the Gazette of India on 21 May 2012, according to the regulation's own consolidated text. The regulation created the Alternative Investment Fund (AIF) registration category and split it into three. Category I is defined as investing 'in start-up or early stage ventures or social ventures or SMEs or infrastructure or other sectors...which the government or regulators consider as socially or economically desirable,' including venture capital funds, SME funds and angel funds. Category II covers funds that do not fall into Category I or III and do not use leverage beyond what the rules permit, such as private equity or debt funds. Category III covers funds using complex or leveraged trading strategies. India's venture funds register under Category I.

What the sources establish

The regulation's own text, as amended through 2026, defines a term central to how a fund's size gets reported: 'corpus' means 'the total amount of funds committed by investors to the Alternative Investment Fund,' a definition of a commitment, not capital actually deployed. SEBI's own published data on AIF activity, current as of the quarter ending 30 June 2026, reports three separate columns for every AIF category: Commitments Raised, Funds Raised and Investments Made, each in rupees crore, noting the figures are compiled from quarterly information funds submit to SEBI on a net basis. Those three numbers are not interchangeable, and SEBI's own table keeps them apart.

Scope and revision

A commitment in SEBI's corpus figures is a contractual pledge by an investor, not money the fund has necessarily called or deployed. Funds Raised reflects capital actually drawn down, and Investments Made reflects capital placed into portfolio positions, which SEBI further splits between listed and unlisted securities and between equity, debt and fund-of-fund structures. The regulation has been amended repeatedly since 2012, with the consolidated text listing amendments dated as recently as 18 April 2026, so a reader should confirm which amendment was in force on the date described, rather than assume the 2012 text is current on every point.

The decision in front of you

A founder, LP or analyst reading a figure attributed to 'SEBI AIF data' should identify which of the three columns produced it, because treating a commitment total as deployed venture capital overstates how much money has reached companies. This is editorial guidance: the same caution applies whenever a regulator's or association's activity data separates a pledge from a disbursement, a distinction the AIF framework makes explicit.

• Is the figure quoted a commitment (corpus), a funds-raised figure, or an investments-made figure, and does the source say which?
• Which AIF category, and which sub-category within Category I, does the figure cover?
• Has the specific regulatory clause behind a compliance claim been checked against the amendment in force on the relevant date?

The 2012 regulations did not just create a registration requirement; they created a reporting vocabulary, and SEBI's quarterly tables still enforce the distinction between what investors have promised and what a fund has actually invested.