Collective Investment Schemes

Collective Investment Schemes (CIS)

If you’re pooling money from investors and managing it as a shared investment venture — whether in agriculture, real estate, plantations, or alternative assets — SEBI may classify it as a Collective Investment Scheme. Without CIS registration, such arrangements can be treated as illegal fund-raising, even if intentions are genuine.

Proper registration protects the business, investors, and promoters from regulatory action.

What is a Collective Investment Scheme?

A CIS is a regulated investment structure where funds from multiple investors are pooled, managed collectively, and returns are shared based on contribution. SEBI approval is mandatory before launching, marketing, collecting funds, or operating such schemes in India.

Who needs CIS registration

  • Agri/plantation and farm yield schemes

  • Group real estate or land development projects

  • Revenue-sharing investment models

  • Large community-based investment pools

  • Businesses promising fixed or performance-linked payouts from pooled assets

If investors rely on the operator — not themselves — to generate returns, it likely qualifies as CIS.

Key eligibility requirements

  • Company incorporated under the Companies Act

  • Minimum net worth of ₹5 crore (₹25 crore within 3 years)

  • Fit and proper promoters and directors

  • Strong governance, risk, compliance, and investor protection systems

  • Clear business plan, investment objective, and asset oversight

What we assist with

  • CIS eligibility analysis and structuring

  • Drafting offer documents, agreements, and disclosures

  • SEBI application preparation and filing

  • Compliance framework, trustee appointment, and investor safeguards

  • Responding to SEBI queries and inspections

  • Post-registration reporting, governance, and annual compliance

Documents usually required

  • Incorporation documents, shareholding, and board details

  • Net worth and audited financials

  • Business plan, investment model, revenue distribution structure

  • Trustee appointment and governance policies

  • Investor onboarding, KYC, grievance procedures

  • Risk management and asset monitoring framework

Our process

  1. Understand business model and investor structure

  2. Confirm whether CIS regulations apply

  3. Prepare documents, policies, and compliance framework

  4. File application and support SEBI evaluation

  5. Assist in onboarding and post-approval obligations

Frequently Asked Questions

1. When does an investment model become a CIS?

If money is pooled, managed collectively, and investors expect returns without active involvement.

 

2. Can an unregistered entity run a CIS?

No. SEBI restricts unregistered schemes and may initiate action.

 

3. How long does CIS registration take?

Generally 4 to 9 months, depending on documentation and SEBI review.

 

4. Are real estate investment groups covered under CIS?

Often yes, unless structured within permitted exemptions.

 

5. Do we need a trustee?

Yes. Trustees safeguard investor assets and interests.