Digitisation of FPI Onboarding

 The recent SEBI Circular dated 20 August 2026 permitting the submission of a digitally signed Power of Attorney (PoA) as part of the registration process for Foreign Portfolio Investors (FPIs) represents a significant and welcome step towards simplification and digitalisation of the regulatory framework governing FPI onboarding.

Under the revised framework, the requirement of having the Power of Attorney subjected to notarisation, apostillisation or consularisation is effectively dispensed with where the prescribed digitally signed documentation is submitted in accordance with the applicable requirements. This is a particularly important procedural reform, as the traditional process of notarisation, apostillisation or consularisation of documents executed outside India can often be cumbersome, time-consuming and disproportionately expensive, particularly for overseas applicants having to comply with the formalities prescribed by multiple jurisdictions.

The relaxation is therefore likely to substantially reduce the administrative burden associated with FPI registration and facilitate a faster, more efficient and technology-driven onboarding process. More importantly, it reflects a regulatory approach that recognises the realities of cross-border transactions and the need to eliminate procedural requirements that may no longer serve a meaningful regulatory purpose in an increasingly digital environment.

The initiative is also consistent with the broader objective of ease of doing business, particularly in the context of attracting and facilitating foreign investment into India. While appropriate safeguards relating to authenticity, integrity and enforceability of documents must necessarily continue to remain in place, regulatory compliance should, wherever possible, be achieved through technology-enabled verification mechanisms rather than through purely procedural and documentary formalities.

It is hoped that this progressive approach adopted by SEBI will serve as a precedent for other regulators and government authorities, including the Ministry of Corporate Affairs (MCA), Reserve Bank of India (RBI) and other statutory and regulatory bodies dealing with cross-border transactions and foreign entities.

There is considerable scope for reviewing the continuing requirement of notarisation, apostillisation and consularisation of documents executed by foreign parties, particularly where the authenticity and identity of the signatory can be established through reliable digital means or other technology-enabled verification mechanisms.

A calibrated transition towards digitally signed, electronically verifiable and self-certified documentation, supplemented by appropriate risk-based verification wherever necessary, could significantly reduce compliance costs and turnaround time without compromising regulatory oversight.

SEBI’s latest initiative is therefore more than a mere procedural relaxation. It represents a broader shift towards trusting technology, reducing redundant formalities and making regulatory compliance proportionate to the underlying risk. It is hoped that other regulators will take note of this development and similarly examine whether long-standing documentary requirements can be rationalised, thereby making India’s regulatory ecosystem more efficient, predictable and conducive to cross-border investment and business.