IFSCA Mandates Display of Key Global Access Risks at Every Client Login

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  • Last Updated on 28 November, 2025

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IFSCA risk disclosure mandate

Circular eF.No. IFSCA-DSI/12/2025-Capital Markets, Dated: 26.11.2025

1. Overview

The International Financial Services Centres Authority (IFSCA) has issued a directive requiring Global Access Providers (GAPs) and Introducing Brokers (IBs) to display key risk disclosures to clients at every login.

This mandate aims to strengthen investor awareness and ensure that clients are fully informed of the risks associated with accessing global markets through IFSC intermediaries.

2. Mandatory Display of Key Risks

As per the circular, the following key risks listed in Annexure I must be prominently displayed to clients at each login session:

2.1 Market and Interest Rate Risks

  • Volatility in global markets
  • Fluctuations in interest rates affecting asset values

2.2 Currency Movement Risks

  • Forex fluctuations impacting returns
  • Exposure to currency conversion losses

2.3 Custody and Settlement Risks

  • Risks arising from foreign custodians
  • Settlement delays, failures, or cross-border operational constraints

2.4 Technology and Cybersecurity Risks

  • Potential system outages
  • Cyber-attacks, data breaches, and platform vulnerabilities

2.5 Regulatory and Taxation Risks

  • Changes in foreign regulations
  • Divergent tax rules that may impact investor obligations and returns

These disclosures are intended to ensure that clients understand the inherent risks associated with international market access and cross-border products.

3. Compliance Requirements for GAPs and IBs

3.1 Display Format and Placement

GAPs and IBs must:

  • Display risk disclosures exactly in the manner prescribed under Clause 39 of the circular,
  • Ensure they appear prominently and unavoidably upon each client login,
  • Implement the disclosure mechanism across all platforms, including mobile apps and web portals.

4. Implementation Timeline

IFSCA has stipulated that full compliance must be ensured by December 31, 2025.

Entities are expected to upgrade systems, interfaces, and investor communication modules to meet this deadline.

5. Significance

This directive aims to:

  • Enhance transparency and investor protection,
  • Promote informed decision-making by clients accessing global markets,
  • Reduce the likelihood of disputes by setting clear expectations on risks,
  • Strengthen IFSC market infrastructure in line with global best practices.
Click Here To Read The Full Circular

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Author: Taxmann

Taxmann Publications has a dedicated in-house Research & Editorial Team. This team consists of a team of Chartered Accountants, Company Secretaries, and Lawyers. This team works under the guidance and supervision of editor-in-chief Mr Rakesh Bhargava.

The Research and Editorial Team is responsible for developing reliable and accurate content for the readers. The team follows the six-sigma approach to achieve the benchmark of zero error in its publications and research platforms. The team ensures that the following publication guidelines are thoroughly followed while developing the content:

  • The statutory material is obtained only from the authorized and reliable sources
  • All the latest developments in the judicial and legislative fields are covered
  • Prepare the analytical write-ups on current, controversial, and important issues to help the readers to understand the concept and its implications
  • Every content published by Taxmann is complete, accurate and lucid
  • All evidence-based statements are supported with proper reference to Section, Circular No., Notification No. or citations
  • The golden rules of grammar, style and consistency are thoroughly followed
  • Font and size that's easy to read and remain consistent across all imprint and digital publications are applied