Comprehensive Annual Activity Report

SEBI supervises hundreds of AIFs it never sees day to day. It needs each of them to report, on a fixed calendar, what the fund has been doing. That reporting is done through Activity Reports.

The legal hook is Regulation 28 of the SEBI (AIF) Regulations: SEBI may at any time call upon an AIF to file such reports as it may desire about its activities. Building on that, SEBI has prescribed reporting formats through circulars, and — for ease of doing business — changed the frequency of Activity Report submission.

Under the current scheme there are two Activity Reports. The Comprehensive Annual Activity Report is the big one: all AIFs submit it at the end of March of every financial year, within 30 calendar days from the end of March, through the SEBI Intermediary Portal (SI Portal). Its partner, the Limited Quarterly Activity Report, covers the other quarters.

The reporting calendar around it (section 13.2.4):

Why no separate March quarterly report. The workbook says no separate quarterly submission is required for the quarter ending March because the Annual Activity Report already includes its data points. The annual report is therefore doing two jobs.

Inoperative funds (section 13.5.1, Table 12.1). An AIF tagged as an Inoperative Fund is exempt from the Annual Activity Report from the financial year subsequent to the financial year in which it is tagged. It instead submits an annual status report on retained amount and outstanding liabilities, to SEBI and investors, also within 30 calendar days from the end of March.

The workbook dates the current two-report scheme to a SEBI circular of March 4, 2026.

The fund and dates of tagging are illustrative; the deadlines are the workbook's.

Sabarmati Opportunities Fund, a Category III AIF, maps its SEBI reporting for the financial year 1 April 2026 – 31 March 2027:

For the year the fund files three Limited Quarterly Activity Reports and one Comprehensive Annual Activity Report — four activity filings covering four quarters.

Now suppose a sister scheme is tagged inoperative in November 2026. Its Annual Activity Report for the year ending 31 March 2027 is still due by 30 April 2027, because that is the year of tagging. From the following financial year (April 2027 – March 2028) it stops filing the Annual Activity Report and files the annual status report on retained amount instead.

Chapter 13, section 13.2.4 (Submission of reports to SEBI), lists the two Activity Reports and their deadlines; section 13.5.1 (Inoperative Funds) and its exemption table set out when the annual report stops. Chapter 13 sample question 2 asks how often activity reporting to SEBI happens — the answer is both annual and quarterly. Expect the 30-day and 15-day deadlines and the March-quarter rule.

• 30 calendar days from the end of March for the annual report; 15 calendar days from quarter end for the quarterly one. Calendar days, not working days.
• Activity reporting is both annual and quarterly — not annual only, not quarterly only.
• There is no separate Limited Quarterly Activity Report for the March quarter; the annual report includes those data points.
• All AIFs file it, not just Category III. The leverage report is the Category III-only addition.
• The Compliance Test Report is a different document, submitted by the manager to the Sponsor and Trustee, not filed as an activity report.
• Inoperative funds are exempt from the financial year after tagging, not from the date of tagging.
• Workbook labelling slip: the inoperative-fund exemption table in Chapter 13 is captioned "Table 12.1" and its first row repeats "Limited Quarterly Activity Report" twice. Read it as one row covering both activity reports.