GARUDA

Before an AIF can ask anyone for money, it has to file its private placement memorandum with SEBI. The old worry was how long that wait could run.

GARUDA is SEBI's answer. The name unpacks as Green Channel: AIF Rollout Upon Document Acknowledgement. The idea sits in the last three words. The clock starts when SEBI acknowledges the document, not when SEBI blesses it.

So the mechanism gives a fast track to launch a scheme and start circulating the PPM to investors.

There are two tracks inside it. Ordinary schemes file through a merchant banker and wait 10 working days. Funds whose investors are all accredited, and angel funds, file directly and may launch at once.

One thing GARUDA does not do is turn a filing into an approval. SEBI still only gives observations on a PPM.

The two tracks (Chapter 9, section 9.5.1). SEBI prescribes a separate process for:

• Regular Schemes — schemes other than a Large Value Fund for Accredited Investors (LVF), an Accredited Investor Only Fund (AI-only Fund) and Angel Funds; and
• LVFs, AI-only Funds and Angel Funds.

Regular schemes. The PPM is filed with SEBI through a SEBI-registered merchant banker at least 10 working days prior to launch of the scheme, on the SEBI Intermediary Portal, with the applicable scheme fee. The application fee is not applicable for the launch of the first scheme by an AIF. The documents filed alongside are:

• the signed Merchant Banker Due Diligence Certificate;
• signed fit and proper declarations for the AIF, Sponsor and Manager, as specified in Schedule II of the SEBI (Intermediaries) Regulations, 2008;
• Sponsor and Manager declarations on minimum continuing interest commitment; and
• PAN copies for the AIF, the scheme, Sponsor, Manager, Trustee, their directors or partners and the key investment team, with a machine-readable list of names and PANs.

The merchant banker exercises independent due diligence on every disclosure in the PPM and certifies veracity and adequacy on SEBI's prescribed format. Its details are disclosed in the PPM. SEBI may communicate comments to the merchant banker or the Manager before launch, and those comments must be incorporated before the scheme launches or the PPM circulates.

The launch clock. AIFs may proceed with the launch of a new scheme after 10 working days of filing the application with SEBI. A first scheme launches from the date of grant of SEBI registration or after 10 working days of filing, whichever is later.

LVFs, AI-only Funds and Angel Funds. These are exempt from filing through a merchant banker and from incorporating SEBI comments, because they launch under the intimation to SEBI model — so they can launch immediately upon filing the PPM. Their first schemes still launch only from the date of grant of registration. Their filing carries a signed and stamped undertaking by the CEO and the Compliance Officer of the Manager instead of a merchant banker certificate.

What GARUDA is not. The PPM is a regulated document, and every version change up to the final one must be highlighted in the final PPM. But SEBI provides only observations and does not approve the document — a sentence the prescribed disclaimer repeats in the PPM itself.

The legal basis the workbook cites. The SEBI (AIF) (Second Amendment) Regulations, 2026 with effect from 14 July 2026, and SEBI circulars dated 30 April 2026 and 30 July 2026.

The funds, dates and amounts are illustrative; the two tracks, the documents and the 10-working-day clock are the workbook's.

Fund A — a Regular scheme. Meridian India Opportunities Fund — Scheme III targets a Rs 250 crore first close from 40 investors, not all of them accredited. It is therefore a Regular scheme.

This is Scheme III, so no application fee relief applies; the relief is only for an AIF's first scheme. Had this been Scheme I and registration been granted on 30 September, the launch date would be 30 September — the later of the two.

Fund B — an LVF. Meridian Large Value Fund — Scheme I has 6 accredited investors committing Rs 40 crore each, a corpus of Rs 240 crore. It files its PPM on 1 September with an undertaking signed and stamped by the Manager's CEO and Compliance Officer. No merchant banker, no SEBI comments to incorporate — it may launch on 1 September, the day of filing.

The cost of the difference. Both funds intended to draw down their first tranche in September. Fund A loses 16 calendar days of deployment on Rs 250 crore. At an illustrative 12% a year that is roughly Rs 1.3 crore of foregone return — which is precisely what a green channel exists to save.

Chapter 9, section 9.5.1 (Filing of PPM and Launch of AIF Schemes) introduces GARUDA by name and then sets out the modalities for Regular schemes and for LVFs, AI-only Funds and Angel Funds. Chapter 15 restates the launch timing in its regulatory summary.

Expect a question on what GARUDA stands for, on which schemes must file through a merchant banker, on the 10 working days and the whichever is later rule for a first scheme, and on the distinction that SEBI gives observations, not approval. The list of documents filed alongside the PPM is also a ready-made multiple-choice.

• GARUDA is a launch process, not a registration route. Registration of the AIF is separate, and a first scheme still waits for it.
• Acknowledgement is not approval. The prescribed disclaimer says submission of the PPM to SEBI shall not be deemed or construed as approval, and SEBI assumes no responsibility for the disclosures or the Manager's performance.
• 10 working days, not 10 calendar days, and working days exclude Saturdays, Sundays and public holidays on which the concerned SEBI office is closed.
• Angel Funds sit with the LVFs here. For PPM filing they are outside the Regular scheme track — but the PPM audit relief for Angel Funds is separate and has its own Rs 100 crore condition.
• The application fee relief is for the first scheme only, and it is the application fee — the scheme fee itself is still payable.
• The undertaking replaces the merchant banker certificate, not the disclosure. An LVF still files a PPM; it just certifies it through its own CEO and Compliance Officer.
• Comments must be incorporated before circulation, not merely before closing. For a Regular scheme the PPM cannot go to investors carrying uncorrected text.