₹20 Crore Securities-Market-Asset Test for Body Corporates: Accredited Investor Proposal

By Ravi Sisodia · Reviewed by CA Divyanshu Sengar · Updated 5 October 2026

The SEBI consultation proposes a ₹20 crore securities-market-asset test for body corporates. Finance teams should model legal ownership and treasury assets carefully because group assets, subsidiaries and pledged holdings cannot simply be aggregated without a rule basis.

Finin2min 2-Minute Summary

• ₹20 crore is a proposed body-corporate securities-market-asset threshold, not an operative October 2026 rule.
• The applicant entity's own qualifying assets should be distinguished from promoter/group/affiliate holdings.
• Audited balance-sheet data may need a bridge to current market-value evidence for securities holdings.
• Encumbrances, treasury mandates and restricted assets should be visible in the calculation.
• Board/authorised-signatory evidence and beneficial-ownership/KYC remain separate onboarding controls.

Start with the legal entity, not the group brand

Identify the exact company/body corporate seeking accreditation and its own asset ownership. Do not pull securities from a parent or sister company merely because consolidated accounts show them in the same group.

Where the final framework permits another route for subsidiaries or group structures, apply that route explicitly rather than blending tests.

Bridge accounts to current securities evidence

Audited financial statements may show investments at accounting values that differ from the proposed eligibility measurement. Prepare a schedule from ledger to depository/custodian/fund statements with valuation date and methodology.

Explain restricted, pledged or non-qualifying holdings separately.

Corporate authority and accreditation are different

Even if the entity meets an asset test, verify who is authorised to seek accreditation and invest. Board resolutions, delegated authorities, constitutional objects and product-specific approvals may still matter.

Keep KYC/beneficial-owner review separate so the accreditation worksheet does not become a substitute for AML controls.

₹20 crore body-corporate case: group treasury creates false eligibility

A subsidiary may participate in a central treasury structure where investments are legally held by the parent but economically attributed internally to group entities. Consolidated MIS can therefore show more than ₹20 crore for the subsidiary even though the securities are not legally owned by it.

The proposed body-corporate test should be modelled from the applicant's legally qualifying assets under the final definition, not an internal treasury allocation unless SEBI expressly allows that treatment. Reconcile corporate books to custodian/depository ownership and identify intercompany balances separately.

If the entity later moves investments into or out of the applicant, preserve transaction dates instead of backfilling earlier eligibility.

• Reconcile treasury MIS to legal ownership.
• Separate intercompany receivables from qualifying securities.
• Use current entity-level evidence, not group consolidation alone.
• Preserve asset-transfer timing around the accreditation decision.

Board evidence for the applicant entity

A body corporate should preserve the management/board authority under which it seeks accreditation and invests, even if the final test is primarily asset based. This prevents the eligibility calculation from being treated as a substitute for corporate authority, treasury mandate or product-level approval.

• Keep corporate authority with the accreditation file.
• Separate treasury authority from regulatory eligibility.

Body-corporate checklist

• ₹20 crore labelled proposal.
• Applicant legal entity confirmed.
• Ledger-to-market evidence bridge.
• Group assets excluded unless final rule permits.
• Pledge/restriction analysis.
• Board/authorised signatory evidence.
• Independent eligibility review.

Questions readers commonly ask

Is the ₹20 crore threshold operative?

No. It is a proposal in SEBI's August 2026 consultation.

Can parent assets be added automatically?

No. Apply only the route and ownership treatment in the final framework.

Are audited accounts enough?

They are important evidence but may need a current securities-market valuation bridge.

Does accreditation replace corporate investment authority?

No. Board/delegated authority and other onboarding checks remain separate.

Official / primary sources

• SEBI - Consultation Paper on Review of Accredited Investor Framework - 13 August 2026 consultation - proposal, not operative final framework
• SEBI - Current Reports Listings - Source check shows consultation status
• SEBI - Angel Fund Accredited-Investor Timeline Circular - 7 September 2026 separate operative timeline circular; does not by itself adopt the consultation proposals

Disclaimer

Important: General educational and professional-reference material. Verify the current operative instrument, effective date and exact facts before acting. Consultation papers are not final law unless SEBI subsequently adopts them. Educational and professional reference only; confirm the current law, rates and the facts of your case before relying on this page.