Accredited Investor Securities-Market-Asset Test: How the Proposed Eligibility Screen Would Work

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

The consultation proposes securities-market-asset tests as new accreditation routes. The compliance challenge is defining eligible assets, valuation date, ownership, encumbrance and evidence consistently rather than simply adding account balances.

Finin2min 2-Minute Summary

• The securities-market-asset approach is proposed, not an operative October 2026 test.
• The consultation explores asset-based thresholds for individuals and body corporates in the securities-market context.
• Eligibility calculation should use defined included/excluded assets and reliable valuation evidence.
• Joint ownership, pledged securities, derivatives, private/unlisted holdings and foreign assets need explicit treatment under the final rule.
• A manager-led route would require reproducible calculation and independent review.

Define the asset perimeter before calculating

Create an asset taxonomy aligned to the final SEBI wording: listed securities, mutual funds, debt securities, cash/securities-market balances and any other included class. Mark assets that fall outside the proposed definition rather than using broad personal net worth.

Do not count the same exposure twice through direct holding and a controlled entity unless the final framework expressly permits it.

Valuation date and source decide the result

Set a consistent cut-off and acceptable source hierarchy such as depository statement, RTA/fund statement, custodian statement or audited financial record. Stale private valuations or a screenshot without date should not be accepted simply to clear a threshold.

Record FX source where foreign holdings are ultimately relevant under the final rule.

Ownership and encumbrance need explicit rules

Joint holdings, pledged securities and assets legally owned by another family member can materially change eligibility. The accreditation worksheet should show gross value, exclusions/adjustments and eligible net amount line by line.

Any judgement should be reviewed independently and linked to the policy clause.

Asset-taxonomy edge cases that need a written rule

A proposed securities-market-asset test becomes difficult at the margins: listed shares pledged for a loan, units held jointly with a spouse, unlisted securities with stale valuation, ESOPs not yet exercised, overseas ETFs, margin balances and securities owned through a personal holding company. A calculator without policy definitions will produce inconsistent answers.

Build an eligibility dictionary that states included, excluded and 'legal review required' categories under the final text. Each calculation line should point to the evidence source and rule interpretation used.

When the final framework is issued, lock the dictionary version to every accreditation decision so a later policy change does not silently alter historical results.

• Maintain included/excluded/conditional asset taxonomy.
• Tie each asset line to a dated source document.
• Version-control interpretation policy.
• Escalate novel asset types instead of forcing them into a category.

Calculator governance

If managers build an internal eligibility calculator, keep the threshold, asset rules and valuation logic in configurable policy fields rather than code scattered across spreadsheets. Every calculation should display its policy version. That makes a future SEBI change auditable and prevents two teams from using different interpretations of the same proposal.

• Version the calculator rules.
• Show policy version on every eligibility output.

Asset-test checklist

• Proposal status and final-rule monitor.
• Eligible-asset taxonomy.
• Valuation cut-off and source hierarchy.
• Ownership verification.
• Pledge/encumbrance treatment.
• Double-counting control.
• Independent calculation review.

Questions readers commonly ask

Is ordinary net worth the same as securities-market assets?

Not necessarily. Use the definition SEBI ultimately adopts.

Can property be counted automatically?

Do not assume so; the proposal focuses on a securities-market-asset test.

How should joint assets be handled?

According to the final rule and documented ownership; do not count full value by default.

Why does evidence source matter?

Because accreditation should be reproducible from reliable dated records.

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.