SEBI Clarifies PAN Allotment Requirements for FPIs

On May 15, 2026, the Securities and Exchange Board of India (SEBI) issued a press release clarifying certain procedural requirements relating to Permanent Account Number (PAN) allotment for Foreign Portfolio Investors (FPIs), with the objective of removing practical difficulties in the onboarding process.

The clarification follows the notification of the Income-tax Rules, 2026, and revised PAN application forms by the Central Board of Direct Taxes (CBDT) on March 20, 2026, pursuant to the broader transition to the new direct tax framework under the Income Tax Act, 2025. The Income Tax Act, 2025 replaced the Income-tax Act, 1961, with effect from April 1, 2026, and seeks to simplify the tax framework, reduce interpretational ambiguity, and align India’s tax administration with a modern, technology-driven compliance system.

Under the revised framework, several fields in the PAN application forms, including details relating to Taxpayer Identification Number (TIN), Representative Assessee (RA), Authorised Representative (AR), and certain contact details that were previously optional, were made mandatory.

The changes gave rise to operational and compliance concerns for FPIs, particularly in jurisdictions where equivalent identification numbers or documentation frameworks may not be readily available. In view of the practical challenges expressed by stakeholders in furnishing such information, SEBI engaged with CBDT to facilitate continued ease of PAN allotment and onboarding for FPIs. Pursuant to these discussions, CBDT issued a set of clarifications to SEBI to streamline the PAN issuance process.

Clarifications relating to RA/AR Details

SEBI clarified that for the purposes of the RA/AR field in the Common Application Form (CAF), the name of the Authorised Signatory (AS) authorised by the FPI to sign the CAF would be sufficient. Further, the liability of such an Authorised Signatory would remain limited solely to the purpose of applying for PAN. No supporting documentation in respect of the AS, RA or AR would be required to be furnished.

Clarifications on Contact Information

With respect to the address, mobile number/landline number, and email ID fields concerning the RA/AR, SEBI stated that the corresponding details of the Authorised Signatory may be provided, where available. In cases where such details are unavailable, the relevant details pertaining to the FPI itself may be furnished instead.

Further, in situations where the mobile number of the FPI is unavailable, the landline number of the FPI may be provided in place of the mobile number in the contact details section.

Clarifications relating to PAN, Aadhaar and TIN Requirements

SEBI also clarified that where the PAN, Aadhaar and Passport Number of the Authorised Signatory are available, the same may be furnished. However, if such details are unavailable, the registration number of the FPI may instead be provided.

Additionally, in jurisdictions where a Taxpayer Identification Number (TIN) or its equivalent is not applicable, applicants may populate the TIN field with the value “0000000000.”

Common Application Form Framework

The press release also reiterates that FPIs utilise a single Common Application Form (CAF) for the purposes of registration with SEBI, opening of bank and demat accounts, and issuance of PAN.