Fund of Funds for Startups

Description
To meet the funding needs of startups, Government of India has established Fund of Funds for Startup FFS under Startup India Programme. Corpus of the FFS is ₹10,000 crore. DPIIT, Government of India is the monitoring agency and SIDBI is the operating agency for FFS. As per the operating guidelines, FFS contributes to the corpus of SEBI registered Alternative Investment Funds AIFs . These AIFs in turn have to invest at least twice the contribution under FFS, in ‘startups’ as defined by the Government of India gazette notification. The objective of FFS is to provide equity support to startups and encourage innovation and entrepreneurship. It targets DPIIT-recognized startups working in technology, research, and innovation across various sectors. A key feature is the multiplier effect, AIFs must invest at least twice the amount contributed by SIDBI, ensuring more funds flow into the ecosystem. Benefits include access to patient capital, mentorship, and industry networks. The scheme also boosts credibility for startups, making it easier to attract follow-on investments. With an initial corpus of ₹10,000 crore, FFS has supported thousands of startups and promoting innovation. Overall, it plays a vital role in building a strong venture capital market and driving India’s economic growth through entrepreneurship.

Exclusions
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Benefits
• 1) Equity/ equity linked instruments-based funding to startups.
• 2) Mentorship through experienced AIF managers along with market connects, governance structure.
• 3) Mobilisation of capital, attracting private investors and mobilising larger capital for startups.
• 4) Support for innovation-driven enterprises, fostering job creation and economic growth.
• 5) Strengthens India’s venture capital ecosystem and promotes entrepreneurship.
• 6) AIFs must invest at least twice SIDBI’s contribution creating a multiplier effect, scheme helped mobilise more than ₹90,000 crore through AIF.

Eligibility Criteria
1. Under FFS support is provided to AIFs. Below are the key eligibility criteria for applying for contribution under FFS
2. • Funds are registered as either Category I or II Alternative Investment Funds (AIF) with Securities and Exchange Board of India (SEBI) or have applied for the same with SEBI.
3. • Funds with corpus of less than Rs 1,000 crores.
4. • Fund`s investment strategy to include investment in startups (Startup as defined as per the Gazette Notification G.S.R.127(E) dt. 19/02/2019 issued by Government of India and as amended from time to time).
5. • Fund to agree to invest at least twice the amount of contribution sought from FFS into Startups. (For instance, if contribution sought is Rs 100 crore under FFS, Fund should invest at least Rs 200 crore in Startups).
6. • Fund Manager / team should have prior track record in Fund management or prior investment experience. All the Key members of the Fund should have CIBIL score more than 650 (Key member is defined as Director, Sponsor and Senior Personnel of the Fund).
7. • All the Key members should be legally eligible to be a Director or in a Managerial position under Indian law (i.e., not barred to be a Director or in a Managerial position under Indian Law).
8. • Startup should be up to 10 years old from the date of incorporation.
9. • Must be DPIIT-recognized.
10. • Should be working on innovation, development, or improvement of products, processes, or services.
11. • Funding is indirect, through SEBI-registered AIFs supported by SIDBI.
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Application Process
Step 1: Step 1: Eligibility Screener and Registration
Online
Initial check to confirm applicant meets basic eligibility criteria and registration on the portal.

Step 2: Step 2: Preliminary Questionnaire
Online
Collection of key details about the fund, strategy, and compliance for initial assessment.

Step 3: Step 3: Feedback, Go / No-Go
Online
Questionnaire helps in decision making on whether the proposal moves forward based on preliminary review.

Step 4: Step 4: First Meeting
Online
Introductory discussion to understand fund objectives, structure, and alignment with FFS goals.

Step 5: Step 5: Detailed Application
Online
Submission of comprehensive documents including fund strategy, team credentials, and compliance.

Step 6: Step 6: Due Diligence Completed
Online
Detailed evaluation of fund strategy, Fund manager past experience, governance, and operational aspects of the fund.

Step 7: Step 7: Second Meeting, Feedback & Terms Discussion
Online
Discussion on due diligence findings and key terms & conditions.

Step 8: Step 8: VCIC Appraisal Memo Submission
Online
Preparation and submission of Venture Capital Investment Committee (VCIC) appraisal summarizing evaluation and recommendations.

Step 9: Step 9: Present to VCIC Investment Committee
Online
Formal presentation to the VCIC for approval and strategic fit assessment.

Step 10: Step 10: SIDBI’s Executive Committee
Online
Final review and approval by SIDBI’s Executive Committee for sanctioning investment.

Step 11: Step 11: Final Feedback, Post IC & EC, Issue of LOI
Online
Communication of decision and issuance of Letter of Intent (LoI) to the selected fund.

Step 12: Step 12: Agreements Finalisation
Online
Drafting and signing of legal agreements to formalize the investment commitment.

Step 13: Step 13: Onboarded for the Fund Lifecycle
Online
Completion of onboarding and monitoring throughout the fund’s lifecycle.

Required Documents
• 1) AIF registration certificate
• 2) IM Agreement
• 3) Past Track record (If any)
• 4) PPM (Private Placement Memorandum)
• 5) AIF and Fund’s Financials
• 6) Trust Deed
• 7) Contributors Details
• 8) Startup Certificate
• 9) KYC Documents (Aadhar Card, Pan Card (Individual and Company), Financials, CIBIL Score)
• In case of startups, please visit AIF’s website.
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Frequently Asked Questions
Q: Does SIDBI charge any processing fee for evaluating proposals under FFS?
A: No, SIDBI does not charge any processing fee for evaluating proposals under the FFS programme.
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Q: Are category I Funds eligible under FFS?
A: Yes, all AIFs registered under SEBI AIF Regulations, 2012 (Category I and II) are eligible.
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Q: Is there any corpus limit for AIFs under FFS?
A: Yes, AIFs with a corpus of less than ₹1,000 crore are eligible for funding under the FFS scheme. Through modifications under FFS regulations, AIFs with a corpus exceeding ₹1,000 crore can also be supported, subject to the following conditions:
• IM must be a domestic entity.
• The IM or its key personnel should have previously managed funds to which SIDBI has committed in the past.
• SIDBI’s exposure to such funds will be capped at the same level applicable to funds with a corpus of ₹1,000 crore.
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Q: Does SIDBI or Government of India have a say in the investment decisions of the AIF?
A: No, investment decisions of investing in any startups are taken by the investment committee of respected AIF.
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Q: What are the general covenants for AIFs under FFS?
A: AIFs must maintain high standards of corporate governance, investor reporting, and comply with SEBI, RBI guidelines.
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Q: What is the definition of a Startup under FFS?
A: Age: Up to 10 years from incorporation/registration date. Turnover must not have exceeded ₹100 Crore in any financial year since incorporation. It must be incorporated as a Private Limited Company, a Registered Partnership Firm, or a Limited Liability Partnership (LLP) in India. Additionally, it is working towards innovation, development, or improvement of products, processes, or services, with potential for high scalability, employment generation, or wealth creation.
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Q: Are AIFs required to be registered with SEBI before approaching SIDBI?
A: Yes, SEBI registration is mandatory before applying to SIDBI.
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Q: Do startups under FFS need to be registered with the DPIIT?
A: Yes, its mandatory.
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Q: Is there any sector-specific eligibility for startups under FFS?
A: No, FFS is sector-agnostic.
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Q: Can AIFs invest in foreign entities under FFS?
A: Generally, investments should be in Indian entities. Investments abroad are allowed only as per SEBI/RBI guidelines, but they do not count toward the multiplier condition.
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Q: When must AIFs fulfill the condition of investing twice the amount received from FFS?
A: This condition must be met by the end of the commitment period of the Fund, with compliance status reported periodically.
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Q: What is the term of AIFs under FFS?
A: Typically, 8–10 years from Final Closing, not exceeding 12 years.
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Q: Can AIFs make warehoused investments before First Closing?
A: Yes, they can, and such investments can later be acquired by the Fund at cost without holding charges.
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Q: Who decides the investments under AIFs supported by FFS?
A: While the VCIC recommends the proposal, final decision of the investment is taken by Executive Committee of SIDBI.
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Q: What reporting and compliance requirements apply to AIFs under FFS?
A: AIFs must maintain proper records, appoint auditors acceptable to SIDBI, and comply with SEBI, RBI, and KYC norms.
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