NPS Bharat Fund of Funds (NBFoF) is a dedicated Alternative Investment Fund (AIF) focused Fund of Funds established under the NPS framework to channel a portion of NPS assets (Pension Savings) into carefully selected AlFs in India.

 

It serves as an institutional investor in order to facilitate structured exposure of NPS assets to high-quality AIFs, while ensuring strong governance, risk management, and fiduciary discipline.

 

The NBFoF aims to:

  • Enhance long-term subscriber returns;
  • Provide portfolio diversification through alternative assets;
  • Generate alpha through investment in well-managed AIFs; and
  • Uphold the highest standards of governance, transparency, and fiduciary oversight.

The NPS Bharat FoF Platform is a centralized platform that facilitates the end-to-end process of mobilizing a portion of NPS assets into the AIF ecosystem.

 

The platform serves as a single-window interface for all pre-investment activities, including the onboarding, screening, evaluation, due diligence, and investment recommendation of eligible AIFs on behalf of the NPS Trust.

 

It also supports post-investment activities, including investment monitoring, performance tracking, compliance oversight, reporting, and ongoing portfolio management, thereby ensuring consistent governance, transparency, and effective oversight throughout the investment lifecycle.
 

Only SEBI-registered Category I and Category II AIFs are eligible for investment, in accordance with the applicable Pension Fund Regulatory and Development Authority (PFRDA) investment guidelines.

AIFs with a target corpus of ₹100 Crore or more are eligible to apply for consideration under the NBFoF.

AIFs may assess their eligibility for application by referring to the prescribed eligibility criteria available on the NBFoF website.
 

Eligible AIFs can only apply through the “Apply Now” Button on the NBFoF website. Only those AIFs who pass initial-assessment score can submit their application.

All required communications regarding the application status will be conveyed to the applicant. For instance, once the AIF Cell begins processing the application, a notification will be sent to inform the applicant accordingly. Similar updates will also be provided at subsequent stages of the process.

The NBFoF follows a sector-agnostic investment approach, with no predefined restrictions on sectors. Investments may be made across sectors, subject to applicable regulatory guidelines and internal evaluation criteria.
 

The investible corpus under NBFoF is as per the regulatory guidelines prescribed by PFRDA pertaining to investments in AIFs under NPS.

 

As per extant PFRDA investment guidelines:

•    Up to 1% of AUM (Government Sector) may be allocated to AIFs.
•    Up to 5% of Scheme E & C AUM (Non-Government Sector).

 

Note: Alternative Assets also includes investment in Gold/Silver ETFs & REITs/InvITs.

No, as per Section 25 of the PFRDA Act, 2013, Funds cannot be invested in securities of the companies or Funds incorporated and operated outside India. 

No, shortlisting does not guarantee a capital commitment. The selection process is conducted in two stages. Shortlisting by the Screening-Cum-Investment Committee constitutes only the first stage. Final commitment depends on:

 

•    Regulatory Ceilings prescribed by PFRDA.
•    Approval of the Pension Fund’s Investment Committee, based on the applicable terms and conditions decided by it.
 

 

The AIF Cell under NPS Trust conducts due diligence, including but not limited to:

 

•    Investment strategy evaluation
•    Track record verification
•    Governance review
•    Risk assessment
•    Legal and regulatory compliance
•    Operational diligence
 

AIFs are required to submit, inter alia, the following documents for evaluation by the AIF Cell:

 

•    SEBI registration certificate
•    Private Placement Memorandum (PPM) and Investment Management (IM) Agreement
•    Track Record (realized and unrealized performance)
•    Details of Key Members such as Directors/Partners of the AIF. 
•    Organizational Structure
•    Compliance certifications
•    Valuation policy
•    ESG Policy (if applicable)
•    Risk management framework
•    Litigation disclosure
•    PMLA-related declarations
•    Grading/Rating of AIF
•    Non Disclosure Agreement

 

The above list is indicative and not exhaustive. Additional information/documents may be sought as part of the evaluation process, wherever required.
 

Post-investment, AIFs shall provide periodic reporting, including, but not limited to:

 

•    Quarterly portfolio updates
•    Net Asset Value (NAV) statements
•    Capital account statements
•    Valuation reports
•    ESG reporting (if applicable)
•    Material event disclosures
 

Yes, the NBFoF may seek participation in the LPAC to facilitate effective oversight and governance.

 

This may include:

 

•    Representation on the LPAC
•    Participation in key governance matters
 

GPs are expected to adhere to high standards of professionalism and fiduciary responsibility, including:

 

•    Adherence to strong institutional governance standards
•    Regular and transparent communication with investors
•    Timely and accurate reporting
•    Strong alignment of interests with investors
•    High standards of ethical conduct
•    Focus on long-term value creation
 

The Contribution Agreement, along with any other relevant documents, shall be executed between the concerned Pension Fund scheme and the AIF.
 

A First-time Fund Manager is an Investment Manager that is raising and managing its first AIF and therefore lacks an established track record in managing AIFs or similar pooled investment vehicles, though the team may have prior individual experience in investments.

 

Further, An Investment Manager that has prior experience in managing an AIF in one category (e.g., debt) but is launching a fund in another category (e.g., equity) will be considered a first-time fund manager for that specific strategy, due to the absence of a demonstrated track record in the new category, and vice versa.

Last Fund refers to the latest vintage fund raised by the Investment Manager within the same strategy (e.g., Debt or Equity) as the proposed fund. Funds raised in a different category shall not be considered as the “Last Fund” for evaluation purposes.
 

AIF Business refers to the end-to-end fund management activities undertaken by the Investment Manager in relation to AIFs, including fundraising, deal sourcing, investment execution, portfolio management, monitoring, and exits.
 

Big Five auditors are Deloitte, PwC, EY, KPMG and Grant Thorton.

AIFs which invest primarily in equity or equity linked instruments or partnership interests of investee companies according to the stated objective of such fund. 

Fund that invests primarily in debt securities of listed or unlisted investee companies, typically through privately negotiated or structured credit instruments, in accordance with its stated investment objectives.

 

There is no restriction on the number of AIFs that may be funded by the NBFoF, as long as the investments remain within the limits prescribed under the PFRDA investment guidelines.

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