IFSCA makes IFSC credit rating agencies give issuers a pre-publication review of rating actions
IFSC credit rating agencies must let issuers review a rating's key basis for factual errors before the rating is published
Change
On 16 July 2026, the International Financial Services Centres Authority (IFSCA) amended its Master Circular for Credit Rating Agencies in the IFSC, with immediate effect, to require CRAs to give an issuer the principal considerations behind a rating action and a chance to correct factual errors before dissemination, to extend the framework to cover issuer ratings and a new Financial Strength Rating, and to impose a records standard detailed enough to reconstruct the rating process.
Why it matters
The amendment adds a pre-dissemination step to the rating workflow: before publishing a rating action with its rationale, a CRA must give the issuer the critical information and principal considerations on which the rating will be based and an opportunity to clarify factual errors, omissions or misperceptions likely to have a material effect — except for unsolicited ratings and private credit rating assignments. It expands the rated perimeter to include the issuer, not only the financial instrument, folds in credit quality and similar rating services by any name, and creates a Financial Strength Rating category. It tightens records: a CRA must keep records sufficient to reconstruct the rating process for each action and the factors underlying it, record a summary of the material considerations and the key arguments for and against the decision without attributing comments to individuals, and retain records from the date a rating is withdrawn under the CMI Regulations 2025. Private credit rating assignments are exempted from the website-disclosure requirement.
Implications
- — Rating-operations and analyst teams at IFSC-registered CRAs must insert a pre-dissemination issuer-review step into the rating-action workflow — before publishing, disclose the rating with rationale and give the issuer the principal considerations and a chance to correct factual errors, omissions or misperceptions with material effect — except for unsolicited and private rating assignments, where the step is not mandatory.
- — CRA records and compliance teams must maintain records detailed enough to reconstruct the rating process for each action, capture a summary of material considerations and the key arguments for and against the decision without attributing comments to named individuals, and retain records from the date a rating is withdrawn or discontinued per the CMI Regulations 2025 — records that only hold the final outcome no longer meet 13.1.10–13.1.12.
- — CRA methodology and registration teams must extend rating coverage to issuer ratings (not only instrument ratings), treat credit quality and similar services as credit ratings whatever they are named, and accommodate the new Financial Strength Rating category — activity previously treated as outside the instrument-rating perimeter now falls within the framework.
- — CRA disclosure teams must apply the private-assignment carve-outs correctly: the pre-dissemination issuer-review step and the website-disclosure requirement do not apply to private credit rating assignments, so mis-classifying a private assignment as public triggers disclosure obligations that do not apply, and the reverse under-discloses a public rating.
Who is affected
- — Rating-operations and analyst teams at IFSC-registered CRAs
- — CRA records and compliance teams
- — CRA methodology and registration teams
- — CRA disclosure teams