The shareholder you did not pitch
Under one of these schemes the party on your share certificate is not the party whose money it is, and your next investor will want that explained.
Summary
- Three schemes in the register buy shares: GENESIS Matching Investment, the SIDBI iDEX seed fund at SINE, and the SIDBI seed fund at a-IDEA.
- Under GENESIS an implementing agency holds the shares as nominee, while ownership vests with MeitY Startup Hub. One holding, two names.
- Milestone tranches mean the stake builds over months, so the holding on the day you sign is not the holding your next investor sees.
Founders sort money into dilutive and non-dilutive and stop there. Government is a third case. It behaves like neither the grant next to it in the register nor the angel round you closed last year. The difference shows up in diligence rather than at signing.
The register carries three equity schemes, and they are not alternatives to each other. GENESIS Matching Investment is for a company that has already banked a private round. The SIDBI iDEX seed fund at SINE is for defence startups that have won an iDEX challenge. The SIDBI seed fund at a-IDEA is for agritech at prototype or early commercialisation stage.
Which schemes actually buy shares?
Three out of the ten families we track. The rest are grants, loans, a guarantee or a reimbursement, and none of those touches your share register.
What each equity scheme buys, and whose name ends up on the share register
| Scheme | What it puts in | Who appears on your register |
|---|---|---|
| GENESIS Matching Investment | Up to INR 50 lakh, matching 1:1 the private equity you have already received | The implementing agency, as nominee. Ownership vests with MeitY Startup Hub |
| SIDBI iDEX Seed Fund at SINE | INR 10 lakh to INR 1.5 crore, in one or more milestone-linked tranches | Not recorded in the register. Settled in the legal documentation before the first tranche |
| SIDBI Seed Fund at a-IDEA | Up to INR 1 crore, as equity or an equity-linked instrument | SIDBI, as a named investor, with the a-IDEA vehicle co-investing |
Two of the three run through an incubator and the third runs through an implementing agency. In all three, the institution you deal with is not the institution whose money it is. That gap is the subject of this article.
Both SIDBI programmes run on calls rather than continuous intake. The last windows the register records closed in July 2026, at SINE and at a-IDEA, so check for a fresh call before you plan around either.
Who is the shareholder under GENESIS?
Not the body that decided to fund you. The money is approved by MeitY Startup Hub, routed through an implementing agency, and the agency holds the resulting shares as nominee. Ownership vests with MeitY Startup Hub. The cash itself goes straight into the startup's own bank account.
Understand that split before it appears on your register of members. There is a name on the share certificate and a different party whose money it is. Both have to be explicable later, by you, to somebody who has heard of neither.
The scheme is also strict about the private round it is matching. The investment must have been received in your bank account, so a signed does not count. It must be an equity instrument, so a convertible round does not count. Under the 2.0 call the investor must be registered.
Four sources are excluded from the match: government funds and grants, incubators under SAMRIDH, founders' family members, and foreign direct investment, which 2.0 added. A government grant you have already taken does not bar you from applying. It simply does not count towards the match.
The window matters as much as the rules. GENESIS runs cohort calls rather than rolling intake, and the Investment 2.0 call opened on 29 August 2026 and closes on 24 September 2026. Between calls the scheme is entirely alive with nothing open to apply to.
Why does the stake build instead of landing?
At SINE the investment is released in one or more milestone-linked tranches, decided by the investment committee, after a term sheet, due diligence and legal documentation. A band of INR 10 lakh to INR 1.5 crore is wide. Where you land inside it is settled over time, not on the day you are selected.
At a-IDEA the ceiling is INR 1 crore and the exact amount is decided by the fund's selection committee. The register records the instrument as equity or an equity-linked one such as compulsorily convertible preference shares, and does not confirm which applies in a given window. Ask, and get the answer into the term sheet.
It is worth saying plainly that the published criteria at a-IDEA are not the complete test. The call lists focus areas across post-harvest technology, food technology, supply and value chain, agri-fintech, fisheries and aquaculture, animal husbandry and farm mechanisation. A committee scores fit against those, and a scored preference is not a rule you can read off a page.
For your , a tranched investment is not one event. Each release comes with its own conditions, and the holding after the last tranche is the one a later investor sees.
A grant asks what you spent. An equity scheme asks who owns you, and it keeps asking.
What does a later investor ask about it?
Three questions, in the diligences we run, almost every time. Who holds the shares and on whose behalf. What the governing documents say about consent rights, transfers and exit. And whether the reporting owed to the scheme survives the new round.
The register records no board rights for any of the three schemes. An absence of a recorded right is not the same as an absence of the right. Read the shareholders' agreement you are asked to sign, not the brochure you applied from.
Two things about GENESIS are genuinely unsettled in the public documents, and the register flags both. The first is how the MeitY Startup Hub tranche is priced, meaning whether it comes in on the private round's terms or on separately negotiated ones. The second is whether the 1:1 match runs against all the private money you have raised or only the current round.
Both are answerable by the implementing agency and both belong in writing before you sign. It is the same discipline as finding the problems before your investor does, applied to a shareholder you did not negotiate with.
Why your share register has to agree with your cap table
Because the scheme checks. GENESIS asks at application for a cap table, a valuation report and investor term sheets. Before disbursement it asks for a verified term sheet, proof that the private investment was received, a shareholders' agreement, an updated cap table and a board resolution accepting the funds.
That is a stack of documents describing one company, and it only works if they agree. An allotment that lives in a spreadsheet and never reached the register of members is the usual point of failure. An option pool that exists in a board minute and nowhere else is the next one.
The SINE programme arrives at the same place by a different route, through due diligence and legal documentation before the first tranche is released. A fund that has decided to invest still needs your paperwork to close.
Fix the cap table before you apply
Not after selection, when the pre-disbursement list lands with a deadline on it. The work itself is ordinary. Every allotment recorded, every convertible instrument listed with its terms, the option pool agreed, and the register of members matching what you have filed with the MCA.
One trap is specific to GENESIS. If your last round was convertible debentures, it does not count towards the match, whatever the amount was. Founders who raised on convertibles because it was faster find the scheme counting a number they do not have.
Our guide to the cap table sets out the version of that document which survives diligence. If you are still choosing between instruments rather than fixing one, read the chooser and the seven stages of an application next.
Frequently asked questions
Does a government scheme take a board seat?
The register records no board rights for GENESIS or for either SIDBI seed programme. What it does record is the nominee holding under GENESIS, and a term sheet with legal documentation under the SINE programme. Read the documents rather than assuming either way.
Does a convertible round count towards the GENESIS match?
No. The match counts equity actually received in your bank account, and convertible debenture rounds are excluded. If your private money came in as convertibles, the matchable figure is smaller than the raise you announced.
Does a grant I have already taken reduce what GENESIS will match?
It does not stop you applying, and it does not add to the match either. Government funds and grants are an excluded source, alongside SAMRIDH incubators, founders' family members and foreign direct investment.
Can I get SIDBI seed money without an incubator?
Not through these two. The a-IDEA programme asks that you are incubated there or incubation ready, and the SINE fund is for startups referred by iDEX after winning a challenge. The incubator is part of the eligibility rather than a formality.
General guidance, current as at September 2026. Scheme windows, instruments and holding arrangements change, and the documents you are asked to sign beat anything written here. If you want your cap table and your statutory register reconciled before an application, our grants and schemes work covers it, and it is CS Manavi Arora's desk.
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Lead - Company Secretarial, Compliance & Fundraise Advisory
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