India has emerged as a significant exporter of capital in recent years, with outward foreign direct investment reaching $48.6 billion in FY26, representing an increase from $43.7 billion in FY25. According to reports from Essential Business Intelligence, Indian companies are also raising foreign-currency debt at scale, with more than 170 bonds listed by over 50 issuers, raising close to $68 billion through GIFT City. This substantial capital movement has established India as a key player in global financial markets.
Despite India's growing capital exports, the country has not yet developed institutions capable of matching this scale. As reported by Essential Business Intelligence, when Indian companies raise dollar bonds, Indian banks may finance the deal and Indian lawyers may draft it, but the trust deed, trustee, security agent, or facility agent is usually an established institution based in London, Hong Kong, or Singapore. This pattern is evident in major transactions, such as Adani Green Energy's $362.5 million bond programme in 2019 where Citicorp International (Hong Kong) was appointed note trustee, and ReNew Power's $450 million senior secured notes in 2020 where HSBC Bank USA served as trustee. The issue persists even when the commercial substance is Indian, as seen in ReNew Power's $450 million senior secured notes due in 2027 where HSBC Bank USA, National Association was appointed trustee despite the borrowers, solar assets, and cash flows being in India.
Building global trustee credibility requires meeting stringent international standards that extend beyond regulatory compliance. According to the analysis, cross-border legal recognition must be enforced across different jurisdictions, with insolvency and enforcement rules differing across jurisdictions. The report emphasizes that independence will be scrutinized, as financial groups may lend, hold accounts, provide escrow services and act as trustee in the same transaction. International parties expect conflicts to be managed to standards they already recognize, requiring repeated acceptance by arrangers, investors, law firms, and regulators built over decades. The value of trusteeship becomes apparent only when things go wrong, such as covenant breaches, lender disputes, or disputed escrow conditions, making it crucial for global financial centres to build focused businesses around bond and security trusteeship.
The GIFT IFSC framework offers India an international financial jurisdiction where cross-border banking, funds, capital markets and leasing can be developed under a unified regulator. As reported by Essential Business Intelligence, the IFSC currently has 35 banks with combined assets exceeding $100 billion, and companies have raised more than $65 billion through bond issuances. The framework also recognises trusteeship and facility-agent functions, providing a foundation for building global trustee capabilities. However, competence in domestic markets does not guarantee international acceptance, as overseas investors will question whether the trustee's authority is recognized in each jurisdiction, whether security can be enforced, and whether the institution has adequate capital, insurance and operational durability.
The report suggests a piecemeal approach to building global trustee capabilities, starting with sectors like aircraft leasing and foreign-currency bonds. According to the analysis, digital bonds and tokenised assets make this more urgent, as technology does not determine who represents investors after a default or acts when digital records and legal rights change. The strategy involves selected mandates that let a GIFT-based trustee work together with established international participants to build a track record and establish credibility in global markets. An Indian trustee appointed where neither the borrower, the asset nor the investors are Indian would represent something more significant - India would be exporting trust rather than simply bringing trusteeship home.
