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PMS minimum investment, net worth and fees under the 2026 Regulations

How much a client must invest in PMS and PRIM, who is exempt, how much net worth a portfolio manager needs, and what SEBI charges, with worked examples.

SEBI PMS

CS Prashant Kumar14 Oct 2026 · 2 min read

Short answer: under the SEBI (Portfolio Managers) Regulations, 2026, a PMS client must invest at least ₹50 lakh, accredited investors are exempt, PRIM needs ₹25 lakh, and a portfolio manager needs net worth of at least ₹5 crore with at least ₹50 lakh of it in liquid assets. The Regulations apply from 1 April 2027.

What is the minimum investment for PMS?

₹50 lakh per client (Regulation 16(3)). The minimum does not apply to an accredited investor, subject to disclosures in the Disclosure Document and the terms agreed with the portfolio manager (Regulation 16(4)). When the initial period ends and the portfolio is renewed, the renewal counts as a fresh investment (Regulation 16(6)), so the minimum applies again.

Is the minimum lower for PRIM?

Yes. PRIM, the PMS route for investing in mutual fund units, has a minimum of ₹25 lakh per client (Regulation 33(1)). PRIM portfolios can be invested only in direct plans of mutual funds in India, including index funds, ETFs and specialized investment funds (Regulation 32).

Who is a large value accredited investor?

An accredited investor whose agreement with the portfolio manager is for at least ₹10 crore (Regulation 2(1)). For them, the Third Schedule contents of the agreement do not apply (Regulation 15(1)(b)), and up to 100% of their assets under management may be invested in unlisted securities, with appropriate disclosures (Regulation 17).

How much net worth does a portfolio manager need?

At least ₹5 crore, with at least 10% of that minimum — ₹50 lakh — in unencumbered liquid assets such as cash, bank deposits with scheduled commercial banks, money market instruments and government securities (Regulation 4(a)(iv)). A portfolio manager offering only PRIM needs at least ₹2 crore at all times (Regulation 31). Existing portfolio managers have twelve months to meet the liquid-asset requirement.

Example: a company with ₹6 crore net worth but only ₹30 lakh in liquid assets meets the net worth figure but not the liquid-asset test, which needs ₹50 lakh.

What fees does SEBI charge a portfolio manager?

  • Application fee: ₹1 lakh, non-refundable.
  • Registration fee: ₹10 lakh, paid within thirty calendar days of SEBI's intimation (Regulation 3(6)).
  • Renewal fee: ₹5 lakh for every block of three years, paid within three months before the block ends (Regulation 7(1)).

Over six years, that is ₹1 lakh + ₹10 lakh + one renewal of ₹5 lakh = ₹16 lakh (First Schedule).

Quick answers

  • Minimum for PMS: ₹50 lakh per client.
  • Minimum for PRIM: ₹25 lakh per client.
  • Accredited investors: exempt from the ₹50 lakh minimum, with disclosures.
  • Net worth: ₹5 crore (₹2 crore for PRIM-only), 10% of the minimum in liquid assets.
  • In force: 1 April 2027.

Check a client's amount with the minimum investment checker, or a firm's numbers with the net worth calculator.

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This is a learning and compliance-preparation tool. Plain-English readings, practical notes, 'what changed' summaries, the timeline and calculators are the portal's interpretation and do not replace professional advice or the notified Gazette text of the IFSCA (Fund Management) Regulations, 2025 and its amendments.

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CS Prashant Kumar

Company Secretary & Compliance Officer
Global Horizons Capital Advisors (IFSC) Private Limited — an IFSCA-licensed investment banker

13+ years of experienceFCS Fellow member, ICSIAuthor Audit Under Fire

Published in The Chartered Accountant (Jun 2025, Jan 2025, Mar 2024) and Chartered Secretary (Aug 2023)

Prashant Kumar is a seasoned Company Secretary and corporate governance strategist with more than 13 years of experience advising large corporates, promoter-led groups and global businesses on compliance, regulatory risk and board governance. In GIFT IFSC, the IFSCA regime is his day job rather than a research topic.