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What is PRIM? SEBI's new PMS route for mutual fund investing

PRIM lets a portfolio manager build a personal portfolio of direct-plan mutual funds for a client, with a ₹25 lakh minimum and a lighter net worth rule. Here is how it works.

SEBI PMS

CS Prashant Kumar14 Oct 2026 · 2 min read

Short answer: PRIM is the Portfolio Management Service Route for Investment in Mutual Fund units, set out in Chapter VI of the SEBI (Portfolio Managers) Regulations, 2026. A portfolio manager under PRIM invests a client's money only in direct plans of mutual funds. The client minimum is ₹25 lakh. It applies from 1 April 2027.

What can a PRIM portfolio invest in?

Only direct plans of mutual funds in India, including index funds, exchange traded funds and specialized investment funds (Regulation 32). Shares, bonds and other securities directly are outside PRIM.

How much does a client need to invest?

At least ₹25 lakh per client (Regulation 33(1)). The general ₹50 lakh PMS minimum in Regulation 16(3) does not apply to PRIM (Regulation 29). As with PMS, a renewal on maturity of the initial period counts as a fresh investment.

Who can offer PRIM?

A new applicant can apply for registration to provide PRIM. An existing portfolio manager may offer PRIM under segregated investment approaches, on conditions SEBI specifies (Regulation 30).

What does a PRIM-only portfolio manager need?

Infrastructure, a principal officer and a compliance officer, and net worth of at least ₹2 crore at all times, kept separate from capital needed for its other businesses, with at least 10% of that minimum in unencumbered liquid assets (Regulation 31). That compares with ₹5 crore for a regular portfolio manager (Regulation 4).

How is PRIM different from investing in mutual funds yourself?

The client still owns the mutual fund units, but a registered portfolio manager chooses and manages the mix under an agreement, with the client protections of the Regulations: segregated holdings, a separate bank account, reports at least every three months and grievance redress within twenty-one calendar days.

Example: a client with ₹30 lakh is below the ₹50 lakh PMS minimum but can use PRIM. The portfolio manager builds a mix of direct-plan equity funds, debt funds and index funds and reports to the client every quarter.

Quick answers

  • What PRIM stands for: Portfolio Management Service Route for Investment in Mutual Fund units.
  • Investments: direct plans of mutual funds only.
  • Client minimum: ₹25 lakh.
  • Net worth (PRIM-only): ₹2 crore at all times.
  • Where: Chapter VI, Regulations 29 to 34.

Read the full plain-English guide in Understand SEBI PMS.

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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.