FME Regulatory Intelligence, Learning & Practice · IFSCA (Fund Management) Regulations, 2025

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People and entities

Who is responsible for what?

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1 · In one sentence

A company registered with SEBI that manages or advises on a client's own portfolio of securities, under a contract with that client.

2 · Think of it like thisLike a personal driver for your own car: the car stays yours, the driver takes it where it needs to go.

4 · A real-world example

A company registered as a portfolio manager runs a ₹1 crore equity portfolio held in the client's own demat account.

5 · Why it matters

Nothing is pooled. Each client's securities stay in that client's name, so the rules focus on contracts, disclosure and keeping assets separate.

6 · Don't confuse it with

A mutual fund or AIF pools many investors' money in one fund; a portfolio manager manages each client's portfolio separately.

7 · Regulatory meaning

Reg 2(1), SEBI (Portfolio Managers) Regulations, 2026 (in force from 1 April 2027): a body corporate which, under a contract with a client, advises, directs or undertakes on behalf of the client (as a discretionary portfolio manager or otherwise) the management or administration of the client's portfolio.

8 · Explain it to someone else

Remember it this way: Portfolio manager = your money, your account, their management.

Plain-English explanations to aid understanding. Regulatory points cite their source; general finance concepts are explained as commonly used. Not legal or tax advice.

Prashant Kumar

Meet the expert

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.