SEBI PMS Regulations, 2026: FAQs

On 1 April 2027 (Regulation 1(2)). The 2020 Regulations are repealed from that date (Regulation 46(1)). Until then, the 2020 Regulations continue to apply.

No fresh registration is required by the 2026 Regulations: registrations granted under the 2020 Regulations are treated as granted under the corresponding provisions of the 2026 Regulations (Regulation 46(2)). Some new requirements give existing portfolio managers time to comply, such as twelve months for the liquid-asset requirement.

At least ₹5 crore, with at least 10% of that minimum kept 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 (Regulation 31).

₹50 lakh per client (Regulation 16(3)). It does not apply to an accredited investor, subject to disclosures in the Disclosure Document and the agreed terms (Regulation 16(4)). For PRIM, the minimum is ₹25 lakh (Regulation 33(1)).

The Portfolio Management Service Route for Investment in Mutual Fund units, set out in Chapter VI. PRIM portfolios can be invested only in direct plans of mutual funds in India, including index funds, ETFs and specialized investment funds (Regulation 32).

An accredited investor who has entered into an agreement with the portfolio manager for a minimum investment amount of ₹10 crore (Regulation 2(1)). The Third Schedule contents of the agreement do not apply to them (Regulation 15(1)(b)), and up to 100% of their AUM may go into unlisted securities, with disclosures (Regulation 17).

A non-refundable application fee of ₹1 lakh, a registration fee of ₹10 lakh and a renewal fee of ₹5 lakh for every three years (First Schedule). The registration fee is paid within thirty calendar days of SEBI's intimation (Regulation 3(6)).

Within three months before the expiry of the three-year block for which fees have been paid (Regulation 7(1)).

Not later than twenty-one calendar days from the date of receipt (Regulations 6(3) and 16(14)).

As agreed in the contract, but at intervals not exceeding three months, and whenever the client asks (Regulation 24(1)).

It sets out, among other things, the fees for each activity. It is given to the client before the agreement, certified by an independent chartered accountant, updated every year within six months of the year end, and filed with SEBI (Regulation 15(2)).

Yes, for the securities it manages or administers, unless it provides only advisory services (Regulation 19).

It cannot borrow funds or securities on behalf of a client, and cannot lend clients' securities to a third person except as the Regulations provide (Regulation 16(12), (13)). Client funds cannot be used for bill discounting, badla financing or lending to corporate or non-corporate bodies (Regulation 17(2)).

A graduate (or CFA charterholder, chartered accountant and others listed) with at least five years in related securities-market activities, of which at least two years are in portfolio management, investment advisory or fund management (Regulation 4(b)).

At least five years (Regulation 22).

It manages co-investments alongside the Category I and II AIFs it manages, investing 100% of its AUM in unlisted securities of the same investee companies, on terms no more favourable than the AIF's and with identical exit terms (Regulation 12).