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In force from 1 April 2027. The SEBI (Portfolio Managers) Regulations, 2026 were notified on 7 October 2026 and replace the 2020 Regulations from 1 April 2027. Until then, the 2020 Regulations apply.

REGULATION 16 · Chapter V · General obligations and responsibilities of portfolio managers

General responsibilities of a Portfolio Manager

SEBI (Portfolio Managers) Regulations, 2026 · notified 7 October 2026 · in force from 1 April 2027

In plain English

Core duties: a discretionary manager manages each client's funds individually (not like a mutual fund); the minimum is ₹50 lakh per client, which does not apply to accredited investors (with disclosures); a renewal on maturity counts as a fresh investment; act as a fiduciary; keep each client's securities in separate accounts and all client funds in a separate account with a scheduled commercial bank; never borrow on a client's behalf; and redress grievances within twenty-one calendar days.

This note explains the provision; the notified text below is the law.

Key numbers in this regulation

  • Minimum investment per client — PMS₹50 lakh (not for accredited investors, with disclosures)
  • Investor grievancesWithin twenty-one calendar days of receipt

Regulation 16 as notified

(1) The discretionary portfolio manager shall individually and independently manage the funds of each client according to the needs of the client, in a manner which does not partake character of a Mutual Fund, whereas the non–discretionary portfolio manager shall manage the funds in accordance with the directions of the client. (2) The portfolio manager shall not carry out its investment management operations or execution of transactions relating to portfolio management services, outside the territory of India, except for execution of trades for investment in foreign securities. (3) The portfolio manager shall not accept funds or securities or a combination thereof worth less than fifty lakh rupees per client. (4) The requirement of minimum investment amount per client specified in sub–regulation (3), shall not apply to an accredited investor, subject to appropriate disclosures in the Disclosure Documents and the terms agreed between the client and the portfolio manager. (5) The portfolio manager shall ensure that all existing investments of clients made prior to the date of notification of the Securities and Exchange Board of India (Portfolio Managers) Regulations, 2020, comply with minimum investment amount as specified in sub–regulation (3) within twelve months from commencement of these regulation. (6) Any renewal of portfolio on maturity of the initial period of agreement shall be deemed as a fresh investment. (7) The portfolio manager shall act in a fiduciary capacity with regard to the client's funds. (8) The portfolio manager shall segregate each client’s holding in securities in separate accounts. (9) The portfolio manager shall keep the funds of all clients in a separate account to be maintained by it in a Scheduled Commercial Bank. (10) The portfolio manager shall transact in securities within the limitation placed by the client with regard to dealing in securities under the provisions of the Reserve Bank of India Act, 1934 (2 of 1934). (11) The portfolio manager shall not derive any undue benefit, directly or indirectly, out of the client's funds or securities. (12) The portfolio manager shall not borrow funds or securities on behalf of the client. (13) The portfolio manager shall not lend securities held on behalf of the clients to a third person except as provided under these regulations. (14) The Portfolio Manager shall redress investor grievances promptly but not later than twenty–one calendar days from the date of receipt of the grievance and in such manner as may be specified by the Board from time to time. (15) The portfolio manager shall ensure that any person or entity involved in the distribution of its services is carrying out the distribution activities in compliance with these regulations and circulars issued thereunder from time to time. (16) The portfolio manager shall ensure compliance wi th the Investor Charter specified by the Board from time to time. (17) The portfolio manager shall carry out valuation of investment in securities in client’s portfolio in accordance with investment valuation norms as specified by the Board from time to time. (18) The portfolio manager shall ensure conformity with the advertisement code as specified by the Board from time to time. (19) The portfolio manager shall report its performance uniformly in the disclosures to the Board, marketing materials, reports to the clients and on its website. (20) The portfolio manager shall comply with the performance benchmarking framework as specified by the Board from time to time. (21) The portfolio manager shall put in place a written down policy for management of clients funds and securities i n compliance with these regulations and circulars issued thereunder from time to time. (22) The portfolio manager shall have a code of conduct as envisaged under the S ecurities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015. (23) The portfolio manager shall comply with a ny other responsibility as specified by the Board from time to time.

English text of the Gazette notification. Read with any circulars SEBI issues under these Regulations.

The plain-English note is a learning aid. The notified text is the law; check later SEBI circulars.

Prashant Kumar

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CS Prashant Kumar

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Global Horizons Capital Advisors (IFSC) Private Limited — an IFSCA-licensed investment banker

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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.