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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 23 · Chapter V · General obligations and responsibilities of portfolio managers

Accounts and audit

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

In plain English

The portfolio manager's books are audited every year by a qualified auditor. Client portfolio accounts are audited every year by an independent chartered accountant, and the client gets a copy of the certificate. A client may also appoint its own chartered accountant to audit its transactions.

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

Regulation 23 as notified

(1) The portfolio manager shall maintain separate client–wise accounts. (2) The funds received from the clients, investments or disinvestments, all the credits to the account of the client like interest, dividend, bonus, or any other beneficial interest received on the investment and debits for expenses, if any, shall be properly accoun ted for and details thereof shall be properly reflected in the client's account. (3) The tax deducted at source as required under the provisions of the Income–Tax Act, 2025 (30 of 2025) shall be recorded in the portfolio account. (4) The books of account will be a udited yearly by qualified auditor to ensure that the portfolio manager has followed proper accounting methods and procedures and that the portfolio manager has performed his duties in accordance with the law and a certificate to this effect shall, if so specified, be submitted to the Board within six months of close of portfolio manager's accounting period. Explanation: For the purpose of this regulation, the expression “qualified auditor” shall have the same meaning as given to it under section 141 of the Companies Act, 2013 (18 of 2013). (5) The portfolio accounts of the portfolio manager shall be audited annually by an independent chartered accountant and a copy of the certificate issued by the chartered accountant shall be given to the client. (6) The client may appoint a chartered accountant to audit the books and accounts of the portfolio manager relating to his transactions and the portfolio manager shall co–operate with such chartered accountant in course of the audit.

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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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.