PMS Registration in India: Quick Overview
Regulator
Securities and Exchange Board of India
Applicable Regulation
SEBI Portfolio Managers Regulations, 2020, as amended from time to time
Latest Official Position Checked
SEBI listing shows Portfolio Managers Regulations last amended on September 03, 2025; Portfolio Managers Master Circular dated July 16, 2025; PMS business transfer circular dated October 24, 2025.
Registration Type
Portfolio Manager Registration
Eligible Applicant
Body corporate such as Company or LLP, subject to eligibility
Individual Applicant
Not eligible
Proprietorship / Partnership Firm
Not eligible, unless structured as eligible body corporate / LLP
Minimum Net Worth
Rs. 5 Crore
Minimum Client Investment
Rs. 50 Lakh per client, subject to applicable exceptions
PMS Models
Discretionary, Non-Discretionary and Advisory Portfolio Management
Application Form
Form A under Schedule I
Certificate
Form B after SEBI approval
Principal Officer
Professional qualification, 5 years securities market experience, 2 years relevant PMS / advisory / fund management experience and valid NISM certification
Additional Employee
At least one additional employee with graduation and 2 years securities market experience
Compliance Officer
Mandatory and separate from Principal Officer
Custodian
Mandatory appointment
Validity
Valid unless suspended or cancelled, subject to ongoing compliance and fee payment
Indicative Timeline
4 to 8 months, depending on documentation and SEBI review
The above details are indicative and must be evaluated based on the applicant’s legal structure, net worth readiness, Principal Officer eligibility, NISM certification, team capability, compliance framework, custodian arrangement, business model, client profile and latest SEBI regulations / circulars at the time of filing.
What is PMS Registration in India?
PMS Registration in India is the approval granted by SEBI to a body corporate for acting as a Portfolio Manager. A Portfolio Manager manages or administers a client’s portfolio of securities, funds or permitted instruments under a written agreement.
Portfolio Management Services are different from simple investment advisory. PMS involves a higher degree of fiduciary responsibility because the portfolio manager may manage client funds or securities directly, depending on whether the model is discretionary, non-discretionary or advisory.
No person should act as a Portfolio Manager or hold itself out as a PMS provider without obtaining SEBI registration. Unregistered portfolio management activity may attract regulatory action.
Legal Background of PMS Registration in India
| Particular | Details |
|---|---|
| Regulator | Securities and Exchange Board of India |
| Primary Regulation | SEBI Portfolio Managers Regulations, 2020, as amended from time to time |
| Applicable Law | SEBI Act, 1992 |
| Intermediary Framework | SEBI Intermediaries Regulations, 2008 |
| Application Form | Form A under Schedule I |
| Certificate | Form B after SEBI approval |
| Registration Requirement | Mandatory before acting as Portfolio Manager |
| Core Regulatory Focus | Net worth, qualification, governance, client protection, disclosures, custodian, reporting, audit and inspection |
SEBI regulates eligibility, conduct, client agreements, disclosures, reporting, fees, audits, custodian arrangements, grievance redressal, inspection, suspension and cancellation of portfolio managers.
What is a Portfolio Manager under SEBI Regulations?
A Portfolio Manager is a body corporate that manages or administers a portfolio of securities or funds on behalf of clients under a written agreement. The portfolio manager may provide discretionary, non-discretionary or advisory services depending on the client mandate and registration scope.
Manages client-wise portfolios
Core PMS obligation to be built into client documentation, systems and internal controls.
Acts under written agreement
Core PMS obligation to be built into client documentation, systems and internal controls.
Maintains client-level segregation
Core PMS obligation to be built into client documentation, systems and internal controls.
Provides portfolio reporting
Core PMS obligation to be built into client documentation, systems and internal controls.
Follows investment restrictions
Core PMS obligation to be built into client documentation, systems and internal controls.
Cannot guarantee returns
Core PMS obligation to be built into client documentation, systems and internal controls.
Must appoint custodian
Core PMS obligation to be built into client documentation, systems and internal controls.
Must maintain compliance records
Core PMS obligation to be built into client documentation, systems and internal controls.
PMS is not a pooled investment vehicle. Each client portfolio must be managed separately.
PMS vs Investment Adviser vs AIF vs Mutual Fund
| Parameter | PMS | Investment Adviser | AIF | Mutual Fund |
|---|---|---|---|---|
| Regulator | SEBI | SEBI | SEBI | SEBI |
| Structure | Client-wise portfolio management | Advice-only model | Privately pooled fund | Public pooled investment product |
| Client Funds Handling | Yes, depending on PMS model | No direct fund management | Yes, pooled fund | Yes, pooled fund |
| Minimum Investment | Rs. 50 Lakh generally | Not same as PMS | Rs. 1 Crore generally | Retail accessible |
| Portfolio Customisation | High | Advisory only | Scheme-level | Scheme-level |
| Registration | Portfolio Manager | Investment Adviser | AIF | Mutual Fund |
| Suitable For | HNI / UHNI customised portfolios | Advice-only business | Fund sponsors | Retail and institutional pooled investment |
PMS Registration in India is suitable when the promoter intends to manage client portfolios, not merely provide investment advice.
Types of Portfolio Management Services
| Type | Meaning | Client Decision Role |
|---|---|---|
| Discretionary PMS | Portfolio Manager takes investment decisions within agreed mandate | Limited day-to-day role |
| Non-Discretionary PMS | Portfolio Manager advises and executes based on client approval | Client approves decisions |
| Advisory PMS | Portfolio Manager provides portfolio advice, but execution remains with client | Client executes |
The business model should be clearly reflected in Form A, client agreement, disclosure document and operating SOPs.
Who Needs PMS Registration in India?
Wealth Management Firms
Entities planning to manage customised portfolios for HNI or UHNI clients.
Family Office Platforms
Groups managing securities portfolios for high-value families and institutional clients.
Investment Professionals
Experienced professionals transitioning from advisory to discretionary portfolio management.
Fintech Wealth Platforms
Digital platforms intending to manage client portfolios under SEBI-regulated PMS structure.
Asset Management Groups
Entities building a client-wise portfolio management vertical.
Institutional Investment Platforms
Firms offering structured portfolio strategies to sophisticated investors.
Who Cannot Apply for PMS Registration in India?
| Applicant / Situation | Regulatory Concern |
|---|---|
| Individual | Not eligible |
| Proprietorship firm | Not eligible |
| Non-LLP partnership firm | Not eligible |
| Entity below Rs. 5 Crore net worth | Fails eligibility |
| Entity without qualified Principal Officer | Application deficiency |
| Entity without independent Compliance Officer | Governance concern |
| Entity without additional qualified employee | Eligibility gap |
| Entity with adverse securities market history | Fit and proper concern |
| Entity intending to pool funds like AIF | Wrong regulatory route |
| Entity proposing guaranteed returns | Not permitted |
Eligibility Criteria for PMS Registration in India
| Eligibility Parameter | Regulatory Expectation |
|---|---|
| Legal Structure | Body corporate such as Company or LLP |
| Net Worth | Minimum Rs. 5 Crore |
| Principal Officer | Professional qualification, experience and NISM certification |
| Additional Employee | At least one employee with graduation and relevant experience |
| Compliance Officer | Mandatory and separate from Principal Officer |
| Fit and Proper | Applicant, directors, partners, principal officer and key persons must qualify |
| Infrastructure | Adequate office, IT systems, staff and record maintenance capability |
| Business Plan | Practical AUM, revenue, cost and compliance plan |
| Custodian | Mandatory appointment |
| Client Agreement | Written agreement with every client |
| Disclosure Document | Required and to be updated on material changes |
Net Worth Requirement for PMS Registration in India
The minimum net worth requirement for PMS Registration in India is Rs. 5 Crore. Net worth must be maintained continuously and cannot be treated as a one-time application-stage requirement.
Net Worth = Paid-up Equity Capital + Free Reserves - Accumulated Losses - Deferred Expenditure - Miscellaneous Expenses Not Written Off
| Component | Treatment |
|---|---|
| Paid-up Equity Capital | Included |
| Free Reserves | Included |
| Revaluation Reserves | Excluded |
| Accumulated Losses | Deducted |
| Deferred Expenditure | Deducted |
| Miscellaneous Expenses Not Written Off | Deducted |
| Borrowed Funds | Not a substitute for net worth |
Net worth should be certified by a Chartered Accountant and supported by financial statements, capital infusion records and bank documentation.
Minimum Client Investment under PMS Registration in India
| Particular | Requirement |
|---|---|
| Minimum Investment per Client | Rs. 50 Lakh |
| Investment Mode | Funds or securities or combination as permitted |
| Client Agreement | Mandatory |
| Portfolio Segregation | Client-wise segregation required |
| Accredited Investor Exception | May be available subject to applicable framework and disclosures |
PMS is designed for sophisticated investors. It should not be positioned as a retail mass-market investment product.
Principal Officer Requirement for PMS Registration in India
The Principal Officer is responsible for decisions relating to management of client funds and securities, administration of client portfolios and other PMS operations.
- Professional qualification in finance, law, accountancy or business management; or NISM postgraduate programme; or CFA Charter
- Minimum 5 years’ experience in securities market
- At least 2 years’ experience in portfolio management / investment advisory / fund management
- Valid NISM certification
- Fit and proper status
- Responsible for portfolio management decisions
- Should not be the same person as Compliance Officer
SEBI may seek detailed experience mapping, employment documents and role descriptions to verify Principal Officer eligibility.
Compliance Officer and Additional Employee Requirement
| Role | Requirement | Practical Importance |
|---|---|---|
| Compliance Officer | Mandatory and separate from Principal Officer | Monitors regulatory compliance |
| Additional Employee | Graduation and 2 years securities market experience | Supports portfolio operations |
| Principal Officer | Experience and certification as prescribed | Responsible for portfolio decisions |
| Board / Partners | Governance oversight | Ensures institutional control |
Do not combine Principal Officer and Compliance Officer roles. Role separation improves governance credibility.
Infrastructure and Governance Requirement for PMS Registration in India
Adequate office premises
Operational capability expected for PMS application, launch and inspection readiness.
IT systems and portfolio management tools
Operational capability expected for PMS application, launch and inspection readiness.
Client-wise record maintenance
Operational capability expected for PMS application, launch and inspection readiness.
Secure data storage
Operational capability expected for PMS application, launch and inspection readiness.
Custodian coordination process
Operational capability expected for PMS application, launch and inspection readiness.
Trade execution control
Operational capability expected for PMS application, launch and inspection readiness.
Compliance monitoring dashboard
Operational capability expected for PMS application, launch and inspection readiness.
Grievance redressal mechanism
Operational capability expected for PMS application, launch and inspection readiness.
Risk management policy
Operational capability expected for PMS application, launch and inspection readiness.
Internal audit framework
Operational capability expected for PMS application, launch and inspection readiness.
Suggested Governance Structure
1
Board of Directors / Designated Partners
2
Principal Officer
3
Investment Team
4
Compliance Officer
5
Operations Team
6
Custodian / Auditor / Back Office
Business Plan Requirement for PMS Registration in India
SEBI examines whether the applicant has a sustainable PMS business model. A weak business plan may result in queries.
| Business Plan Component | What It Should Cover |
|---|---|
| Projected AUM | 3-year AUM growth plan |
| Revenue Model | Fixed fee, performance fee or combination |
| Expense Structure | Staff, systems, compliance, custodian, audit and technology costs |
| Client Acquisition Strategy | HNI / UHNI / family office pipeline |
| Capital Sustainability | Ability to maintain Rs. 5 Crore net worth |
| Compliance Budget | Reporting, audit, regulatory filings and legal support |
| Risk Controls | Investment risk, concentration risk and grievance risk |
| Technology Plan | PMS software, reporting tools and data security |
| Particular | Year 1 | Year 2 | Year 3 |
|---|---|---|---|
| Projected AUM | Rs. 75 Cr | Rs. 150 Cr | Rs. 300 Cr |
| Average Fee | 2% | 2% | 2% |
| Gross Revenue | Rs. 1.5 Cr | Rs. 3 Cr | Rs. 6 Cr |
| Employee Cost | Rs. 60 L | Rs. 90 L | Rs. 1.2 Cr |
| Compliance Cost | Rs. 20 L | Rs. 25 L | Rs. 35 L |
| Custodian Charges | Rs. 10 L | Rs. 20 L | Rs. 40 L |
| Net Profit Estimate | Rs. 40 L | Rs. 1.2 Cr | Rs. 3 Cr |
The financial model is illustrative. Actual projections should match the promoter’s real business pipeline and cost assumptions.
Documents Required for PMS Registration in India
| Document Category | Key Documents |
|---|---|
| Application Documents | Form A, application fee proof and SEBI-prescribed declarations |
| Constitutional Documents | Certificate of incorporation / LLP registration, MOA, AOA / LLP agreement and PAN |
| Corporate Approvals | Board resolution / partner resolution approving PMS application |
| Financial Documents | CA-certified net worth certificate, audited financial statements, capital proof and bank statements |
| Principal Officer Documents | Qualification proof, work experience evidence, NISM certificate and appointment documents |
| Compliance Officer Documents | Qualification, experience and appointment documents |
| Additional Employee Documents | Graduation certificate, experience documents and appointment proof |
| Infrastructure Documents | Office proof, IT systems note, record maintenance capability and operational readiness details |
| Business Plan | 3-year AUM projection, revenue model, cost structure and compliance plan |
| Fit and Proper Documents | Declarations for directors, partners, principal officer and key persons |
| Policy Documents | Risk policy, investment policy, grievance SOP, related party policy, insider trading / confidentiality policy |
| Custodian Documents | Proposed custodian arrangement / appointment details |
| Application Annexures | Any SEBI-prescribed supporting forms and undertakings |
Step-by-Step Process for PMS Registration in India
Step 1
Entity Structuring and Eligibility Review
Review whether the applicant is an eligible body corporate and whether its objects permit portfolio management services.
Step 2
Capital Infusion and Net Worth Readiness
Arrange and document minimum Rs. 5 Crore net worth and obtain CA certification.
Step 3
Principal Officer and Team Appointment
Appoint qualified Principal Officer, Compliance Officer and additional employee.
Step 4
NISM Certification Completion
Ensure Principal Officer and other relevant persons hold valid certification as required.
Step 5
Policy and Infrastructure Preparation
Prepare PMS policies, IT systems, record maintenance process, grievance mechanism and governance controls.
Step 6
Form A Filing
Submit Form A through the SEBI Intermediaries Portal with required documents and application fee.
Step 7
SEBI Scrutiny
SEBI reviews net worth, Principal Officer eligibility, team strength, infrastructure, business plan and fit and proper status.
Step 8
Clarification and Query Response
Respond to SEBI queries with proper documents, explanations and revised submissions wherever required.
Step 9
Personal Representation
SEBI may call the applicant or Principal Officer for interaction, if required.
Step 10
In-Principle Approval
SEBI may issue in-principle approval subject to fulfilment of conditions.
Step 11
Registration Fee Payment
Pay registration fee within prescribed timeline after SEBI intimation.
Step 12
Certificate in Form B
SEBI grants certificate of registration in Form B.
Government Fees for PMS Registration in India
| Fee Type | Amount / Position |
|---|---|
| Application Fee | Rs. 1,00,000 |
| Registration Fee | Rs. 10,00,000 |
| Block / Continuation Fee | Rs. 5,00,000 every 3 years |
| Payment Timeline | Registration fee generally payable within 15 days of SEBI intimation |
| Payment Mode | SEBI payment gateway / prescribed SEBI mode |
Fees should be verified from the latest SEBI Portfolio Managers Regulations, Schedule II and SEBI portal instructions before filing or hardcoding in reusable website data.
Timeline for PMS Registration in India
| Stage | Indicative Timeline |
|---|---|
| Entity and eligibility review | 1 to 2 weeks |
| Capital and net worth readiness | Case-specific |
| Documentation and policy preparation | 3 to 6 weeks |
| Form A filing | Case-specific |
| Initial SEBI review | 30 to 45 days or more |
| Query and clarification rounds | 30 to 60 days or more |
| Personal representation | Case-specific |
| Overall timeline | 4 to 8 months, depending on query cycle |
Timeline is indicative and depends on documentation quality, net worth readiness, Principal Officer eligibility, certification status, SEBI scrutiny and query response.
Form A Field-Wise Explanation for PMS Registration in India
| Form A Section | What SEBI Expects Practically |
|---|---|
| Applicant Details | Exact legal name, CIN / LLPIN and registered address |
| Shareholding Pattern | Clear ownership and control structure |
| Directors / Partners | KYC, DIN / DPIN, background and fit and proper disclosures |
| Principal Officer | Qualification, experience, NISM certification and appointment details |
| Compliance Officer | Qualification, experience and independence from Principal Officer |
| Infrastructure | Office, IT systems and record maintenance capability |
| Net Worth | CA-certified computation with break-up |
| Business Plan | AUM strategy, revenue model and compliance cost |
| Litigation Disclosure | Full transparency of securities market matters |
| Fit and Proper Declaration | Confirmation under SEBI Intermediaries framework |
Incomplete Form A or weak supporting evidence may lead to multiple query rounds.
Activities After PMS Registration in India
- Execute client agreements
- Issue disclosure document
- Appoint custodian
- Create client-wise portfolio records
- Define investment mandates
- Open client accounts as required
- Set up reporting system
- Establish grievance redressal mechanism
- Create audit and compliance calendar
- Maintain portfolio-wise investment restrictions
- Track material changes in disclosure document
- Maintain SEBI correspondence file
Post-Registration Compliance for Portfolio Managers
| Compliance Area | Requirement |
|---|---|
| Client Agreement | Mandatory written agreement |
| Disclosure Document | Required before onboarding clients |
| Quarterly Reporting | Client reports every 3 months |
| Annual Audit | Within prescribed timeline after financial year close |
| Net Worth Maintenance | Rs. 5 Crore continuously |
| Custodian Appointment | Mandatory |
| Grievance Redressal | Within prescribed timeline |
| Disclosure Update | Material changes to be updated within prescribed timeline |
| Books and Records | Maintain client-wise records |
| Investment Restrictions | No guarantee of returns, no unauthorised leverage, no prohibited related party exposure |
| Regulatory Filings | As specified by SEBI |
| Business Transfer | Prior SEBI approval where applicable |
PMS Registration in India - Compliance Calendar
Continuous Compliance
| Compliance Item | Frequency | Responsibility | Risk if Missed |
|---|---|---|---|
| Maintain Rs. 5 Crore Net Worth | Continuous | CFO / Board | Suspension / regulatory action |
| Client-wise Segregation | Continuous | Operations Team | Inspection concern |
| Investment Restrictions | Continuous | Investment Team | SEBI action |
| Custodian Coordination | Continuous | Operations / Compliance | Operational risk |
| Grievance Tracking | Continuous | Compliance Officer | Regulatory breach |
| Disclosure Accuracy | Continuous | Principal Officer / Compliance | Investor protection issue |
Monthly Compliance
| Compliance Item | Purpose | Responsible Person |
|---|---|---|
| Portfolio Restriction Review | Check investment limits and prohibited exposures | Investment Team |
| Grievance Review | Track pending complaints | Compliance Officer |
| Net Worth Monitoring | Check capital erosion risk | CFO |
| Client Reporting Data Review | Prepare quarterly reporting inputs | Operations Team |
Quarterly Compliance
| Compliance Item | Requirement | Responsible Person |
|---|---|---|
| Quarterly Client Report | Every 3 months | Portfolio Manager |
| Risk Review | Portfolio risk and concentration review | Principal Officer |
| Compliance Report | Internal compliance status note | Compliance Officer |
| Board / Management Review | Governance oversight | Board / Partners |
Annual Compliance
| Compliance Item | Requirement |
|---|---|
| Annual Audit | Within prescribed timeline after financial year close |
| Audited Financial Statements | Maintain and submit where applicable |
| Net Worth Certificate | CA-certified net worth statement |
| Policy Review | Investment policy, risk policy, grievance SOP and related party policy |
| Custodian Confirmation | Annual custodian review |
| NISM / Team Certification Review | Track validity and renewals |
Event-Based Compliance
| Trigger Event | Compliance Action |
|---|---|
| Change in Principal Officer | Regulatory intimation / approval as applicable |
| Change in Compliance Officer | Update records and ensure independence |
| Change in Control | Prior SEBI approval required |
| Material Change in Disclosure Document | Update within prescribed timeline |
| Transfer of PMS Business | Prior SEBI approval required |
| Net Worth Shortfall | Immediate corrective action |
| SEBI Inspection Notice | Provide books and records promptly |
| Client Complaint Escalation | Resolve and record closure |
Investment Restrictions under PMS Framework
| Restriction / Requirement | Practical Meaning |
|---|---|
| No Guaranteed Returns | Portfolio Manager cannot guarantee performance |
| No Pooling Like AIF | Client portfolios must remain separately managed |
| No Unauthorised Leverage | Leverage restrictions must be followed |
| No Speculative Transactions | Speculative trades not permitted except permitted derivatives |
| No Unrated Related Party Securities | Restricted as per SEBI framework |
| Prudential Limits | Portfolio mandates and risk limits must be followed |
| Client Mandate Discipline | Investments must align with agreement and disclosure document |
PMS is a fiduciary business. Strategy freedom is subject to client mandate, SEBI restrictions and risk governance.
Custodian, Audit and Reporting Requirements
| Requirement | Practical Position |
|---|---|
| Custodian Appointment | Mandatory |
| Quarterly Client Report | Required every 3 months |
| Annual Audit | Required within prescribed timeline |
| Client-wise Records | Mandatory |
| Portfolio Valuation | As per agreed framework and regulations |
| Disclosure Document | Updated for material changes |
| Regulatory Reporting | As specified by SEBI |
| Audit Trail | Trade and portfolio records must be inspection-ready |
Grievance Redressal for PMS Clients
1
Complaint Received
2
Acknowledgement
3
Investigation
4
Resolution
5
Client Communication
6
Closure Record
7
Compliance Review
- Dedicated grievance officer / compliance contact
- Complaint register
- Resolution timeline tracking
- Escalation matrix
- Client communication record
- SEBI / SCORES tracking where applicable
- Board / management review of complaints
Transfer of PMS Business and Exit Strategy
The uploaded source document refers to SEBI’s October 24, 2025 circular allowing transfer of PMS business with prior approval. The latest official SEBI circular should be verified before hardcoding conditions.
| Scenario | Key Requirement |
|---|---|
| Group Transfer | Prior SEBI approval required; selected or complete transfer may be permitted subject to conditions |
| Non-Group Transfer | Complete business transfer may be required as per applicable framework |
| Completion Timeline | Source document refers to 2 months; verify latest SEBI circular |
| Client Consent | May be required based on transaction structure |
| Surrender | Registration surrender may be required after complete transfer |
Business transfer is a strategic regulatory matter. Do not present PMS transfer as automatic or purely contractual.
SEBI Inspection and Enforcement Powers
SEBI may inspect books, records, client details, investment records, compliance reports, grievance records, custodian arrangements and related party transactions.
| Inspection Area | Documents / Controls to Keep Ready |
|---|---|
| Registration Certificate | Form B and SEBI correspondence |
| Net Worth Records | CA certificate and financial statements |
| Client Agreements | Executed client contracts |
| Disclosure Documents | Latest and historical versions |
| Portfolio Records | Client-wise portfolio statements |
| Trade Records | Order and execution logs |
| Custodian Records | Custodian appointment and confirmations |
| Audit Reports | Annual audit and internal audit records |
| Grievance Register | Complaint records and closure proof |
| Related Party Records | Investment and conflict checks |
| Board / Management Minutes | Governance review records |
Suspension and Cancellation Triggers
| Trigger | Possible Regulatory Consequence |
|---|---|
| Net worth below Rs. 5 Crore | Suspension or corrective action |
| False disclosure | Cancellation risk |
| Non-payment of fees | Suspension risk |
| Failure to redress grievances | Regulatory action |
| Misleading performance claims | Enforcement risk |
| Guaranteeing returns | Serious regulatory concern |
| Client fund misuse | Severe enforcement action |
| Failure to maintain records | Inspection adverse finding |
| Non-cooperation with SEBI inspection | Serious regulatory action |
| Material change not reported | Regulatory breach |
Common Mistakes in PMS Registration in India
| Mistake | Risk |
|---|---|
| Weak Principal Officer experience documentation | SEBI query or delay |
| No valid NISM certification | Eligibility gap |
| Net worth not properly certified | Capital query |
| Treating borrowed funds as capital | Regulatory concern |
| Compliance Officer not independent | Governance issue |
| Poorly drafted business plan | SEBI query |
| Confusing PMS with Investment Adviser | Wrong regulatory positioning |
| No custodian plan | Application weakness |
| No client agreement draft | Operational gap |
| No disclosure document framework | Investor protection concern |
| No grievance SOP | Compliance deficiency |
| Delayed SEBI query response | Approval delay |
Strategic Structuring Recommendations Before Applying
- Select correct PMS model: discretionary, non-discretionary or advisory
- Maintain Rs. 5 Crore net worth with clean documentation
- Appoint qualified Principal Officer early
- Complete NISM certification before filing
- Keep Compliance Officer independent
- Prepare detailed 3-year AUM and revenue model
- Draft client agreement and disclosure document
- Appoint or identify custodian early
- Prepare investment policy and risk framework
- Build client-wise portfolio record system
- Prepare grievance redressal SOP
- Avoid guaranteed return language
- Prepare for SEBI inspection from day one
“In portfolio management, capital is only the entry ticket. What sustains the licence is governance discipline, transparent disclosures and fiduciary responsibility.”CS Devyani Khambhati - Compliance Expert
How Estabizz Helps with PMS Registration in India
PMS Model Assessment
We help evaluate whether the proposed business should operate as discretionary PMS, non-discretionary PMS or advisory PMS.
Entity and Eligibility Review
We review company / LLP structure, object clause, fit and proper criteria, litigation background and regulatory suitability.
Net Worth Documentation
We assist with Rs. 5 Crore net worth planning, CA certificate, capital documentation and financial record alignment.
Principal Officer and Team Documentation
We assist in mapping Principal Officer qualification, experience, NISM certification, Compliance Officer independence and additional employee requirement.
Business Plan and Financial Projections
We prepare 3-year AUM projection, fee model, cost structure, compliance cost and profitability assumptions.
Policy and Governance Documentation
We help draft investment policy, risk management framework, related party policy, grievance SOP, confidentiality policy and internal compliance manual.
Form A Filing and SEBI Query Support
We support Form A preparation, SEBI portal filing coordination, document compilation and structured responses to SEBI clarifications.
Post-Registration Compliance
We support client agreement framework, disclosure document, quarterly reporting, annual audit, custodian coordination, net worth monitoring and compliance calendar.
PMS Business Transfer Advisory
We assist in evaluating regulatory requirements for PMS business transfer, change in control and surrender matters, where applicable.
Ticket-Based Execution
Estabizz follows a structured task-tracking system so clients receive organised updates throughout the engagement.
Why Choose Estabizz for PMS Registration in India?
SEBI Regulatory Expertise
Our team works across SEBI licensing and compliance matters and understands capital market intermediary scrutiny.
Wealth Management Structuring Depth
We understand PMS business models, HNI client structures, AUM projections, custodian coordination and client agreement requirements.
Compliance-First Documentation
We focus on net worth, Principal Officer, Compliance Officer independence, investment restrictions, disclosures and inspection readiness.
Business Plan Strength
We prepare practical, regulator-facing business plans suitable for PMS applicants.
Multi-Regulator Experience
Estabizz’s experience across RBI, SEBI, IRDAI and IFSCA enables a wider financial regulatory perspective.
End-to-End Support
From structuring to SEBI application, query response and post-registration compliance, we provide organised professional handholding.
FAQs on PMS Registration in India
What is PMS Registration in India?
PMS Registration in India is approval granted by SEBI to a body corporate that intends to manage portfolios of securities or funds on behalf of clients under a written agreement.
Who regulates PMS in India?
PMS is regulated by the Securities and Exchange Board of India.
Which regulations govern PMS Registration?
PMS is governed by the SEBI Portfolio Managers Regulations, 2020, as amended from time to time.
Is PMS Registration mandatory?
Yes. No person can act as a Portfolio Manager without obtaining SEBI registration.
What is a Portfolio Manager?
A Portfolio Manager is a body corporate that manages or administers client portfolios on discretionary, non-discretionary or advisory basis.
Is PMS the same as Investment Adviser?
No. Investment Adviser gives advice, while PMS involves managing or administering client portfolios.
Is PMS the same as AIF?
No. PMS manages client-wise portfolios separately, while AIF is a privately pooled investment vehicle.
Is PMS the same as Mutual Fund?
No. PMS is customised client-wise portfolio management, while mutual funds are pooled investment products.
What are the types of PMS?
PMS may be discretionary, non-discretionary or advisory.
What is discretionary PMS?
In discretionary PMS, the portfolio manager takes investment decisions on behalf of the client within the agreed mandate.
What is non-discretionary PMS?
In non-discretionary PMS, the portfolio manager acts based on client instructions or approval.
What is advisory PMS?
Advisory PMS involves portfolio advice, while the client retains execution control.
Who can apply for PMS Registration?
A body corporate such as company or LLP may apply, subject to SEBI eligibility requirements.
Can an individual apply?
No. Individuals cannot obtain PMS Registration.
Can a partnership firm apply?
A non-LLP partnership firm is not eligible. LLP may apply if it meets regulatory conditions.
What is the minimum net worth required?
Minimum net worth required is Rs. 5 Crore.
Is net worth required only at application stage?
No. Net worth must be maintained continuously.
Can borrowed funds be counted as net worth?
No. Borrowed funds should not be treated as regulatory net worth.
What is the minimum client investment?
The minimum investment per client is generally Rs. 50 Lakh, subject to applicable exceptions.
Can PMS accept retail clients below Rs. 50 Lakh?
Generally no, unless a regulatory exception applies.
Is Principal Officer required?
Yes. A qualified and experienced Principal Officer is mandatory.
What experience is required for Principal Officer?
The Principal Officer must have minimum 5 years’ securities market experience, including relevant PMS, advisory or fund management experience.
Is NISM certification required?
Yes. Valid NISM certification is required as applicable.
Is Compliance Officer required?
Yes. A separate Compliance Officer is mandatory.
Can Principal Officer and Compliance Officer be the same person?
No. These roles should remain separate.
Is additional employee required?
Yes. At least one additional employee with prescribed qualification and experience is required.
Is custodian appointment mandatory?
Yes. Custodian appointment is mandatory.
What form is used for PMS application?
Form A under Schedule I is used for application.
Where is PMS application filed?
PMS application is filed through the SEBI Intermediaries Portal.
What is Form B?
Form B is the certificate of registration granted by SEBI.
What is the application fee?
The current official FAQ states application fee of Rs. 1,00,000, subject to latest SEBI verification.
What is the registration fee?
Registration fee is generally Rs. 10,00,000, subject to latest SEBI Schedule II verification.
Is block fee payable?
Yes. A continuation / block fee is payable every three years, subject to latest SEBI fee schedule.
Can SEBI reject an incomplete application?
Yes. SEBI may reject applications that are incomplete or do not meet requirements after giving opportunity to rectify deficiencies.
Can SEBI ask for personal representation?
Yes. SEBI may call the applicant or Principal Officer for interaction.
How long does PMS Registration take?
The process generally takes several months depending on documentation quality, SEBI review and query response.
Can PMS guarantee returns?
No. PMS cannot guarantee returns.
Can PMS pool investor funds?
PMS should not pool funds like an AIF or mutual fund. Client-wise portfolio segregation is required.
Are quarterly reports required?
Yes. Client reporting is required every quarter.
Is annual audit required?
Yes. Annual audit is required within the prescribed timeline.
Can PMS business be transferred?
PMS business transfer requires prior SEBI approval and must comply with applicable circulars and conditions.
Is change in control allowed without approval?
No. Prior SEBI approval is required for change in control.
Can SEBI inspect PMS entities?
Yes. SEBI may inspect books, client records, compliance systems, investment records and related documents.
Can PMS Registration be suspended?
Yes. SEBI may suspend or cancel registration for serious or repeated non-compliance.
What are common reasons for SEBI queries?
Common reasons include weak Principal Officer documentation, unclear business plan, net worth issues, certification gaps and inadequate compliance framework.
How can Estabizz help with PMS Registration in India?
Estabizz assists with PMS model assessment, entity review, net worth documentation, Principal Officer and team documentation, business plan, Form A filing, SEBI query support and post-registration compliance.
Reviewed by Estabizz Compliance Expert
Reviewed by: CS Devyani Khambhati
Designation: Compliance Expert | Estabizz Fintech Private Limited
Expertise: SEBI, RBI, IRDAI, IFSCA, PMS registration, portfolio manager compliance, wealth management structuring, SEBI intermediary licensing and post-registration regulatory support.
This content has been prepared from a regulatory advisory perspective to help wealth management companies, investment professionals, family office platforms, HNI advisory businesses, fintech wealth platforms and asset management groups understand the broad SEBI framework for PMS Registration in India.
This content is for general informational purposes only and should not be treated as legal, regulatory, tax, investment or financial advice. SEBI requirements, application formats, fee structures, net worth thresholds, certification requirements, custodian obligations, reporting timelines and approval processes may change from time to time. Applicants should verify the latest SEBI regulations, FAQs, circulars and fee schedule before filing any PMS application.
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