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Finin2minCurrent Action Brief · 13 Aug 2026
SEBI & SecuritiesUpdated 5 October 2026

₹5 Crore Securities-Market-Asset Test for Individual Accredited Investors: SEBI Consultation Guide

By Ravi Sisodia · Reviewed by CA Divyanshu Sengar · Updated 5 October 2026

The consultation proposes a ₹5 crore securities-market-asset route for individual accredited investors. It is not yet an operative threshold; managers should use it only for impact modelling until SEBI finalises the framework.

Finin2min 2-Minute Summary

Do not market the ₹5 crore route as live

Website calculators, investor decks and relationship-manager scripts should say 'proposed' until an operative circular/regulation is issued. An investor with ₹5 crore in a broad wealth statement should not be told that accreditation is already guaranteed.

Monitor final SEBI wording for whether the amount, asset perimeter or conditions change.

Build a transparent calculation sheet

List each qualifying account/holding, owner, value date, source and eligible amount. Excluded or disputed assets should remain visible as zero/adjusted lines rather than being deleted from the file.

Use a reviewer to confirm arithmetic and policy interpretation.

Manage valuation volatility around the threshold

For market-linked holdings, a portfolio can move across ₹5 crore quickly. The final framework may specify a determination date and validity. Until then, design the system to preserve the actual decision-date valuation rather than retroactively rewriting it.

Near-threshold cases should never be 'topped up' through unsupported valuations.

₹5 crore proposal case: market moves below the line after verification

Suppose an individual's qualifying portfolio is ₹5.15 crore on the determination date and falls to ₹4.70 crore during a market correction soon afterwards. The consultation's final adopted validity rules - not day-to-day price movements chosen ad hoc by the manager - should determine whether status remains valid.

That is why the evidence file needs a precise valuation date, source and decision timestamp. Recalculating historical status with today's market value would make the audit trail unstable.

At the same time, relationship teams should avoid telling the investor that the ₹5 crore proposal guarantees long-duration status. Validity and revalidation are separate elements that SEBI must finalise.

Evidence quality at the threshold

Near the proposed threshold, evidence quality matters more than decimal precision. A ₹5.02 crore result built partly from stale screenshots is weaker than a lower but fully verified portfolio. The reviewer should reject unsupported lines rather than applying optimistic rounding to reach the proposed level.

Individual-test checklist

Questions readers commonly ask

Is ₹5 crore a live SEBI rule today?

No. It is part of the 13 August consultation proposal.

Can house property be added to reach ₹5 crore?

Use only assets within the final securities-market-asset definition; do not assume property qualifies.

What date should values use?

The final instrument must be followed; readiness systems should at least preserve a clear decision-date valuation.

Does crossing the threshold make every AIF/product suitable?

No. Accreditation is not the same as suitability.

Official / primary sources

Disclaimer

Important: General educational and professional-reference material. Verify the current operative instrument, effective date and exact facts before acting. Consultation papers are not final law unless SEBI subsequently adopts them. Educational and professional reference only; confirm the current law, rates and the facts of your case before relying on this page.

Related tools and reading

Educational and professional reference only — not financial, tax or legal advice. Verify the current official position from the primary source before relying on any figure, rate, provision or deadline.