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

Portfolio Manager Dealing-Room Relaxation for Fewer Than 10 Clients or AUM Below ₹100 Crore: SEBI Proposal

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

The proposed dealing-room relaxation for small Portfolio Managers sits inside SEBI's 23 July 2026 comprehensive PMS consultation. The fewer-than-10-clients / below-₹100-crore concept is a proposal, not a current exemption.

Finin2min 2-Minute Summary

Do not convert the proposal into an exemption

The current Portfolio Managers Regulations and Master Circular continue to govern. A firm with nine clients or ₹90 crore AUM should not dismantle controls merely because the consultation proposes relief.

Keep the proposed threshold in a sandbox readiness policy and activate it only if final wording adopts it.

What controls must survive a physical-room relaxation

Order initiation, approval, timestamp, broker selection, client allocation, personal-dealing restrictions, restricted lists, call/message retention and exception review remain relevant. The risk is not the room; it is uncontrolled dealing.

For work-from-office/hybrid setups, define authorised devices, recorded channels and access restrictions.

Threshold monitoring

Client count and AUM can cross a boundary mid-period. Design a daily/monthly dashboard depending on the final rule and create a transition plan for the date on which the firm ceases to qualify.

Do not manipulate account grouping or valuation timing to remain below a threshold.

Small PMS case: no dealing room does not mean no dealing controls

Imagine a boutique PMS with eight clients and ₹75 crore AUM. Under the consultation concept it may eventually qualify for dealing-room relaxation, but the same employee could still place orders across clients, handle restricted information and allocate fills. The compliance risk therefore moves from physical segregation to digital and supervisory segregation.

A workable alternative would require authorised terminals, recorded order channels, restricted-list checks, pre/post-trade review, allocation rules and periodic surveillance. If the business grows to twelve clients or ₹120 crore, a threshold-triggered transition should restore whatever controls the final framework requires without a rushed rebuild.

Evidence of supervisory review

Where a small PMS eventually operates under relaxed physical infrastructure, supervisory review should still leave evidence: sampled orders, allocation checks, restricted-list exceptions and personal-dealing surveillance. Small size can simplify process, but it should not make supervision invisible.

Proposal-readiness checklist

Questions readers commonly ask

Is the relaxation live now?

No. It is part of a July 2026 consultation.

Can a small PMS stop keeping dealing records?

No. Core order and conflict controls remain important regardless of physical setup.

Why monitor AUM continuously?

A final threshold-based relief could stop applying as the business grows.

Which current sources govern meanwhile?

The Portfolio Managers Regulations and Master Circular.

Official / primary sources

Disclaimer

Important: General educational and professional-reference material. Verify the current operative regulation/circular, portal version and exact facts before acting. Consultation papers are proposals unless a later operative instrument adopts them. Educational and professional reference only; confirm the current law, rates and the facts of your case before relying on this page.

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.