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SEBI product and intermediary module

Portfolio Managers

Integrated module covering client agreements, custody, performance, fees and reporting.

client agreements, custody, performance, fees and reporting8 control pages

Reviewed by Ravi Sisodia · Last reviewed 24 July 2026

What this module covers

Portfolio Managers who manage client securities/funds on a discretionary or non-discretionary basis are regulated under the SEBI (Portfolio Managers) Regulations, 2020 (last amended 3 September 2025). The regulations set a minimum net worth of ₹5 crore, mandate a written client agreement disclosing fees, risk factors and past performance (computed on a Time-Weighted Rate of Return basis under a prescribed disclosure document), require client funds and securities to be held in segregated bank/demat accounts distinct from the portfolio manager’s own, and cap the minimum investment amount accepted from a client at ₹50 lakh. Performance-linked fees, if charged, must follow a high-watermark principle so a manager cannot charge the same gains twice.

The 8 control pages below turn this framework into operational checkpoints — confirming registration and governance (P-01, P-02) through client onboarding and agreement due diligence (P-03), fund/securities custody and segregation (P-04), fee and performance-disclosure controls (P-05), periodic reporting (P-06), complaint handling (P-07) and inspection readiness (P-08) — as a single connected compliance workflow.

Control pages

Official sources

Current law status: in force as of this review date; last amended 3 September 2025. Verify for further amendments before relying on this page for a live compliance decision.