SEBI

What are the SEBI PMS Reporting Requirements and Regulatory Filing Deadlines?  

Portfolio Management Services (PMS) is a SEBI-regulated investment service in India. Professional portfolio managers manage the investments of clients through this service. However, this work does not only involve investment management. Various reports have to be submitted as per the rules prescribed by SEBI. 

PMS providers are required to make regular reports, disclose information and file within a specified period. SEBI can monitor their work and help investors get accurate information about their portfolio. 

This reporting includes filing on a monthly, quarterly, annual, and special event basis. SEBI notified new Portfolio Managers Regulations in 2026. These rules will come into effect from April 1, 2027. The 2020 Regulations and current guidelines will be applicable. 

Understanding the SEBI PMS Regulatory Framework  

SEBI has specific rules for the operation of Portfolio Management Services in India. These rules ensure the functioning, reporting, and protection of clients by PMS providers. 

Here are some important rules and guidelines to be followed- 

• SEBI (Portfolio Managers) Regulations, 2020: This is the main regulatory framework for PMS providers. The revised 2020 regulations will remain in force till March 31, 2027. 
  
  
• SEBI Master Circular, July 16, 2025: This circular has put together important guidelines for reporting, operations, and disclosure of information by PMS. 
  
  
• SEBI (Portfolio Managers) Regulations, 2026: SEBI has published new regulations. It will be effective from April 1, 2027. 
  
  
• Compliance Officer: PMS providers are required to have appropriate mechanisms in place to monitor compliance regularly. The compliance officer plays an important role in this process. 

This report is to monitor AUM, client investments, transactions, and performance. 

PMS reporting is mainly of two types: 

1. Regulatory Reporting: Direct reporting to SEBI. 

2. Client Reporting: Reporting portfolio, returns, and other information to investors. 

SEBI PMS Reporting Requirements 

SEBI PMS providers are required to submit reports at various intervals. Through these reports, the regulatory body can understand their activities and compliance status. The reporting period is fixed on a monthly, quarterly, and annual basis. 

Monthly Reporting Requirements 

Every registered Portfolio Manager is required to submit a monthly activity report to SEBI. This report contains information about the Portfolio Management Activities conducted during the respective months. 

The report should mention the Assets Under Management (AUM) as on the last calendar day of the month. Other information related to portfolio management should also be provided. 

For submitting this report, the SEBI Intermediaries Portal should be used. The report should be prepared as per the prescribed format given in Annexure 5A of the Master Circular. 

Filing Deadline: The report should be submitted within 7 working days after the end of each month. 

Online submission of the report is sufficient. There is no need to send a separate hard copy for this. 

Quarterly Reporting Requirements 

Apart from the monthly report, Portfolio Managers are required to submit Off-site Inspection Data to SEBI every quarter. This report contains client-wise investment and portfolio information. 

It mainly includes two important pieces of information: 

●      Client Folio AUM: Information on Assets Under Management of each client’s portfolio. 

●      Client Holding Master: Details of various securities and other investments held by clients. 

In addition, day-wise data, details of clients’ holdings, and transactions are required for specific information. The report is to be prepared as per Annexure 5B of the Master Circular. 

Filing Deadline: The report is to be submitted within 15 calendar days of the end of each quarter. SEBI uses this information to monitor portfolio management. 

Annual Compliance Reporting 

Portfolio managers are required to submit an annual compliance report at the end of every financial year. This report contains information on compliance with applicable regulations, circulars, and other guidelines for SEBI. 

Some important points should be mentioned in the report: 

•      Details of compliance throughout the year. 
  
•      Information on any violation of regulations. 
  
•      Steps taken to resolve the identified issues. 
  
•      Details of important compliance issues. 
  
•      Approval of the Board should also be taken as required. 

Filing deadline: Annual Compliance Report should be submitted to SEBI within 30 calendar days of the end of the financial year. 

In addition, the principal officer should submit a separate compliance certificate. The deadline is within 60 calendar days of the end of the financial year. 

Annual Performance Audit Reporting 

Portfolio managers are required to audit firm-level performance data every year. This verifies whether the investment performance information has been calculated correctly. 

This audit is to be done independently. The Standard Terms of Reference set by the Association of Portfolio Managers in India (APMI) are to be followed during the audit. 

Along with the audit report, confirmation of compliance is also to be submitted to SEBI. The required certification is to be given by the authorized director, partner, or other responsible person. 

Filing deadline: Within 60 calendar days of the end of the financial year. 

Corporate Governance Reporting 

The Corporate Governance Report is an important part of the annual compliance of PMS providers. This report has to highlight various aspects of the internal control and management of the organization. 

It usually includes the following: 

•      Results and observations of internal audits. 
  
•      Compliance deficiencies identified during the financial year. 
  
•      Warning or deficiency letters received from SEBI. 
  
•      Steps taken to resolve the issues identified. 
  
•      Investor complaints and status of their resolution. 
  
•      Review of compliance issues by the Board. 

PMS providers are also required to have internal audit arrangements. This audit can be conducted by a Practicing Chartered Accountant (CA) or Company Secretary (CS). 

Filing Deadline: The Corporate Governance Compliance Report must be submitted to SEBI within 30 calendar days of the end of the financial year. SEBI gets a clear idea about the control system and compliance status of the organization. 

PMS Client Reporting and Disclosure Requirements  

PMS providers are required to submit regulatory reports as per SEBI norms. They are also required to provide accurate information to their clients on a regular basis. This enables investors to know about their portfolios, returns, expenses, and investment risks. 

1. Quarterly Client Statements 

PMS providers are required to provide Portfolio Statements to their clients every quarter. This report contains information about investment status and related transactions. 

The Quarterly Client Statement generally contains the following: 

• Composition and current market value of the client’s portfolio. 
  
• Details of Securities, Units, and Cash Balance. 
  
• Information on investments bought and sold during the period. 
  
• Dividend, Interest, Bonus Shares, and Rights Entitlements. 
  
• Management fees and other expenses. 
  
• Potential risks associated with the portfolio and investments. 

The format prescribed in Annexure 5D of the SEBI Master Circular is to be followed for preparing this report. 

2. Performance Reporting to Clients  

Portfolio Managers are required to use specific methods to communicate investment performance to clients. XIRR and TWRR are important here. 

Reporting Type	Requirement
Individual client performance	XIRR for each investment approach
Investment approach comparison	Minimum, maximum, and median XIRR across investors
Public performance communication	TWRR with the trailing return of the selected benchmark

XIRR calculates the return based on the time of deposit and withdrawal of the client’s money. On the other hand, TWRR shows investment performance by reducing the impact of external cash flows. Using these methods, investors can understand the return more easily. 

3.  Disclosure Document Requirements  

Before investing in PMS, the client is required to provide a Disclosure Document. It contains important terms of service and investment-related information. 

This document usually includes the following: 

• Fees, charges, and other expenses. 
  
• Investment Objectives and Portfolio Risks. 
  
• Related Party Transactions. 
  
• Past performance information. 
  
• Audited Financial Statements for the last three years. 

The portfolio manager is required to keep the latest disclosure document available on its website. The revised document must be submitted to SEBI for any material change. As per the current rules, this filing has to be done within 7 working days of the change. 

Event-Based PMS Regulatory Filings 

PMS providers are not required to submit all reports as per a specific monthly or quarterly schedule. Any significant change in business, ownership, or management must be reported to SEBI. These are called event-based regulatory filings. 

Some important events and related compliance details are given below- 

Event	Compliance Requirement
Change in control	Obtain prior approval from SEBI through the prescribed process
Change in control communication	Inform existing clients and provide an exit option without an exit load.
Change in Principal Officer	Notify SEBI and clients within the applicable timeline.
Material change in Disclosure Document	File the revised document with SEBI within 7 working days.
Scheme of arrangement	Obtain SEBI approval before approaching NCLT and complete subsequent filings within the prescribed period

In case of a change in control, the portfolio manager must obtain prior approval from SEBI. The existing clients also have to be informed about the change. They have to be given an exit window of at least 30 calendar days. During this period, clients can exit the investment without any exit load. 

There are different rules for Change of Principal Officer, Material Amendments in Disclosure Document, and Scheme of Arrangement. 

The filing deadline for each event is not the same. So, it is important to check the relevant SEBI Circular and applicable rules before implementing any change. 

SEBI PMS Compliance Calendar and Filing Deadlines 

PMS providers must submit multiple reports within a specific time frame. So, it is important to have a compliance calendar for when a report should be submitted. This reduces the risk of missing deadlines. 

Here are important PMS reporting and filing deadlines. 

Compliance Requirement	Frequency	Filing Deadline
Monthly activity report	Monthly	7 working days after month-end
Off-site inspection data	Quarterly	15 calendar days after quarter-end
Client portfolio statement	Quarterly	As prescribed under applicable requirements
Annual compliance report	Annual	30 calendar days after FY-end
Corporate governance report	Annual	30 calendar days after FY-end
Firm-level performance audit report and confirmation	Annual	60 calendar days after FY-end
Principal Officer compliance certificate	Annual	60 calendar days after FY-end
Distributor self-certification	Annual	15 calendar days after FY-end
Material Disclosure Document changes	Event-based	7 working days from the change

PMS providers should create a Central Compliance Calendar. A specific employee or officer should be assigned responsibility for each filing. Acknowledgement and other evidence of the submitted report should also be retained. This will help in future SEBI Inspection or Compliance Review. 

Consequences of Not Meeting SEBI PMS Filing Deadlines  

PMS providers may face various compliance issues if they do not submit reports within the stipulated time. Late, incomplete or incorrect submission of information may lead to increased scrutiny by SEBI. 

Several risks may arise in this case: 

• Regulatory Scrutiny and Inspection Observations by SEBI. 
  
• Directions or Corrective Measures by SEBI. 
  
• Regulatory Action as per applicable Intermediary Regulations. 
  
• Weak Internal Controls and Incomplete Compliance Records. 
  
• Loss of investor confidence. 
  
• Timely submission of reports is not enough. It is also important that the information is accurate, complete, and supported by necessary documents. 

How Can Enterslice Help with Compliance? 

Compliance with SEBI’s PMS norms requires proper planning and regular compliance monitoring. Enterslice can provide professional support to portfolio managers. 

Our Services: 

• Helping to understand applicable SEBI PMS Regulations and Circulars. 
  
• Preparing and reviewing monthly, quarterly, and annual reports. 
  
• Assistance in portfolio manager registration with SEBI.
   
• Tracking important filing deadlines and Regulatory Updates. 
  
• Helping to create and update Disclosure Documents. 
  
• Assisting in documentation of Compliance Review and Performance Audit. 
  
• Identifying Reporting Gaps and taking corrective actions. 

We help PMS providers reduce filing errors and manage the compliance process more easily. 

Conclusion  

Adhering to SEBI’s reporting norms and filing deadlines is very important for managing PMS in India. The regulatory body monitors the portfolio management performance through monthly, quarterly, annual, and event-based reporting. It is the responsibility of every portfolio manager to submit timely reports, keep the information updated, and maintain the required documents.  

Enterslice’s professional support can be taken to facilitate these tasks. We help providers with various reporting, filing, and compliance tasks. Contact Enterslice today to manage SEBI PMS Compliance more easily. 

Frequently Asked Questions