PMS Registration with SEBI- An Overview

PMS registration with SEBI is a process that allows a financial professional or entity to obtain a license to handle or manage an investment portfolio on behalf of its clients. The Securities and Exchange Board of India governs and controls portfolio managers based on qualification and regulatory requirements. A mutual fund is a mass market, while a PMS is a premium market.

A portfolio manager is responsible for overseeing their clients’ investment returns while simultaneously mitigating the risks. The registration certificate ensures that the PMS is certified to provide services to its clients.

With Enterslice assistance, you can:

Appoint a compliance and principal officer

Complete your legal documentation

Apply for the SEBI PMS registration

Reply to queries to the SEBI

Fulfil your annual obligations

Renew your PMS registration with SEBI certification

Get real-time tracking of your application

Connect with an individual case manager

Start Your SEBI PMS Registration in India with Enterslice

Maximize your wealth with SEBI PMS registration in India through the Enterslice team.

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Types of PMS Registration with SEBI Based on Assets

Scroll down and find out the different types of PMS registration with SEBI-based on assets, as explained below:

Equity PMS

Equity PMS

Highly focused on equity instruments, including listed shares, unlisted shares, and mutual funds. This is considered high-risk due to market fluctuations. Recommended for investors seeking long-term capital appreciation.

Debt PMS

Debt PMS

Investment is made in fixed-income securities, which are typically debt instruments such as corporate bonds (issued by companies), government securities (issued by the government), and debt mutual funds (pooled investments in various debt instruments). These are highly recommended for investors seeking stable returns.

Hybrid PMS

Hybrid PMS

This type is a combination of both equity and debt instruments. The risk is highly dependent on the equity-to-debt ratio. It is good for investors seeking diversification through a single portfolio.

Multi-Asset PMS

Multi-Asset PMS

This is an enhanced version of a hybrid PMS because it includes assets like gold, Real Estate Investment Trusts (REITs), and Infrastructure Investment Trusts (InvITs).

Categories of PMS for SEBI PMS Registration

Given below are the categories of PMS for SEBI PMS registration based on the degree of control and investor involvement-

  • Discretionary PMS: The fund manager takes all investment decisions on your behalf.
  • Non-Discretionary PMS: The fund manager suggests investments, but the final decision is yours.
  • Advisory PMS: The fund manager only provides advice; you execute the investments.

Benefits of SEBI Portfolio Manager Registration

Discover the benefits of SEBI portfolio manager registration as described below:

Business Development

Once you’ve obtained a SEBI PMS license, you can increase your reputation and recognition in the securities market, increasing your consumer base and profit generation.

Wide Range of Clients

After PMS registration with SEBI, you are entitled to provide services to a vast pool of clients, including high-net-worth entrepreneurs, entities, investors, and related parties.

Authentic Credibility

Once you’re a SEBI-registered portfolio manager, you can demonstrate your credibility through your certificate of registration, placing a sense of trust and confidence in your clients and investors. It is one of the benefits of SEBI portfolio manager registration.

Risk Mitigation

After PMS registration with SEBI, the portfolio manager can take guidance from the regulatory authority on risk mitigation, providing appropriate advice to the investors. This practice instils a sense of responsibility in the manager to their clients.

License to Provide Portfolio Management Services SEBI

With a PMS registration with SEBI, you can provide a wide range of services, including investment, asset management, financial planning, and wealth management.

Compliance With SEBI

As per SEBI PMS guidelines and regulations, the manager is required to provide continuous monitoring updates, ensuring conflict and fraud-free services to stakeholders and clients.

How to Apply for SEBI PMS license With Enterslice?

A SEBI PMS License is mandatory for you if your entity is desirous of being registered as a portfolio manager. Get Enterslice expert assistance to understand the process of PMS registration with SEBI as described below:

Document Preparation

Our lawyers will prepare various documents, including net-worth certificate, audited financial statements, MOA, company charter, disclosure agreements, and details of directors & shareholders.

Appointment of Principal and Compliance Officer

We’ll help you appoint experienced professionals with at least 5 years of experience in the field of requirement.

Application Filing with the SEBI

Once we’ve gathered all the documents, we’ll formally apply with Form A to the Securities and Exchange Board of India (SEBI) with a non-refundable fee of INR 1 lakh.

Evaluation of the PMS registration with SEBI Application

The regulatory authority will examine your application and documents. Our lawyers will keep a track of the application in case SEBI has any questions or concerns. Accordingly, we’ll send your real-time updates and take effective measures as per the authority’s instructions after taking your consent.

Approval and Subsequent Registration

After verifying all your documents, the SEBI will approve your application for PMS registration. You’ll be required to pay INR 10 lakh as the final fee.

Successful PMS Registration with SEBI

Once you’ve made the final payment fee, the authority will verify the same and grant you the certificate of registration, authorizing you as a SEBI-registered portfolio manager.

Timeline for PMS SEBI Registration in India

PMS SEBI registration takes at least 3 to 4 months. The timeline is as follows:

Documentation: 1 to 2 weeks

Gather documents like ID proofs, registered business address, MOA, AOA, company charter, NISM-XII A/B certification, and other related documents.

Application Submission: 1 Day

Submit Form A with mandatory documents and fees via the SEBI portal.

Evaluation of Documents: 8 to 12 weeks

The SEBI officials will examine the documents and application for verification.

Approval: 1 to 2 weeks

If everything is as per the SEBO PMS guidelines, then your application will be approved, and you’ll be required to pay the remaining registration fees.

PMS Registration with SEBI Certificate: Immediate After Confirmation of Fees

Once the SEBI has verified your payment, it’ll issue the certificate of SEBI PMS registration.

Documents Required for SEBI Portfolio Manager Registration

The documents required for SEBI portfolio manager registration are as follows:

ID proofs, including Aadhar, driving license, voter ID, or passport of all directors, shareholders, and partners

Address proof, namely water bills, electricity bills, or lease/rental agreements

Application Form A

Permanent Account Number (PAN)

Goods and Services Tax (GST) number

A copy of the original company registration certificate or partnership deed

Memorandum of Association (MOA)

Articles of association (AOA)

Registered business and correspondence address

A detailed business plan

A board resolution

The last three years' audited financial statements of the entity/organization’s

A certification by a CA on the net worth of the applicants

A certification by a CA on the net worth of the applicants

A certificate on NISM-Series-XXI-A or B Portfolio Managers Certification Examination

Education and qualification of principal officers in portfolio management or related domains

Renewal of SEBI PMS Registration

To renew the SEBI PMS registration, all managers must pass the NISM XXI A/XXI B certificate within the last 12 months of the validity’s expiration. Key points to remember about the renewal are as follows:

The PMS SEBI registration is only renewed if you pass the NISM XII-A/XII-B examination. Both certifications are valid for three years from their initial validity. The renewal fee for PMS certification is INR 5 Lakh, and NISM XII-A/XII-B is INR 1500.

If you fail to pass the exam, the subsequent failure to renew the PMS certificate will result in the revocation of the registration. Furthermore, you won’t be able to obtain any commissions, meaning the SEBI will forfeit all of it unless you renew your certifications.

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Complete Legal Documents are Mandatory

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Updated Disclosure Agreement is Required

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NISM Certification for Principal Officer

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Audited Statements and Net-Worth Declarations

Requirements for Obtaining SEBI PMS License

Scroll down the basic criteria and requirements for obtaining the SEBI PMS license in India as mentioned below:

  • The applicant must be a SEBI-registered entity. A PMS provider should be an LLP or a company. Individual registrations are not allowed.
  • All the primary personnel must be well-qualified with adequate professional experience as prescribed by the SEBI.
  • The applicant must have at least a net worth of INR 5 crore at the time of PMS SEBI registration.
  • The net worth must be authenticated by a Chartered Accountant (CA).
  • The principal officer (PO) must be a professional with experience as a CA, CFA, CS, Cost Accountant, or an MBA with specialisation in finance of at least five years.
  • The PO must have a valid NISM Series- XXI-A (Portfolio Management Certificate.
  • A compliance officer must be appointed for regulatory purposes.
  • The applicant must have installed an adequate workspace, IT & computer systems, and risk-mitigating channels.
  • All personnel, including directors, managers, and partners, shouldn’t be disqualified by law or otherwise bankrupt.
  • An application fee of INR 1 Lakh must be paid at the time of filing.
  • The applicant must submit important documents, including the MOA, AOA, partnership deed, business registration certificate, details, and identification of mandatory personnel.
  • A diagram of the organizational structure.
  • The applicant must draft legally binding agreements with clients in accordance with SEBI.
  • A registration fee of INR 10 Lakhs must be paid after SEBI approval.

Compliance of SEBI-Registered Portfolio Manager

With Enterslice experts, you can easily keep track of your compliance obligations as a SEBI-registered portfolio manager.

  • We’ll ensure you adhere to the principles of standards and the code of conduct.
  • You must be 100% honest with your clients to avoid any type of legal disputes and conflicts of interest.
  • Our compliance associates will assist you in preparing risk disclosure and performance reports.
  • You should maintain at least INR 50 Lakh as a minimum portfolio investment after PMS registration with SEBI.
  • We’ll help you appoint a compliance officer to track your regulatory obligations pursuant to SEBI.
  • If you’re planning for a change in control, then we’ll assist you in notifying and obtaining prior approval from the SEBI.
  • We’ll help you appoint an independent custodian who will main your investors’ accounts.
  • Our compliance associates will ensure that all your clients get notified before hand of any change in control in case they want to exit without any load.
  • Our compliance consultants will assist you in submitting a monthly report by the 7th of each month.
  • Enterslice’s will help you conduct an internal audit through our network of 200+ seasoned professionals within 30 days after the fiscal year end.
  • Our Chartered accountants will certify your annual net worth of at least INR 5 crore by March 31st and submit the same by September 30th.
  • We’ll assist you in renewing your PMS registration with SEBI during the last year of your 3-year validity.
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Why Trust Enterslice for PMS Registration with SEBI in India?

We are the first choice of over 1 lakh founders globally. With 15+ years of experience in the compliance industry, we thrive on the success of our clients. Take a look at the key reasons mentioned below and decide why Enterslice must be your go-to preference for PMS registration with SEBI:

  • No government office visits are required- fully remote.
  • Compliance support for 1 year after SEBI PMS registration.
  • Proven track record of 99%, unmatchable and beyond all expectations
  • Complete assistance in the appointment of the compliance officer.
  • Sign up with us for the PMS registration process SEBI from anywhere in India.
  • Avail portfolio management services under SEBI regulations at the best EMI rates with leading banks.
  • Monitor compliance easily and avoid penalties- timely filing of monthly, quarterly, and annual returns.
  • Transparent fee structure with government fees- no hidden charges.
  • End-to-end client support from PMS registration with SEBI approval to compliance assistance.
  • Complete legal documentation, including agreement drafting and application filing.
  • Lifetime free consultation, best in the industry

Frequently Asked Questions on PMS SEBI Registration

Have a look at the following answers to the most asked questions:

The content, including discretionary and non-discretionary, that must be included for the monthly report is as follows:

  • Asset under management (AUM) breakdown of all clients, including the number and types. (foreign or domestic, and entities or entrepreneurs).
  • Total number of transactions.
  • Fund inflow and outflow in the given month.
  • Performance index- what was expected vs what was achieved.
  • Total number of assets under advice by category.
  • Details on co-investment clients and assets managed as such.
  • Mandatory disclosure of complaints received/pending beginning or during the start or end of the month.

The fee structure for SEBI PMS registration includes:

  • A non-refundable application fee: INR 1 Lakh.
  • Registration fees: INR 10 Lakh.

The step-by-step procedure for obtaining the PMS SEBI registration is as follows:

  • Preparation of documents and agreement drafting.
  • Submission of NISM-XII A/B passing certificate.
  • Application filing through the SEBI online portal.
  • Payment of fees of INR 1 Lakh
  • Examination by the SEBI authorities
  • Final approval and payment of INR 10 Lakhs.
  • Issuance of a certificate of registration.

The documents needed for the SEBI-registered portfolio manager application are as follows:

  • ID and address proof of the applicant.
  • A certificate of business incorporation/partnership deed (LLP).
  • A registered business office address,
  • Details of all directors, partners, and shareholders.
  • An NISM- XII A/B passing certificate.
  • A declaration of minimum net worth certificate.
  • Audited financial statement of the last three years.
  • Education and professional qualifications of the principal officer.
  • A risk management policy.

The applicant must have at least INR 5 crore of net worth to obtain a SEBI portfolio management registration.

Only companies and LLPs are eligible to act as a SEBI-registered portfolio manager in India.

In case the SEBI authority rejects your application, then you’ve 45 days from the receipt of the said order to appeal it to the Securities Appellate Tribunal (SAT).

The timeframe for acquiring a SEBI portfolio registration management is as follows:

  • Legal documentation: 1 to 2 weeks
  • Form A- Application filing: 1 day.
  • Payment of fees: 1 day
  • SEBI examination of the application: 8 to 12 weeks
  • Approval and payment of registration: 1 to 2 weeks
  • Issuance of certification: immediately after payment of INR 10 lakhs.

The various categories of SEBI PMS registration are as follows:

  • Discretionary
  • Non-discretionary
  • Advisory

You must submit your annual reports by September of each year.

No, you cannot provide any sort of indicative or guaranteed returns as a portfolio manager to your clients or investors.

  • An investment charter consists of the following information:
  • Different types of services with timeframes.
  • Manager’s agreement with the investor.
  • Monthly and quarterly statements.
  • Grievance and redressal mechanism.
  • Responsibilities of the stakeholders.

A portfolio manager can apply for a change through the SEBI portal. Any such prior approval is valid for six months from the date of the approval, provided the manager applies for a new registration within six months of the previous approval.

No, as a portfolio manager, you’re not allowed to impose a lock-in on any or all of the investments of your clients.

A disclosure document is provided by the manager to every client they deal with. It consists of the following details:

  • Amount and mode of payment of fees paid by the client for each transaction and activity.
  • Any transaction with a related party in accordance with transfer pricing laws.
  • The performance indicator of the manager
  • Audited financial statements of the last three years.

Given below are key pointers on the responsibilities of SEBI portfolio managers:

  • Ensure the activities and management are aligned with the binding contracts/agreements.
  • Provide an oversight of the portfolios to the clients at the latter’s convenience or request at any point in time.
  • Provide the latest updates about investment activities to clients/investors.
  • Recommend modifications/changes in investment portfolios as per regulatory and market changes.

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