PMS Reporting Requirement to SEBI & few allied compliance.

Hyperlink for Regulatory Para Page Effective

Sr No Remarks Applicability Frequency Deadline Actionable Format if any. Page No.
Reference No. No. Date

As per Annex IA
Immediately or Updation in SEBI
Updation in details submitted during tabel Online Process
1 SEBI | Master Circular for Portfolio 1.5
Managers12 All PMS Every Change prior approval in Existing intermediary 53
regsitration like change in control etc for Updation of
few instances portal
Information

Within 6 Month pms_nw@sebi.go

Submittion of Networth Certfificate based on Para 1.6 of Master
2 SEBI | Master Circular for Portfolio
5.2.1.1
Managers42 All PMS Annual from end financial Existing v.in by email and 14
audited accounts Circular
Year
may send CC to
dealing officer of
SEBI

SEBI Portal &

APMI Portal. As Annexure 5A (except
Submission of reports of performance on SEBI Within 7 days of 1st April
3 SEBI | Master Circular for Portfolio Managers41
5.2.1.1. All PMS Monthly per procedure for Part E) For Part E 75
portal as well as APMI. end o the month 2023
prescribed para refer to next Sr.No.5)
5.1.4

All PMS all para

applicable.
However Para
In above montly performane(Sr.No.4) the change
2.9 to 2.15
in format for part E which is replaced by SEBI
SEBI | Performance Benchmarking and applicable to any Within 7 days of 1st April
4 2.12Reporting
3 ofB&V
Performance by Portfolio
Circular dated Managers
16 December 2022 which Monthly SEBI Portal Annexure 1 3
entity end o the month 2023
prescribe for additional layering of reporting with
reporting/adverti
benchmarking.
sing performance
or and IA of any
PM.

The above information to audited as per PMS Withing 6 month of

SEBI | Performance Benchmarking and 1st April Part of Annual
5 2.14Reporting
3 of Performance
Regulation 30byasPortfolio Managers
part of annual audit scope by All PMS Annual end of 6 months of NA NA
2023 Audit Report
auditor. financial year.
 Certificate of Compliance with PM Regn and
Within 60 dasys pms_comp@sebi.
Circulars signed by Principle Officer. This to
6 SEBI | Master Circular for Portfolio
5.2.1.2
Managers42 All PMS Annual from end of Existing gov.in by email No prescribed format. NA
include details of non-compliance alsong with the
financial year
corrective actions if any duly approved by board. and may send CC
to dealing officer
of SEBI

Corporate Governance Report including

quarterly certification and reports on compliances,
due diligence n overall operation ensuring
Within 30 days
protection of interest of investor, Redressal of
7 SEBI | Master Circular for Portfolio5.2.2
Managers42 All PMS Annual from end of Existing No prescribed format. NA
grivance any deficienty or ,rgulatory action or
financial year.
warning, Considering Internal Audit Report by
CA/CS and rectification thereof, any deficienty or
warning letter by SEBI along with Annual Report. pms_cg@sebi.gov
.in by email and
may send CC to
dealing officer of
SEBI

Scope of Annual Audit of to cover verification of

FIrm Level Performance reporting and
Confirmation by PM Board regarding
Compliance with para 4.5.3 by PM.
Comformation to compliance certificate by PM
includes 4.5.3.1 All cash
holdings and ivestemnts in liquied funds for caln
of performance 4.5.3.2
Performance data net of all fees and all
expenses(including taxes) 4.5.3.3 Change in
Investment Aprroach which may effect
performance of client portfolio in marketing pms_pers@sebi.g
material. 4.5.3.4 Ensure that ov.in by email
Within 60 days
5.3 & 43 & performance reported in all marketing material and 1st April
8 SEBI | Master Circular for Portfolio Managers
4.5.3 37. website of the PM is same as that reoted to SEBI
All PMS Annual from end of
2023
and may send CC No prescribed format. NA
financial year. to dealing officer
4.5.4.5 Ensure that aggregate
performances of the PM (firm level performance) of SEBI
reported in any documents shall be same as the
combined performance of all the Portfolio
managed by PM.
4.5.3.6 disclaimer in all marketing
material that hte performance related information
provided therein is not verified by SEBI.
This requirement should be read with
Monthly Requirements para 5.1 of Master Circualr
and Annexur 5A This further Amended by
Circular dated 16 December 2022 (B&V) refer Sr
No. 3 &4 of this checklist.
 Offsite Inspection and Surveillance data reporting
with in 10 days of From 1st Yet to receive email
9 SEBI | Master Circular for Portfolio5.4.1
Managers44 to SEBI. First itme from April 2020 to Spe 20, All PMS every quarter Annexure 5B 80
qtr end Oct. 23 id
2023

Details of reporting requirements as per provisions

of the Master Circular that are covered through the
offsite inspection reporting format as mentioned in Within 10 days w.e.f 30 Yet to receive email
10 SEBI | Master Circular for Portfolio5.4.2
Managers44 All PMS Quarterly Annexure 5C. 87
para 5.4.1 above.. First time submit data for all from end of quarter Sept 23 id
their clients from April1, 2020 to September,
30,2023

Reporting to client by PM. 5.5..1.1 Details of

invetment of clients fund in the securities of
To client but ensure
associates/related parties of the PM 5.5.1.2 1st April
11 SEBI | Master Circular for Portfolio 5.5
Managers45 All PMS Quarterly Basis Not prescribed. it matches with data Annexure 5D 89
instances of passive breach and steps taken to 2023
provided to SEBI.
rectify and 5.5.1.3 Details of credit rating of
investment in debt and hybrid securities.

1. Complain data on website of PM to be

published. 2. PM to
sensure display link/option in website and mobile
Within 7 days from 1st April
12 SEBI | Master Circular for Portfolio 7.2
Managers50 app to enable clients to lodge complian with them. All PMS Monthly On website of PM Annexure 7A 95
end of month. 2023
In addition to this link to SEBI complain redress
system website and link to download SCORES
mobile app to be published in website.

In procedure for seeking prior appruval for Co-

Every change
SEBI | Change in control of Portfolio Managers investment the provision is different from regular
13 1 1providing Co-investment services Co-investment in Control of NA Existing On SEBI portal NA NA
PMS. Read this circualr with Master Circular para
PM
1.5 page 12.

PMS with AUM vapt_reports@sebi.

Annexu 1st
SEBI | Cyber Security and Cyber Resilience Rs. 3000 Cr or Within 6 hours of gov.in and
14 re I framework
10 forReporting
Portfolio Managers
of cyber attacks, threats, etc Every Incident October NA NA
above for DPMS incident. cybersecurity_pms
para 51 2023
or NDPMS. @sebi.gov.in
 PMS with AUM vapt_reports@sebi.
Annexu 1st
SEBI | Cyber Security and Cyber Resilience Detailed report on cyber attack, threats, etc Rs. 3000 Cr or Every three Within 15 days gov.in and
15 re I framework
51 for Portfolio Managers October NA NA
along with action taken. above for DPMS month from end of quarter. cybersecurity_pms
para 51 2023
or NDPMS. @sebi.gov.in

PMS with AUM vapt_reports@sebi.

Annexu Within 1 month of 1st
SEBI | Cyber Security and Cyber Resilience Rs. 3000 Cr or Once in Year or gov.in and
16 re I framework
8 for Portfolio Managers
VAPT Audit submission of October NA NA
above for DPMS Twice in Year. cybersecurity_pms
para 40 VAPT report. 2023
or NDPMS. @sebi.gov.in

PMS with AUM vapt_reports@sebi.

Annexu Within 3 month of 1st
SEBI | Cyber Security and Cyber Resilience Remidial action on VAPT gap or vulnerabilities Rs. 3000 Cr or Once in Year or gov.in and
17 re I framework
8 for Portfolio Managers submission of October NA NA
detected. above for DPMS once in 2 year cybersecurity_pms
para 41 VAPT report. 2023
or NDPMS. @sebi.gov.in

PMS with AUM Every Year vapt_reports@sebi.

Annexu Within 3 year from 1st
SEBI | Cyber Security and Cyber Resilience Rs. 3000 Cr or along with gov.in and
18 re I framework
10 for PortfolioSystem
Managers
Audit Report the end of Financial October NA NA
above for DPMS compiiance cybersecurity_pms
para 55 Year. 2023
or NDPMS. report. @sebi.gov.in

BY APMI based
3. Submission of BI-monthly Progress Report. vapt_reports@sebi.
on information 1st
Para framework
SEBI | Cyber Security and Cyber Resilience This
for based on progress
Portfolio Managers of implimention of cyber Every bi monthly gov.in and
19 1 provided by PM. Bi Montly October NA NA
No.4 security and cyber resilience framework by PMS from 1 Oct 2023 cybersecurity_pms
Applicable to all 2023
progress submitted to APMI. @sebi.gov.in
PMS.

BY APMI based
Written Down Policy for team of PM. Order Put in place
on information
SEBI | Circular for Portfolio Managers execution and management of fund and securities, April 1st, Writtend down
20 Para 3 2 provided by NA Bi Montly NA NA
marigin and deviation thereof duly approved by 2023 poilicy and inform
PMs. Applicable
Board of PM status to APMI
to all PMS.
 Ensure
BY APMI based
documentation and
Requiement with repect to investment in all on information
SEBI | Circular for Portfolio Managers April 1st, implimentaion of
Para 4.1 3 instruments / Preventive measures for dealing provided by NA NA NA NA
2023 preventive measure
person. PMs. Applicable
and report progress
to all PMS.
to APMI

BY APMI based
Ensure software
on information
and system
provided by
System Automation with minimum manual updation along with
PMs. Applicable
SEBI | Circular for Portfolio Managers4.2 intervation including maintaining audit trial for April 1st, training to staff to
21 3 to PMS having NA NA NA NA
effective and efficient management of client fund 2023 ensure compliance.
INR 1000 Cr
and securities. Also ensure
AUM or more
maintaning audit
including Dpms
trial.
and NDpms.

BY APMI based
The progress report for above compliance to be on information
Annex.
SEBI | Circular for Portfolio Managers From Feb Inform progress to
22 6 submitted to SEBI by APMI based on information provided by Bi Montly NA NA NA
1 28, 2023. APMI.
provided by PM. PMs. Applicable
to all PMS.