SEBI Circular – Format of ‘Disclosure Document’ for Portfolio Managers

SEBI, vide its circular dated September 9, 2025, has simplified the format of the ‘Disclosure Document’ for Portfolio Managers by deleting Schedule V from the SEBI (Portfolio Managers) Regulations, 2020 and issuing a new format (Annexure-I) in consultation with APMI. The document is now divided into static and dynamic sections, with each parameter starting on a fresh page. Only the updated pages need certification by an independent Chartered Accountant and the Principal Officer, and such changes must be highlighted, simultaneously communicated to clients, uploaded on the PMS website, and filed with SEBI within 7 working days. Other regulatory requirements, including content under Regulation 22(4) and certification under Regulation 22(5), remain unchanged. The circular takes immediate effect.

Link: https://www.sebi.gov.in/web/?file=https://www.sebi.gov.in/sebi_data/attachdocs/sep-2025/1757413322022.pdf#page=1&zoom=page-width,-16,792