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Corporate Laws Central Ministry of Finance Securities and Exchange Board of India Act, 1992

Format of Disclosure Document for Portfolio Managers

09-Sep-2025 | SEBI/HO/IMD/IMD-RAC-3/P/CIR/2025/125

SEBI has issued a circular regarding Format of Disclosure Document for Portfolio Managers, effective from 9th September 2025. This circular has been issued in reference to Regulation 22(3) of SEBI (Portfolio Managers) Regulations, 2020 (Regulation), which mandates the submission of 'Disclosure Document' by Portfolio Managers to the client, prior to entering into an agreement with the client. By virtue of this circular, SEBI has specified the format of 'Disclosure Document' seperately, which was earlier specified in Schedule V from the SEBI (Portfolio Managers) Regulations, 2020. The 'Disclosure Document' has been divided into 2 sections- static and dynamic. Each parameter of 'Disclosure Document' begins on a fresh page. Only the page containing change(s) in any parameter needed to be certified by the Independent Chartered Accountant and Principal Officer of the PMS, and the updated Disclosure Document Page(s)shall be simultaneously communicated to the clients, updated on the website of Portfolio Manager, and filed with the Board within 7 working days from the date of change. The format of 'Disclosure Document' along with the template is given in Annexure-I. Kindly refer to the attached document for more information.

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