SEBI Notifies Simplified Disclosure Document for Portfolio Managers

Circular No. SEBI/HO/IMD/IMD-RAC-3/P/CIR/2025/125; Dated: 09.09.2025

1. Introduction

The Securities and Exchange Board of India (SEBI) has issued a simplified format of the ‘Disclosure Document’ for Portfolio Managers. This initiative is designed to enhance transparency, standardize disclosures, and empower investors to make informed investment decisions when engaging with portfolio management services (PMS).

2. Structure of the Disclosure Document

The new disclosure format is divided into two sections: static and dynamic. The static section contains information that does not change frequently, such as organizational structure, key policies, and compliance framework. In contrast, the dynamic section includes details that undergo frequent updates, such as investment strategies, fee structures, and risk factors. This bifurcation ensures that investors receive accurate, up-to-date information without being overloaded with repetitive details.

3. Page-Wise Presentation and Certification

SEBI has mandated that each parameter of the disclosure document must begin on a fresh page, ensuring clarity and easy reference. Importantly, only the page(s) containing changes in any parameter will need to be certified by both an independent Chartered Accountant and the Principal Officer of the PMS. This selective certification approach reduces compliance burden while maintaining accountability and authenticity of updated information.

4. Communication and Updating Requirements

Portfolio managers must also ensure that any changes made to the disclosure document are promptly communicated to clients. The updated page(s) must be simultaneously uploaded on the portfolio manager’s website and filed with SEBI within 7 working days of the change. This measure ensures real-time transparency and keeps clients continuously informed of modifications affecting their investments.

5. Conclusion

The simplified disclosure framework introduced by SEBI represents a progressive step toward greater transparency and investor protection in the portfolio management industry. By distinguishing between static and dynamic content, mandating page-wise certification, and enforcing timely communication of updates, SEBI has streamlined the disclosure process while reinforcing compliance and accountability. This initiative will not only improve investor confidence but also strengthen the governance framework within the PMS ecosystem.

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