About PMS
Portfolio managers manage client portfolios under the SEBI (Portfolio Managers) Regulations, 2020, whether on a discretionary, non-discretionary or advisory basis. Registration with SEBI is required before offering the service.
How we help. We advise on the entity and the service model, prepare the client agreement and disclosure documents, handle the registration application, and set out the operational compliance the portfolio manager will need to maintain.
Explore PMS mandates
Service models
How the portfolio is managed
Service models
How the portfolio is managed
Discretionary mandates
Portfolio managed at the discretion of the manager.
Non-discretionary mandates
Investment decisions approved by the client.
Advisory mandates
Investment advice and recommendations.
Setting up a PMS
Registration and ongoing compliance
Registration with SEBI
Entity, eligibility and the registration application.
Client agreement and disclosure document
The documents every client relationship rests on.
Operational compliance
What the portfolio manager must maintain after registration.
What our PMS work covers
A PMS registration is judged on the applicant’s structure, people, systems and documents. These are the areas we advise on.
- Registration readinessThe entity and its net worth, the principal officer, compliance officer and key personnel, fit-and-proper status, infrastructure, custody arrangements and the compliance framework. Confirm current figures in the regulations before applying.
- Client documentationThe client agreement, the disclosure document and the strategy description must tell the same story: mandate type, investment approach, fees, risks, conflicts and reporting, and they must match how the strategy is actually run.
- Operating changesA change in ownership or control, a new strategy, revised fees, updates to the disclosure document, or running PMS alongside an AIF or another regulated business. Some changes need intimation to or approval from SEBI.
- Regulatory boundariesPMS, investment advice and pooled funds are different regulated activities. A portfolio manager keeps each client’s assets separate and in the client’s name; pooling is what AIFs and mutual funds are for. We confirm which framework applies to the service you actually deliver.
- Ongoing compliancePeriodic reports to SEBI, client reporting, audit and updates to the disclosure document. Our Fund and Listco Compliance Retainer covers these obligations.
Who does what in a PMS registration
- Finleaf Legal. Eligibility review, preparation of the application, the disclosure document and client agreement, and responses to SEBI’s queries.
- The applicant. The business and strategy, fee and governance decisions, the qualifications and conduct of its people, and the accuracy of the information it provides.
- Chartered accountant and auditor. The net worth certificate and the audit of operations.
- Custodian. Custody of client assets, appointed as the regulations require.
SEBI decides the application and the time it takes. We do not guarantee registration or a timeline, and we do not manage client money or distribute investment products.
How we typically help
This is an illustrative example of how we approach a common situation. It is not a client case study.
An established manager adding a PMS
We advise on how the new service sits alongside the existing business, prepare the client agreement and disclosure documents, and take the portfolio manager registration forward while the manager keeps running the current funds.
Who we work with
- First-time portfolio managers who need a clear, well-documented path to registration.
- Established fund managers adding a PMS alongside existing AIFs or other businesses.
- Family offices and promoter groups considering a managed-account offering.
- Wealth and advisory firms moving from advice to portfolio management.
What to expect when you work with us
- Initial conversationYou tell us about your objectives, your investors and your timeline. We tell you what is feasible and what the regulator will expect.
- Scope and proposalWe set out the workstreams, deliverables and fees in a written proposal, so that you know what is included before you commit.
- Kick-offWe agree on the timeline, the information we need from you and the people on each side who will be responsible.
- DeliveryStructuring, documentation and regulatory preparation move forward together, and we keep you updated at each step.
- Filing and follow-throughWe submit the application, manage regulatory queries and keep you informed until the process is complete.
- Launch handoverWe walk you through post-registration obligations and the compliance calendar, so that you can operate with confidence.
Why clients choose Finleaf
- Fewer advisers to manage. One team and one point of accountability.
- Fewer surprises. Defined scope, defined deliverables and clear next steps.
- Cleaner regulatory journeys. Structures and documents prepared with the approval process in mind from day one.
- Coordinated workstreams. Where the engagement requires it, legal documentation and regulatory preparation can be planned in parallel, subject to dependencies and regulator timelines.
- Continuity. The same team supports you after registration.
Our commitments
- Accuracy. We work from current regulations and circulars, and we tell you where the position is unsettled.
- Candour. We tell you what is feasible, what is risky and what we would do in your position.
- Confidentiality. Your plans, structures and investor details stay protected.
- Accountability. We own the outcome of our workstream and report progress clearly.
Frequently asked questions
Do I need SEBI registration before offering PMS?
Yes. Registration with SEBI is required before offering portfolio management services. We prepare the application and take it through the process.
Do you handle the entire process or only part of it?
Both are possible. Most clients engage us across structuring, documentation, regulatory execution and launch readiness, but you can engage us for a specific stage.
How long does it take to launch?
The timeline depends on the product, how ready your documents and information are, and the regulator’s review. We give a realistic estimate in the proposal and update it as the work progresses.
Do you guarantee regulatory approval?
No adviser can. Approval rests with the regulator. What we do is prepare your structure, documents and filings to the standard the process demands and manage the process closely.
Do you support us after registration?
Yes. Our Launch Readiness workstream and post-incorporation support help you onboard investors and meet your ongoing obligations.
Can you work alongside our other advisers?
Yes. We regularly coordinate with merchant bankers, tax advisers, auditors, trustees and custodians, and we can work with the advisers you already have.
Do you manage money or distribute investment products?
No. Finleaf provides legal and regulatory advisory services. We do not manage funds or distribute investment products.
How do I get started?
Share a short brief about your fund or offering. We will revert to discuss scope and next steps.
Speak to Finleaf
Planning a fund, a PMS or a listing? Let’s structure it properly from the start.