Introduction
Portfolio Manager is an intermediary registered with the Securities and Exchange Board of India (SEBI) who, under a Portfolio Management Services (PMS) agreement, constructs and actively manages a customized portfolio of securities such as equities, debt instruments, and other permitted assets on behalf of a client either with a discretionary authority or non-discretionary/advisory authority.
The Portfolio Managers Compliance Calendar serves as a structured and time-bound reference tool to help Portfolio Managers and related intermediaries, ensure timely adherence to regulatory obligations as prescribed under the Securities and Exchange Board of India (Portfolio Managers) Regulations, 2020, and various Master Circulars issued by Securities and Exchange Board of India (SEBI) from time to time.
These regulations, supplemented by circulars and operational guidelines, lay down the compliance framework governing the activities of Portfolio Managers (PM) in India, covering areas such as Registration and Capital Adequacy, Client Onboarding and Investment Mandates, Investment Prudentials and Risk Management, Governance and Ethics, periodic reporting to SEBI and clients, as well as governance standards including conflict of interest mitigation, fee structure transparency, and investor grievance redressal. The Calendar is designed to:
- Track periodic compliance requirements (daily, weekly, monthly, quarterly, half-yearly, and annual)
- Ensure timely submissions to SEBI and other regulatory bodies
- Promote accountability among compliance officers and relevant departments.
| S.NO. | Compliance Description | Forms and Formats | Submitted By | Submitted To | Filing Dates | Regulating Document |
|---|---|---|---|---|---|---|
| Yearly Filings/ Intimations | ||||||
| 1 | NetWorth Certificate | NA | Portfolio Manager | SEBI | 30th September |
|
| 2 | Certificate of Audit of Books of Accounts | NA | Portfolio Manager | SEBI | 30th September | SEBI (Portfolio Managers) Regulations, 2020 |
| 3 | Certificate of Compliance with Portfolio Managers Regualtions | NA | Principal Officer | SEBI | 30th May | Master Circular for Portfolio Managers dated July 16, 2025 |
| 4 | Annual Report on Compliance with Applicable SEBI Regulations | NA | Portfolio Manager | SEBI | 30th April | Master Circular for Portfolio Managers dated July 16, 2025 |
| 5 | Annual Compliance Reporting on Audited Firm-Level Performance Data | NA | Portfolio Manager | SEBI | 30th May | Master Circular for Portfolio Managers dated July 16, 2025 |
| 6 | Audit Report on Firm-level Performance Data | NA | Portfolio Manager | SEBI | 30th May | Master Circular for Portfolio Managers dated July 16, 2025 |
| 7 | Digital Accesibilty Compliance | NA | Portfolio Manager | SEBI | 30th April | SEBI Circular on Compliance Guidelines for Digital Accessibility Circular-RPWD (Dated: 31st July, 2025) |
| Quarterly Filings/ Intimations | ||||||
| 8 | Off-site Inspection Data Rerport | Annexure 5B(Offsite Inspection Reporting Formats) | Portfolio Manager | SEBI |
|
Master Circular for Portfolio Managers dated July 16, 2025 |
| 9 | Report on Cyber Attacks, Threats, Cyber Security Incidents and Breaches | NA | Portfolio Manager | SEBI |
|
Cybersecurity and Cyber Resilience Framework (CSCRF) for SEBI Regulated Entities (REs) |
| Monthly Filings/ Intimations | ||||||
| 10 | Monthly Portfolio Management Activity Report | Annexure 5A (Format for Monthly Report to SEBI) | Portfolio Manager | SEBI | Within seven (7) working days of the end of each month | Master Circular for Portfolio Managers dated July 16, 2025 |
| 11 | Monthly Performance Report of Investment Approaches | NA | Portfolio Manager | SEBI | Within seven (7) working days of the end of each month | Master Circular for Portfolio Managers dated July 16, 2025 |
| 12 | Monthly Performance Report of Investment Approaches | NA | Portfolio Manager | APMI | Within seven (7) working days of the end of each month | Master Circular for Portfolio Managers dated July 16, 2025 |
| 13 | Investor Complaints | Annexure 7A(Format of Complaint data to be displayed by the Portfolio Managers) | Portfolio Manager | Website | By 7th of Succeeding Month | Master Circular for Portfolio Managers dated July 16, 2025 |
| 14 | Cash Transaction Report | NA | Portfolio Manager | FIU-IND | Within fifteen (15) days of the end of each month | Master Circular on AML Standards and CFT |
| 15 | Non-Profit Organization Transaction Reports | NA | Portfolio Manager | FIU-IND | Within fifteen (15) days of the end of each month | Master Circular on AML Standards and CFT |
| Event-Based Filings/ Intimations | ||||||
| 16 | Approval for Any Change in Control | Annexure-I (Undertaking to be submitted by the transferee),Annexure-II (Undertaking to be submitted by the Portfolio Manager intending to transfer the PMS business) | Portfolio Manager | SEBI | Immediately | Master Circular for Portfolio Managers dated July 16, 2025 |
| 17 | Material Changes Affecting Registration to SEBI | NA | Portfolio Manager | SEBI | Immediately | SEBI (Portfolio Managers) Regulations, 2020 |
| 18 | Material Change in Disclosure Document | Annexure-I (Disclosure Document) | Portfolio Manager | SEBI & Client | Within 7 working days from the date of change |
|
| 19 | Material Change in Disclosure Document | Annexure-I (Disclosure Document) | Portfolio Manager | Website | Within 7 working days from the date of change | Cybersecurity and Cyber Resilience Framework (CSCRF) for SEBI Regulated Entities (REs) |
| 20 | Change in Identity of Principal Officer | NA | Portfolio Manager | SEBI & Client | Within 7 working days from the date of change | SEBI (Portfolio Managers) Regulations, 2020 |
| 21 | Compliance Certificate of Annual Audit | NA | Portfolio Manager | Client | On Annual basis | SEBI (Portfolio Managers) Regulations, 2020 |
| 22 | Report Non-Compliances under PM Regulations | NA | Compliance Officer | SEBI | Immediately | SEBI (Portfolio Managers) Regulations, 2020 |
| 23 | Report of Vulnerability Assessment & Penetration Testing (VAPT) | Annexure-A (VAPT Report Format) | Portfolio Manager | SEBI | Within 1 month of Completion of VAPT Activity | Cybersecurity and Cyber Resilience Framework (CSCRF) for SEBI Regulated Entities (REs) |
| 24 | Report on Cyber Audit | Annexure-B (Cyber Audit Report Format) | Portfolio Manager | SEBI | Within 1 month of Completion of Cyber Audit | Cybersecurity and Cyber Resilience Framework (CSCRF) for SEBI Regulated Entities (REs) |
| 25 | Self-Certification on Compliance with Cyber Security and Cyber Resilience Framework (CSCRF) | Annexure-P (Reporting Format for Self-certification REs) | Portfolio Manager | SEBI | As and when required | Cybersecurity and Cyber Resilience Framework (CSCRF) for SEBI Regulated Entities (REs) |
| 26 | Evidence for Self Assessment of Cyber Resilience | Annexure-K (Cyber Capability Index (CCI)) | Portfolio Manager | SEBI | Within 15 Days of CCI Assessment Completion | Cybersecurity and Cyber Resilience Framework (CSCRF) for SEBI Regulated Entities (REs) |
| 27 | Cyber Security Incident Falling under CERT-In Cybersecurity Directions | NA | Portfolio Manager | SEBI, CERT-In, NCIIPC | Within 6 hours of noticing or detecting such incident | Cybersecurity and Cyber Resilience Framework (CSCRF) for SEBI Regulated Entities (REs) |
| 28 | Interim Report | NA | Portfolio Manager | SEBI | Within 3 days from the date of reporting such incident | Cybersecurity and Cyber Resilience Framework (CSCRF) for SEBI Regulated Entities (REs) |
| 29 | Mitigation Measure Report | NA | Portfolio Manager | SEBI | Within 7 days from the date of reporting the incident | Cybersecurity and Cyber Resilience Framework (CSCRF) for SEBI Regulated Entities (REs) |
| 30 | Root Cause Analysis (RCA) Report | NA | Portfolio Manager | SEBI | Within 30 days from the date of reporting the incident | Cybersecurity and Cyber Resilience Framework (CSCRF) for SEBI Regulated Entities (REs) |
| 31 | Forensic Audit Report | NA | Portfolio Manager | SEBI | Within 75 days from the date of reporting the incident | Cybersecurity and Cyber Resilience Framework (CSCRF) for SEBI Regulated Entities (REs) |
| 32 | Post-Cyber Incident Vulnerability Assessment and Penetration Testing (VAPT) | NA | Portfolio Manager | SEBI | Within 45 days from the date of reporting post cyber incident activity | Cybersecurity and Cyber Resilience Framework (CSCRF) for SEBI Regulated Entities (REs) |
| 33 | Periodical Performance Reports | NA | Portfolio Manager | Client | As and when required by client |
|
| 34 | Quarterly Investment Report | Annexure 5D(Format of Quarterly Reporting to Client) | Portfolio Manager | Client | On a quarterly basis |
|
Abbreviations
| S.NO. | Particular | Description |
|---|---|---|
| 1 | SEBI | Securities and Exchange Board of India |
| 2 | APMI | Association of Portfolio Managers of India |
| 3 | CSCRF | Cyber Security and Cyber Resilience Framework |
| 4 | VAPT | Vulnerability Assessment and Penetration Testing |
| 5 | RE | Regulated Entity |
| 6 | RCA | Root Cause Analysis |
| 7 | CERT-In | Indian Computer Emergency Response Team |
| 8 | NCIIPC | National Critical Information Infrastructure Protection Centre |
| 9 | CCI | Cyber Capability Index |
| 10 | PM | Portfolio Manager |
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Disclaimer
The information provided in this article is intended for general informational purposes only and should not be construed as legal advice. The content of this article is not intended to create and receipt of it does not constitute any relationship. Readers should not act upon this information without seeking professional legal counsel.