Regulatory Compliance Calendar - INDIA
Portfolio Managers

Lokik Harit
Lokik Harit

Published on: Apr 29, 2026

Priya Gandhi
Priya Gandhi

Updated on: Apr 29, 2026

(1 Rating)
30

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:

  1. Track periodic compliance requirements (daily, weekly, monthly, quarterly, half-yearly, and annual)
  2. Ensure timely submissions to SEBI and other regulatory bodies
  3. 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
  • SEBI (Portfolio Managers) Regulations, 2020
  • Master Circular for Portfolio Managers dated July 16, 2025
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
  • 15th April
  • 15th July
  • 15th October
  • 15th January
Master Circular for Portfolio Managers dated July 16, 2025
9 Report on Cyber Attacks, Threats, Cyber Security Incidents and Breaches NA Portfolio Manager SEBI
  • 15th April
  • 15th July
  • 15th October
  • 15th January
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
  • SEBI (Portfolio Managers) Regulations, 2020
  • Master Circular for Portfolio Managers dated July 16, 2025
  • SEBI Circular on Format of ‘Disclosure Document’ for Portfolio Managers, vide no. SEBI/HO/IMD/IMD-RAC-3/P/CIR/2025/125 dated September 9, 2025
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
  • SEBI (Portfolio Managers) Regulations, 2020
  • Master Circular for Portfolio Managers dated July 16, 2025
34 Quarterly Investment Report Annexure 5D(Format of Quarterly Reporting to Client) Portfolio Manager Client On a quarterly basis
  • SEBI (Portfolio Managers) Regulations, 2020
  • Master Circular for Portfolio Managers dated July 16, 2025

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.

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