Description

SEBI simplifies disclosure document format for portfolio managers, dividing it into static and dynamic sections for ease of business.

Summary

SEBI has issued a simplified format for the ‘Disclosure Document’ required under Regulation 22(3) of SEBI (Portfolio Managers) Regulations, 2020. The new format divides the disclosure document into static and dynamic sections, allowing portfolio managers to update only changed pages rather than the entire document, thereby reducing compliance burden.

Key Points

  • Schedule V containing the disclosure document format is deleted from SEBI (Portfolio Managers) Regulations, 2020
  • New simplified format issued through this circular in consultation with APMI
  • Disclosure document divided into two sections: static (11 parameters) and dynamic (5 parameters)
  • Each parameter must begin on a fresh page
  • Only pages with changes need certification by independent Chartered Accountant and Principal Officer
  • Updated pages must be communicated to clients, website, and SEBI within 7 working days

Regulatory Changes

  • Deletion of Schedule V from SEBI (Portfolio Managers) Regulations, 2020
  • Introduction of standardized template with 16 classified parameters
  • Modified certification requirements - only changed pages need certification instead of entire document

Compliance Requirements

  • Portfolio managers must use the new disclosure document format as per Annexure-I
  • Each of the 16 parameters must start on a separate page
  • Pages with changes must be certified by independent Chartered Accountant and Principal Officer
  • Updated disclosure document pages must be:
    • Communicated to clients
    • Updated on portfolio manager’s website
    • Filed with SEBI within 7 working days from date of change
  • Changes must be highlighted in client communications
  • All other requirements under SEBI (Portfolio Managers) Regulations, 2020 remain unchanged

Important Dates

  • Effective Date: Immediate effect from September 9, 2025
  • Update Timeline: 7 working days for filing updated pages with SEBI

Impact Assessment

This circular significantly reduces the compliance burden on portfolio managers by allowing partial updates to disclosure documents rather than complete re-certification. The standardized format with clear static and dynamic sections will streamline the documentation process and reduce costs associated with frequent updates. Portfolio managers will benefit from reduced administrative overhead while maintaining transparency standards for investors.

Impact Justification

Simplifies compliance process for portfolio managers without changing core regulatory requirements