Every SEBI registered Portfolio Manager (PMS) needs to issue a Disclosure Document. The disclosure document has to be provided to the client prior to entering into the PMS agreement as well as display the same on the website.
The ‘Model Disclosure Document’ format was given in Schedule V of the SEBI (Portfolio Managers) Regulations, 2020.
To enable ease of doing business for portfolio managers and to enhance information dissemination to investors, on June 18, 2025, SEBI approved restructuring of the Disclosure Document.
On September 9, 2025, in consultation with the Association of Portfolio Managers in India (APMI), SEBI issued a circular introducing a simplified template of the Disclosure Document.
The circular is effective with immediate effect.
Here is a summary of the circular.
Key Change
The new template retains all Schedule V parameters. However, the Disclosure Document is now divided into two sections:
#1 – Static Section: For details which do not change frequently (e.g., firm info, investment philosophy).
#2 – Dynamic Section: For content that undergoes frequent changes (e.g., performance, fees).
Action Points for Portfolio Managers
#1 – The portfolio managers have to revise the template and each parameter of the Disclosure Document have to begin on a new page.
#2 – Only the page(s) containing change(s) in any parameter would be required to be certified by an independent Chartered Accountant and the Principal Officer of the PMS.
#3 – Within 7 working days from the date of changes, the updated pages of the Disclosure document –
- need to be circulated to the clients,
- have to be uploaded on the website of the portfolio manager and
- have to be filed with SEBI.
The changes are aimed to provide operational convenience to the Portfolio Manager as well as provide ease of understanding to the investors.
The Portfolio Managers are required to review and align the document with static/dynamic sections, and ensure timely updates.
Click here to view the format of the updated Disclosure Document.