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SEBI / Portfolio Managers

Annual Compliance Audit for PMS — Timeline and Submission Deadlines

A comprehensive guide to annual compliance audit timelines and submission deadlines for Portfolio Managers, covering completion requirements and filing obligations.

25 Jul 20263 min read

Annual compliance audit is a critical regulatory requirement with strict timelines. This article explains the audit timeline, submission deadlines, and compliance obligations.

The Regulatory Framework

Audit Requirement

Portfolio managers must complete the annual compliance audit within six months from the end of each financial year and submit a compliance audit report to SEBI within a period of one month from the date of the audit report.

Performance Audit Requirement

Portfolio managers are required to submit audit reports on firm-level performance data to SEBI within sixty days from the end of each financial year.

Key Deadlines

Financial Year End

The financial year for portfolio managers ends on March 31 of each year. All audit-related timelines are calculated from this date.

Audit Completion Deadline

The annual compliance audit must be completed within six months from the end of each financial year. This means the audit must be completed by September 30 for the financial year ending March 31.

Audit Report Submission Deadline

After completion, the audit report must be submitted to SEBI within a period of one month from the date of the audit report, but no later than October 31 for the preceding financial year.

Performance Audit Report Deadline

Portfolio managers are required to submit audit reports on firm-level performance data to SEBI within sixty days from the end of each financial year.

Summary of Deadlines

RequirementCompletion DeadlineSubmission Deadline
Annual Compliance AuditSeptember 30 (within 6 months of March 31)October 31 (within 1 month of audit completion)
Performance AuditSeptember 30 (within 6 months of March 31)60 days from end of financial year
Confirmation of Compliance-60 days from end of financial year

Compliance Requirements

Audit Report Contents

The audit report must specify:

  • Each provision of the PMS Regulations
  • Compliance status for each requirement
  • Any adverse findings
  • Action taken to address findings

Publication Requirements

Portfolio managers must:

  • Publish status of compliance audit report on website
  • Publish adverse findings of audit, if any, along with action taken
  • Provide compliance audit report to clients

Record Keeping

Audit reports and related documents must be preserved for a minimum period of five years.

Consequences of Non-Compliance

Regulatory Action

Failure to submit audit reports within the prescribed timelines can result in:

  • Enforcement action by SEBI
  • Monetary penalties
  • Restrictions on onboarding new clients

Recent Enforcement

SEBI has taken action against portfolio managers who failed to submit mandatory periodic reports, including net worth certification, corporate governance reports, and portfolio manager compliance reports.

Standardisation of Audit

Uniform Approach

SEBI has decided to standardise the way portfolio managers audit performance data on an annual basis. This ensures consistency across the industry and enables better comparison.

Terms of Reference

APMI, in consultation with SEBI, has specified standardised Terms of Reference (ToR) for the audit of firm-level performance data.

Expert Legal Guidance

Anuj Desai & Associates provides expert legal advisory services on annual compliance audit compliance for portfolio managers. Our securities law experts help clients meet audit deadlines, prepare compliant reports, and ensure regulatory compliance. Contact us for guidance on annual compliance audit and other regulatory matters.


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