Skip to content
SEBI / Portfolio Managers

Monthly and Periodic Reporting to PMS Clients — What Must Be Included

A comprehensive guide to monthly and periodic reporting requirements for Portfolio Managers, covering what must be included in client reports and regulatory filings.

25 Jul 20264 min read

Portfolio managers have extensive reporting obligations to both SEBI and clients. This article explains the monthly and periodic reporting requirements and what must be included.

Reporting to SEBI

Monthly Report Submission

Portfolio managers are required to submit a monthly report regarding their portfolio management activity, on SEBI Intermediaries Portal within 7 working days of the end of each month.

Report Format

The monthly report must be submitted as per the prescribed format in Annexure A. The format includes:

Type of Services Offered:

  • Discretionary Service
  • Non-Discretionary Service
  • Advisory Service

Data for Discretionary Services:

  • Break-up of clients (domestic and foreign)
  • Assets Under Management
  • Break-up of assets by Investment Approach
  • Funds Inflow/Outflow
  • Transaction Data (sales, purchases, portfolio turnover ratio)
  • Performance Data

Data for Non-Discretionary Services:

  • Similar breakdown for non-discretionary clients

Data for Advisory Services:

  • Client base break-up
  • Value of assets for advisory services

Complaint Data:

  • Complaints received, resolved, and pending

Revised Format

The reporting requirements under the revised formats are applicable for monthly reports to SEBI from April 2022 onwards.

Reporting to Clients

Quarterly Client Reports

Portfolio managers shall furnish a report to their clients on a quarterly basis, as per the prescribed format.

Timeline

Quarterly statements must be sent within 10 days from the end of the quarter.

Contents of Client Report

The quarterly report to clients must include:

A. Account Overview:

  • Name of the Client
  • PAN
  • Address
  • Email and Phone number
  • Unique Client Code
  • Account Activation date
  • Type of Portfolio Management Service
  • Investment approach for the account
  • Benchmark for the investment approach

B. Portfolio Details:

  • Portfolio Allocation by type of security (Equity, Debt, Derivatives, Mutual Funds, etc.)
  • Purchase Value and Market Value
  • Percentage of Assets Under Management

C. Performance of Portfolio:

  • Returns of Client Portfolio (1 Year, 3 Years, 5 Years, 10 Years, Since Inception)
  • Aggregate Returns of Investment Approach
  • Benchmark Performance

D. Transaction Details:

  • Capital Contribution (inflow and outflow)
  • Investments during the reporting period
  • Holding Report as of end of quarter

E. Other Important Information:

  • Deviations from investment approach
  • Details of delay in coupon payments
  • Details of default
  • Details of funds and securities held as collateral
  • Details of other assets outstanding

Co-Investment Reporting

The Co-investment Manager shall submit a monthly report on SEBI Intermediaries Portal within 7 working days. They shall also furnish a report to their clients on a quarterly basis, as per the prescribed format, which includes details of Co-investment services offered by them.

Performance Reporting

TWRR with Benchmark

Portfolio Manager shall present the TWRR of the IA along with the trailing return of the selected benchmark.

XIRR for Investors

Portfolio Manager shall present the Extended Internal Rate of Return (XIRR) for each IA the investor invests in when reporting performance to an investor. This shall be accompanied by the minimum, maximum and median XIRR return generated across all investors.

Disclaimer

A disclaimer must accompany performance disclosure: "Please note that performance of your portfolio may vary from that of other investors and that generated by the Investment Approach across all investors because of 1) the timing of inflows and outflows of funds; and 2) differences in the portfolio composition because of restrictions and other constraints."

Expert Legal Guidance

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


Compliance GuideSEBI PMS monthly reportingportfolio manager periodic reportingPMS client reporting formatSEBI PMS quarterly reportingportfolio manager client reportsPMS reporting requirementsSEBI PMS monthly report to SEBIportfolio manager quarterly client reportPMS reporting format AnnexureSEBI PMS reporting timelineportfolio manager monthly report 7 working daysPMS client quarterly statementSEBI PMS reporting contentsportfolio manager client report portfolio holdingsPMS performance reporting clientSEBI PMS reporting to APMIportfolio manager monthly SEBI portalPMS reporting requirements 2022SEBI PMS Annexure A formatportfolio manager client quarterly report formatPMS reporting cash holdingsSEBI PMS reporting investment approachportfolio manager monthly report discretionaryPMS non-discretionary reportingSEBI PMS report to clients quarterlyportfolio manager report composition valuePMS reporting co-investmentSEBI PMS reporting timeline 7 daysportfolio manager quarterly report 10 daysPMS client report asset allocationSEBI PMS reporting format revisedportfolio manager report transactionsPMS report beneficial interestSEBI PMS report expensesportfolio manager report risk foreseenPMS report default paymentsSEBI PMS report distributor commission
Share

Related insights

Work with ADA

Ready to talk to an advisor?

Book a consultation and get a clear, considered view from a team that handles audit, tax, regulatory and cross-border work under one roof.