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SEBI / Portfolio Managers

Performance Reporting to APMI/SEBI — Half-Yearly Filing Requirements

A comprehensive guide to performance reporting requirements to APMI and SEBI, including half-yearly filing, monthly submissions, and audit obligations.

25 Jul 20263 min read

SEBI and APMI have established comprehensive performance reporting requirements for portfolio managers. This article explains the filing obligations, timelines, and compliance requirements.

Monthly Reporting to APMI and SEBI

Dual Submission Requirement

Portfolio Managers shall submit the monthly reports to APMI in addition to SEBI within 7 working days from the end of each month.

Purpose of APMI Reporting

APMI shall make available the monthly reports of the Portfolio Managers on APMI website in an intuitive and user-friendly manner facilitating ease of comparison so as to provide access to portfolio level, investment approach level, portfolio manager level and industry level information to all the stakeholders.

Relative Performance Disclosure

APMI shall make available relative performance of each investment approach within the strategy to concerned portfolio manager and also disclose the same on its website.

Performance Audit Requirements

Annual Performance Audit

After SEBI's recent tightening of norms, PMS players are required to conduct a performance audit annually.

Submission Timeline

Portfolio managers must submit a report within 60 days after the end of a financial year.

Audit Standards

SEBI and APMI collaboratively established performance audit standards for portfolio management services providers, effective from October 1, 2023.

Firm-Level Performance Data

The firm-level performance data of Portfolio Managers shall be audited annually. Confirmation of compliance shall be reported to SEBI within sixty days of end of each financial year. The said report to SEBI shall be certified by the Directors/Partners of the Portfolio Manager or by person(s) authorized by the Board of Directors/Partners of the Portfolio Manager.

Half-Yearly Periodic Reports

Reporting Periods

Periodic reports must be submitted for half-yearly periods ending September 30 and March 31.

Submission Deadlines

Reporting PeriodSubmission Deadline
September 30October 30
March 31April 30

Report Contents

The half-yearly report must include:

  • General Information
  • Net worth statement
  • Details of settled and pending disputes
  • Indictment or involvement in any economic offence
  • List of corporate clients
  • Performance of Portfolio Manager in comparison to relevant benchmark indices
  • Enclosures including auditor's certificate

Annual Compliance Audit

Audit Completion

Annual compliance audit must be completed within six months from end of financial year.

Audit Report Submission

Submit compliance audit report to RAASB/SEBI within a period of one month from the date of the audit report but not later than October 31st of each year for the previous financial year.

Publication Requirements

  • 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

Expert Legal Guidance

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


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