Regulatory desk · SEBI document · 24 Sep 2026
At end-August 2026, 27 of 510 reporting portfolio managers held 92.5% of all portfolio-management money
The terms this paper uses
What a portfolio manager is. A portfolio manager is a firm registered with SEBI that manages and operates the portfolio of each of its clients, account by account. It is for clients who hand over a large sum -- the new mutual-fund route described below alone sets a minimum ticket of INR 25 Lakh -- and for large institutions that award mandates, such as the government provident funds HDFC AMC names on its own calls. SEBI's board decisions below are about these firms; the press release does not say which of them each change will bind, or from when.
The other words this paper uses
The four kinds of service. Managers report their money in four kinds: discretionary, where the manager chooses the investments; non-discretionary, where the client signs off each one; advisory, where the manager advises and the client acts; and co-investment. At end-August 2026, 510 managers reported about Rs 44,34,316 crore in all, of which about Rs 37,55,457 crore was discretionary, for about 2,26,039 clients.
How the money is spread. The money sits with very few firms. At end-August 2026, the 27 managers with over Rs 10,000 crore each held 92.5% of it; the 87 with Rs 1,000-10,000 crore held 6.0%; the 174 with Rs 100-1,000 crore held 1.4%; and the 222 with under Rs 100 crore held 0.1%.
The biggest books moved hard. Among the five largest managers at end-August, two books jumped, two fell and one barely moved. HDFC AMC went from about Rs 12,175 crore at end-June to about Rs 6,84,591 crore at end-July 2026. Aditya Birla Sun Life AMC went from about Rs 32,609 crore at end-May to about Rs 6,41,364 crore at end-June. SBI Funds Management fell from about Rs 16,75,277 crore at end-May to about Rs 12,88,868 crore at end-August, down 23.1%, and UTI AMC fell 50.8% over the same months. Darashaw and Company rose 4.7%.
The same managers, twice. Managers come and go from the monthly reports: 512 reported for May and 510 for August. Adding up only the 408 managers that reported in both months gives about Rs 42,32,708 crore at end-May and about Rs 44,10,209 crore at end-August, a rise of 4.2%. All five of the largest books above sit inside that sum, so their swings are part of it.
What SEBI's board decided. On 24 September 2026 SEBI's board approved changes for portfolio managers. Discretionary managers may put up to 10% of a client's money in investment-grade, non-convertible, unlisted debt with the client's consent. Exchange-traded derivatives are allowed up to 1.25 times a client's money. Foreign securities are allowed in both discretionary and non-discretionary accounts. The dealing room requirement is relaxed for managers with under INR 100 Crores.
The mutual-fund route. A new route lets portfolio managers put client money into direct plans of Indian mutual funds, including ETFs, index funds and specialized investment funds. An existing manager offers it as a separate investment approach with a minimum ticket of INR 25 Lakh. A firm registered only for this route needs a net worth of INR 2 crore, may put at most 25% into schemes of its own group's fund houses, and may charge a fixed fee of at most 1% of the client's money.
Independent fund managers. A new kind of firm, the independent fund manager, will manage and operate client portfolios in association with a registered portfolio manager. One portfolio manager may take on several of them; each can work under only one portfolio manager at a time.
Where this stands. The board has approved the decisions, but the press release prints no date from which they apply and no date by which anyone must act. The one date it gives, July 23, 2026, is when SEBI issued the — a proposal the regulator publishes to invite comment before it decides; it binds nobody yet with draft regulations for public comment; that date binds nobody.
How many managers there are. SEBI's own count of registered portfolio managers was 530 at end-August 2026, up from 491 a year earlier, a rise of 7.9%; 510 managers filed a monthly report for August. Why the count rose is not known.
In one line
SEBI's board has approved wider investment room and cheaper ways in for portfolio managers, a business where 27 of 510 reporting managers held 92.5% of the money at end-August 2026. In our view the new routes matter most to the small managers and to wealth firms thinking of becoming one.
What the paper sets
What does it require, and where does it say it?
Discretionary portfolio managers may put a stated share of client assets under management in investment-grade, non-convertible, unlisted debt securities, with client consent.
Where the paper says it · paragraph 1.2.1.2
“Enabling investment upto 10% of client Asset Under Management (AUM) in investment-grade, non-convertible, unlisted debt securities under Discretionary Portfolio Management Services (DPMS) with client consent.”
Investment in exchange traded derivatives is allowed with greater flexibility, up to a stated multiple of client assets under management.
Where the paper says it · paragraph 1.2.1.3
“Permitting greater flexibility for investment in Exchange traded Derivatives up to 1.25 times of client’s AUM.”
Investment in foreign securities is enabled under both discretionary and non-discretionary portfolio management services.
Where the paper says it · paragraph 1.2.1.4
“Enabling investment in Foreign Securities under DPMS and Non - Discretionary Portfolio Management Services (NDPMS).”
What our read rests on
Who it touches
What we make of it opinion
What do we think this paper does, and why?
HDFC AMC's portfolio-management book went from about Rs 12,175 crore at end-June to about Rs 6,84,591 crore at end-July 2026, while SBI Funds Management's fell from about Rs 16,75,277 crore at end-May to about Rs 12,88,868 crore at end-August. Our guess: HDFC AMC's jump is a government mandate arriving rather than rich clients signing up, since the firm says it won two fixed-income provident-fund mandates, from EPFO and the Seaman's Provident Fund Organization, and that its portfolio book holds a large Government of India mandate, though it does not tie either to July; HDFC AMC saying when that mandate began would confirm it. What we don't know is why SBI Funds' book fell: a mandate moving to another manager, money being paid back to a client, or bonds running off.
Why we think so3 reasons
On what grounds?
- The first reason is how unevenly the money sits. At end-August 2026 the 27 managers above Rs 10,000 crore held 92.5% of it, the 87 with Rs 1,000-10,000 crore held 6.0%, and the 222 under Rs 100 crore held 0.1%, as the chart below shows.
- That shape is the second reason, because it is where the new rules land. The relaxed dealing room, the mutual-fund route with its INR 2 crore net worth and the independent fund managers all speak to the small end, not to the largest books.
- Both of those are about who holds the money; the third is about how to read the total. The same 408 managers grew 4.2% from end-May to end-August, but HDFC AMC, Aditya Birla Sun Life AMC, SBI Funds and UTI AMC swung hard inside that sum, so the total alone does not say whether new clients arrived.
What would prove us wrong3 trip-wires
What would we have to see to drop that read?
- First, SBI Funds' monthly reports showing its fall spread across many clients leaving rather than one large account, which would make the fall about clients, not mandates.
- Second, the 408 managers' 4.2% rise staying about the same once HDFC AMC, Aditya Birla Sun Life AMC, SBI Funds and UTI AMC are taken out, which would mean the mandate moves were not flattering the total.
- Third, the 222 managers under Rs 100 crore still holding about 0.1% of the money well after the rules apply, which would mean the small end was not what they changed.
What to watch3 things to watch
What happens next, and when would we know?
- SEBI's final portfolio manager regulations and the date from which they apply, since the board's press release prints none and firms cannot plan without it.
- UTI AMC's and SBI Funds' monthly reports to SEBI, to see whether the money they lost appears in another manager's book in the same month.
- The number of registered portfolio managers and the count in the smallest band, to see whether wealth firms register for the mutual-fund route once it opens.
Who this touches
Who could benefit and who is at risk, and on what condition?
Opinion · adds no figures the Facts do not hold · every effect is potential and states its condition
| Who | Potential effect | How it reaches them | How sure |
|---|---|---|---|
| Asset managers (AMCs) | ▲ potential benefitif portfolio managers move client money into direct plans through the new route | Money arrives in fund houses' direct plans, ETFs, index funds and specialized investment funds, and the 25% cap on a manager's own group's schemes spreads it across other fund houses. | Inferred · no take-up figure exists until the route opens |
| Deposit & savings apps | ◆ unclearpulls both ways: portfolio clients may now hold up to 10% in unlisted investment-grade debt, a fixed-return choice beside deposits, but only savers with a managed account can use it; whether deposit platforms register as portfolio managers would settle it | A fixed-deposit marketplace competes only at the edge, for savers large enough to open a managed account. | Unresolved · no platform has said it will register |
| Savers & depositors | ◆ unclearpulls both ways: more choice through foreign securities, unlisted debt and derivatives up to 1.25 times the account, but more ways to lose; how many managers use the wider limits would settle it | Clients of discretionary managers can see their accounts hold assets that were not allowed before; the decisions name client consent for the unlisted debt. | Inferred · the rules' final wording is not yet printed |
| Wealth managers & private banks | ▲ potential benefitif a wealth firm registers only for the mutual-fund route, or takes on independent fund managers under an existing portfolio manager | An AI-led wealth manager whose real peers are the 222 managers under Rs 100 crore, or a micro-savings app moving into wealth, can offer managed accounts of direct mutual-fund plans with an INR 2 crore net worth, an INR 25 Lakh ticket and a fee of at most 1%, without the full dealing room a larger manager keeps. | Inferred · the final regulations and their start date are not yet printed |
The evidence
From SEBI's paper, Key decisions taken in the SEBI Board Meeting dated 24th September, 2026, 24 Sep 2026. The paper.
Also in the paper — what the rule is today, who is covered, and by when
Every line below is quoted from that same paper. Open it.
| Where | What it says | The paper's words |
|---|---|---|
| paragraph 1.2.1.5.1 | An existing portfolio manager can offer the mutual fund route through a separate investment approach, accepting a stated minimum ticket size. | “An existing portfolio manager will be able to offer PRIM through a separate investment approach while accepting minimum ticket size of INR 25 Lakh.” |
| paragraph 1.2.1.5.2, item ii | A net worth requirement applies to an applicant registered strictly for the mutual fund route. | “ii. Net Worth INR 2 crore.” |
| paragraph 1.2.1.5.2, item v | A prudential cap applies to investments in schemes of affiliated, group or associate AMCs under the mutual fund route. | “Prudential cap of 25% on investments in schemes of affiliated/group/ associate AMCs.” |
| paragraph 1.2.1.5.2, item vi | Under the mutual fund route the fixed management fee is capped at a stated share of client assets under management. | “Fixed management fee capped at a maximum of 1% of the client's AUM.” |
| paragraph 1.2.1.7.5 | One portfolio manager may affiliate with several independent fund managers, while each independent fund manager can operate under only one portfolio manager at a time. | “One Portfolio Manager may affiliate with several IFMs while one IFM would only be able to operate under one PM at a time.” |
| paragraph 1.2.2.1.2 | The dealing room requirement is relaxed for portfolio managers below a stated size of assets under management. | “Relaxed dealing room requirement for portfolio managers with AUM less than INR 100 Crores.” |
| paragraph 1.3 | After a stakeholder survey and internal analysis, SEBI issued a consultation paper with draft regulations on a stated date for public comments. | “Based on in dustry feedback and internal analysis, SEBI issued a consultation paper including draft Securities and Exchange Board of India (Portfolio Managers) Regulations on July 23, 2026 for public comments.” |
| Figure | Reading | Date | A year earlier | Where from |
|---|---|---|---|---|
| SEBI-registered portfolio managers | 530 | 31 Aug 2026 | +39, +7.9%, against 491 at 31 Aug 2025 | sebi.gov.in |
What else we hold on this
We hold 1 other SEBI consultation papers on this subject, published 23 Jul 2026 — and none of them has become a card. They are the store's, not the paper's: nothing below is cited by the document above.
- Comprehensive Review of SEBI (Portfolio Managers) Regulations, 202023 Jul 2026 · no card written
Go deeper
Whether we have said this before
1 of them became a card.
Audit trail: how this card was checked, and the store's own notes
Status: Clear. the rule is issued and every fact is quoted from SEBI's own text
Exact figures: 12 quoted facts from Key decisions taken in the SEBI Board Meeting dated 24th September, 2026; the warning on every one: none.
Words used on this page, in plain English
- consultation paper
- a proposal the regulator publishes to invite comment before it decides; it binds nobody yet