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What is PMS? Portfolio management services 2026

By Flock Research · Filings research desk

To answer what is PMS plainly: PMS, or portfolio management services, is a SEBI-regulated product where a licensed portfolio manager runs a portfolio of securities on your behalf, held in your own demat account. It is meant for larger investors, carries a 50 lakh rupee minimum, and comes in three mandate types. It is not a pooled retail product like a mutual fund, and it does not publish its holdings to the public. This guide is not investment advice.

Definition

PMS (portfolio management services)

is a SEBI-regulated arrangement where a licensed portfolio manager builds and runs a portfolio of securities for a single client, held in that client's own demat account rather than a pooled fund. The 2020 rules set a 50 lakh rupee minimum investment. Source: SEBI.

What is PMS, and who can invest in one?

A portfolio management service sits under the SEBI (Portfolio Managers) Regulations, 2020. Because it is built for investors who can commit larger sums, SEBI sets a high entry floor. The minimum investment is 50 lakh rupees per client, up from 25 lakh rupees before the 2020 rules. The portfolio manager itself must hold a net worth of at least 5 crore rupees, raised from 2 crore rupees by the same rules.

50 lakh rupees

Minimum investment per client in a PMS, raised from 25 lakh under the 2020 rules

Source: SEBI (Portfolio Managers) Regulations, 2020

The three types of PMS

SEBI recognises three mandate types, split by who makes the trading decision.

TypeWho decides tradesNotes
DiscretionaryThe portfolio managerManager acts without per-trade sign-off; limited to listed securities, mutual fund units, and money market instruments
Non-discretionaryYou approve each tradeManager proposes, client executes the decision
AdvisoryYou, on the manager's adviceManager only advises; up to 25% of AUM may be in unlisted securities for advisory or non-discretionary mandates

How PMS disclosure differs from public filings

This is the part that matters if you track holdings from public records. A PMS holds securities in your own demat account and reports to you and to SEBI. It does not publish a per-holding portfolio to the open market. That is the opposite of the disclosure regimes Flock reads: a mutual fund publishes its full portfolio monthly, a US manager files a 13F listing its holdings, and every listed company names its large shareholders in its shareholding pattern. A PMS is closer to an AIF on this point: private by design.

So when someone asks what is PMS and whether they can see inside one, the honest answer is that it is a private mandate, not a public filing. You can verify what a mutual fund or a 13F filer holds from the record. You generally cannot do the same for a PMS. Flock works from the public filing record, and what any disclosure means for you is your call to make.

Frequently asked questions

What is the minimum investment in PMS?

The minimum investment in a portfolio management service is 50 lakh rupees per client, raised from 25 lakh rupees by the 2020 rules. The same floor applies whether the mandate is discretionary, non-discretionary, or advisory. Source: SEBI (Portfolio Managers) Regulations, 2020.

What are the three types of PMS?

Discretionary PMS lets the manager trade without checking each decision with you. Non-discretionary PMS needs your approval for each trade. Advisory PMS only gives advice while you execute. All three sit under the same SEBI rules and 50 lakh rupee minimum. Source: SEBI.

Who holds the securities in a PMS account?

You do. In a PMS the stocks sit in your own demat account under your name, not pooled into a common fund. That segregation is a core difference from a mutual fund or an AIF, where investors hold units of a shared pool. Source: SEBI.

Is a PMS portfolio disclosed to the public?

No. A portfolio management service reports to its client and to SEBI, not to the open market. Unlike a mutual fund, which publishes its full holdings monthly, a PMS does not put a per-holding portfolio into the public record. Source: SEBI, AMFI.

Flock tracks these filings, sourced, dated, and linked back to the original. See what smart-money entities disclosed, without the guesswork about what it means.

Disclosures shown are public regulatory filings. Data may be delayed or incomplete. Smart-money entities may no longer hold positions shown. Not investment advice.

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