SEBI/HO/IMD/IMD -RAC -3/P/CIR/2025/125 — THE SECURITIES AND EXCHANGE BOARD OF INDIA ACT, 1992

CIRCULAR SEBI/HO/IMD/IMD -RAC -3/P/CIR/2025/125 To All Portfolio Managers Association of Portfolio Managers in India (APMI) Madam / Sir , Sub: Format of ‘Disclosure Document’ for Portfolio Managers Regulation 22(3) of SEBI (Portfolio Managers) Regulations, 2020 mandates submission of ' Disclosure Document ' by Portfolio Managers: "The portfolio manager shall provide to the client, the Disclosure Document as specified in Schedule V, along with a certificate in Form C as specified in Schedule I, prior to entering into an agreement with the client as referred to in sub -regulation (1)." As a part of an initiative for ease of doing business, it has been decided, in consultation with the Association of Portfolio Managers of India (APMI), to delete the Schedule V from the SEBI (Portfolio Managers) Regulations, 2020 containing the format of 'Disclosure Document' and issue the same in a simplified manner through this circular. 2.1.The 'Disclosure Document' has been divided into two sections viz. static and dynamic. The format of 'Disclosure Document' along with template is given in Annexure -I. September 9, 2025 2.2.PMS to ensure that each parameter of 'Disclosure Document' begins on a fresh page. Only the page(s) containing change(s) in any parameter would need to be certified by independent Chartered Accountant and Principal Officer of the PMS. The same shall also be highlighted in the communication to clients. 2.3.The updated Disclosure Document Page(s) in which changes are carried out shall be simultaneously communicated to the clients, updated on the website of portfolio manager and filed with the Board within 7 working days from the date of change. 2.4.All other requirements, terms and conditions as enshrined in the SEBI (Portfolio Managers) Regulations, 2020 shall remain