How to Read a PMS Disclosure Document (SEBI 2026)

A PMS Disclosure Document is the SEBI-mandated filing every Portfolio Manager must hand you before you sign an agreement. Reading it properly means checking five specific things, not skimming the cover page. SEBI rebuilt the entire format on 9 September 2025 into a Static Section and a Dynamic Section.

The old format let material facts sit buried in dense text. Consider a Surat textile promoter comparing three PMS providers before deploying ₹2 crore. Two of the disclosure documents run past 40 pages, yet the shortest sections are usually litigation history and the material-change date.

Reading a Disclosure Document correctly is not a formality. It is the one place where a provider is legally required to put in writing what the sales conversation left out.

TL; DR

1. Every SEBI-registered PMS must give you a Disclosure Document before you sign, certified by an independent Chartered Accountant.

2. SEBI rebuilt the format on 9 September 2025 into a Static Section and a Dynamic Section.

3. Only the changed pages need fresh certification, and updates must reach clients and SEBI within 7 working days.

4. The sections investors skip most, litigation history and the material-change log, are worth reading first.

5. Roughly 85% of the industry's headline AUM belongs to EPFO and provident funds. A large disclosed AUM number tells you less than it appears to.

6. The Disclosure Document cannot tell you what you will earn. It can only tell you what you are actually being told.

7. The five-point check below takes about ten minutes to run on any provider's document, including Ckredence's own.

Already holding a Disclosure Document from another provider? A second read from a SEBI-registered team costs nothing.

What Is a PMS Disclosure Document, and Why Does SEBI Require It?

A PMS Disclosure Document is what a Portfolio Manager must give you under Regulation 22 of the SEBI Portfolio Managers Regulations, 2020, before you sign. It exists because a sales conversation is not a regulated disclosure. This document is.

Regulation 22(3) requires the format to follow SEBI's prescribed structure. Regulation 22(5) requires an independent Chartered Accountant to certify its contents before it reaches you. Regulation 22(6) requires the manager to host the current version on its own website continuously.

A Surat SME promoter moving from mutual funds into his first PMS is exactly the reader this document is written for. He has heard the pitch already. The Disclosure Document is where he checks it, separate from choosing the right provider in the first place.

 The pattern we see across first-time PMS investors is that they read the fee page and stop there. The fee page is usually the least revealing section in the entire document.

What Changed in SEBI's 2025 Disclosure Document Format?

SEBI's circular of 9 September 2025 replaced the earlier Schedule V format with a two-part structure. Every document filed after that date separates information into a Static Section and a Dynamic Section. Knowing which is which tells you how current the numbers in front of you actually are.

According to SEBI's circular simplifying the Disclosure Document format, the Static Section carries 11 parameters that rarely change. The Dynamic Section carries 5 parameters that need regular updates.

Source: SEBI, as of 9 September 2025

The practical implication is that only the changed pages require fresh certification, not the whole document. If a provider hands you a document where every page carries the same certification date, ask why. Once you have checked the format, the next practical step is usually gathering the documents your own onboarding will require.

What Should You Check in a Disclosure Document's Static Section?

The Static Section rarely changes, which makes it the right place to verify facts against what you were told before you ever saw the document.

1. Business background and promoter details. Confirm the entity name matches the SEBI registration number you were quoted, not a related group entity.

2. Investment approach. Confirm the strategy described matches what was pitched to you, not a generic template description shared across all clients.

3. Risk factors. Confirm market, concentration, liquidity and strategy-specific risks are named individually, not bundled into one paragraph.

4. Fee structure as filed. Cross-check the percentages against your verbal quote. Read the full breakdown on PMS charges and fee structure if anything differs.

5. Exit terms. The Static Section should state the same exit-load slab that governs PMS exit and lock-in rules under SEBI's regulations.

What Should You Check in a Disclosure Document's Dynamic Section?

The Dynamic Section is where a provider's current numbers live, and it is also where a large figure can do more persuading than informing. According to data reported via Cyril Amarchand Mangaldas, India had 515 registered portfolio managers and 2.19 lakh PMS client accounts as of 31 May 2026.

Source: Cyril Amarchand Mangaldas, as of 31 May 2026

Scale alone does not tell you whether a specific manager's disclosed AUM is what it appears to be.

• Client representation and AUM. How many clients, and how that AUM breaks down by category, resident versus NRI, individual versus institutional.

• Financial statements. The manager's own balance sheet, profit and loss, and cash flow, filed for the business itself, not for your portfolio.

• Audit observations. Any findings from the manager's own SEBI inspection, if disclosed.

 The pattern we see when a diamond-trade family reviews a shortlist of providers is that total AUM gets read as a quality signal by itself. Nobody checks what fraction is even the individual, non-institutional book. SEBI fixes the entry point for this conversation regardless of a manager's scale, at ₹50 lakh under the current PMS regulations.

Already Reviewed the Document? Get a Second Read.

A Disclosure Document is written to satisfy SEBI's format, not to answer your specific questions. Our SEBI-registered advisory team can walk through any provider's document with you, including our own.

Can You Verify a PMS Disclosure Document in Five Checks?

Most of what a Disclosure Document reveals is hiding in plain sight. It takes about ten minutes to check, using only the document and what you were told verbally.

 A blank litigation section is normal and not a red flag by itself. A provider who cannot explain their own material-change log when asked directly is the more informative signal of the two.

Who Should Not Rely on the Disclosure Document Alone?

An investor looking for a forward return projection will not find one here, and should not expect to. A Disclosure Document is backward-looking by design: past financials, past AUM, past disciplinary history. It cannot tell you what a strategy will earn, only what the manager has already done and disclosed.

• An investor deciding purely on disclosed AUM size, without checking the EPFO-adjusted, individual-client portion of that figure.

• An investor looking for a single document to answer "which PMS is best." No Disclosure Document is built to produce that answer, and Ckredence does not publish one either.

• An investor unwilling to also verify SEBI or APMI registration independently, since the document itself is self-filed by the manager it describes.

If your real comparison is a PMS against a mutual fund, not two PMS providers, this is the wrong document to start with. A mutual fund has no equivalent filing.

Conclusion

A PMS Disclosure Document is not paperwork to sign past. It is the one place where a Portfolio Manager must put in writing what the sales conversation may only have implied.

The next decision is not whether to read it. It is which of the five checks above you run first.

Holding a Disclosure Document right now, from Ckredence or another manager? Review your mandate with our SEBI-registered team before you commit.