Registering as a PRIM-only portfolio manager: what you need

The 2026 regulations create a lighter registration for firms that want to offer only PRIM. Existing portfolio managers do not need a new registration; they can launch PRIM as a separate investment approach.

Requirements for a PRIM-only registration

Requirement	PRIM-only	Regular portfolio manager
Minimum net worth	₹2 crore	₹5 crore
Liquid assets	At least 10% of the minimum net worth, unencumbered, applies to portfolio managers	Same
Principal Officer	Graduate, CFA or CA with two years' securities-market experience, plus a simplified NISM certification	Any graduate with the prescribed experience and certification
Other staff	A Compliance Officer (not in a dual role) and at least one more employee	Same
SEBI fees	Application fee ₹1 lakh; registration fee ₹10 lakh	Same schedule
Client minimum	₹25 lakh	₹50 lakh

Keeping PRIM apart from distribution

If your firm or group also distributes mutual funds, SEBI requires PRIM activities and clients to be segregated from distribution, except for accredited investors. In practice that means planning which clients you serve through PRIM and which through distribution. See the segregation rule.

What else you will need

• A PMS agreement and disclosure document for your PRIM approach
• Systems to place direct-plan orders, reconcile holdings, calculate fees and report performance
• A grievance process: SEBI expects complaints to be resolved within 21 calendar days
• Cyber-security controls under SEBI's cyber-security framework for regulated entities

Before you apply

Operating details, including custody and order-placement arrangements, will come in a SEBI circular. Check the regulation tracker before you finalise your structure, and take advice from a securities lawyer on entity structure and segregation.

Use the readiness checklist to see where you stand.