NRI PMS Documents Checklist: KYC, Attestation and Accounts

You have picked a strategy, the money is in an Indian bank account, and the portfolio manager has sent a list of papers. Three weeks later the file comes back because the notary's stamp did not carry a designation, or the utility bill was three months old, or the PAN still shows you as a resident.

This guide is about that paperwork and nothing else. It lists every document, says in which form each one is accepted, and names who is allowed to certify it, with the regulator's own text behind each line.

A resident investor can often finish KYC online, using Aadhaar and DigiLocker. A non-resident usually cannot. The identity papers are foreign, the address is overseas, the bank account is a non-resident account governed by RBI, and the person is rarely in India to show originals. Each fact adds a document or a certification.

One caution: regulation sets the floor. A portfolio manager, its custodian and your bank can each ask for more under their own risk policies.

The list of people who may certify a non-resident's papers is older than most investors expect. It comes from a SEBI circular of August 2011 on simplifying account opening, which said that where originals cannot be verified, a non-resident's copies must be certified by specified officials abroad.

In the same year SEBI created KYC Registration Agencies, or KRAs. A KRA stores your KYC record once so that every SEBI intermediary can fetch it instead of collecting papers again.

Tax reporting arrived next. SEBI's investor material records that from January 2016 every investor, resident or not, has had to file a FATCA self-declaration.

Portfolio management got its present rulebook on 16 January 2020, when the SEBI (Portfolio Managers) Regulations, 2020 set the minimum investment at Rs 50 lakh. In April 2020 SEBI allowed verification by video and electronic signatures. On 12 October 2023 it folded every KYC instruction into one Master Circular, still the reference text, and a Master Circular for Portfolio Managers followed on 16 July 2025.

Two recent events matter most to someone living abroad. On 10 December 2025 SEBI allowed existing NRI clients to redo their KYC digitally without being physically in India. On 14 August 2026 it published a consultation paper proposing the same freedom for first-time onboarding of clients in FATF-compliant countries, with comments due by 4 September 2026. As of 7 October 2026 no final circular has followed, so the older rule still governs a new account.

SEBI's Board also approved new Portfolio Managers Regulations on 24 September 2026. They had not appeared as notified on SEBI's website when this was written, so the 2020 Regulations remain the operative text.

SEBI's KYC Master Circular states the non-resident requirement in one sentence: for non-residents and foreign nationals, a copy of the passport, PIO card or OCI card and an overseas address proof is mandatory.

PAN is the unique identifier for every participant in the securities market, whatever the transaction size. The Master Circular tells intermediaries to verify it online with the Income Tax Department without insisting on the original or a copy of the card.

The trap is linkage. A PAN that is not linked with Aadhaar becomes inoperative, and an inoperative PAN fails KYC. SEBI's KYC FAQ is clear that NRIs who do not hold an Aadhaar number are exempt from linking, but only after they update their residential status to non-resident on the income-tax portal. The exemption is not automatic. If your PAN dates from your years in India and the status was never changed, fix this first.

An Indian passport holder gives a copy of the valid passport and the valid visa or residence permit that shows the right to live abroad. A foreign passport holder gives the foreign passport and the OCI card. PIO cards have been deemed OCI cards since 9 January 2015. Merchant Navy NRIs give a Mariner's declaration or a certified copy of the Continuous Discharge Certificate in place of a visa. An expired visa page proves nothing about present status, so check dates before copying.

The overseas address proof is a document that often comes back. SEBI's investor material on NRI investments lists what works: a driving licence, the foreign passport itself if it carries an address, utility bills, a bank statement, or a rent, lease or sale agreement. The Master Circular wants a utility bill to be not more than two months old, and SEBI's investor guidance applies the same two-month limit to a bank statement.

Two smaller rules catch people. A proof in a foreign language needs an English translation. And if your correspondence and permanent addresses differ, proof is needed for both, which is why managers ask for an Indian address proof when you list an Indian permanent address. An Indian passport showing an Indian address cannot double as your overseas address proof.

FATCA is a United States law and CRS a multi-country standard, but the form is an Indian requirement for every investor. You declare your country or countries of tax residence, the tax identification number issued there, and whether you are a US person. SEBI's guidance says US citizens and green card holders must list the USA as a country of residence even if they have since moved.

The reporting duty behind the form sat in section 285BA of the Income-tax Act, 1961 and now sits in section 508 of the Income-tax Act, 2025, which took effect on 1 April 2026. A wrong or missing tax identification number can put a file on hold. Nobody attests a FATCA form; you sign it yourself.

A tax residency certificate is not a KYC document. SEBI's KYC rules do not ask for one. It becomes relevant when you want relief under a tax treaty: section 159(8) of the Income-tax Act, 2025 (section 90(4) of the 1961 Act) lets a non-resident claim treaty benefit only with a certificate of residence from the other country's government, plus prescribed information. A manager who demands one for KYC alone is applying a house rule. How to make a treaty claim is a separate subject.

Attestation solves one problem. The intermediary must see your original documents and verify the copies against them. In India an authorised official does that across a desk, and your own signature on the copies is enough. Abroad, somebody trustworthy has to do it on the intermediary's behalf.

SEBI's August 2026 consultation paper restates who that somebody may be under the current rules:

After attestation the documents are couriered to the intermediary in India.

Intermediaries generally want the attester to mark each page as verified with the original and to add a name, designation, signature and date. A set that lacks any of these can be refused. Ask your manager for its exact wording before the appointment.

Attestation is the fallback, and three situations avoid it. First, you are visiting India: carry the originals to the manager's or depository participant's office, sign the copies yourself, and let the official record that the originals were seen. Second, your KYC record already sits with a KRA as a non-resident and is in order, in which case an intermediary may fetch it and ask only for what has changed. Third, an authorised official of the intermediary visits you and sees the originals, which the rules permit but which you should not count on outside India.

What does not work is self-attestation from abroad with nobody having seen the originals. One KYC technology provider's published analysis names attestation failures as the leading cause of rejected NRI files.

Apostille is not on SEBI's list, and an apostilled passport copy is not what the KYC rules ask for. Apostille belongs to a different job: making a public or notarised document from one country legally usable in another. India has been a member of the Hague Apostille Convention since 2005, and the Ministry of External Affairs says an apostilled document from a member country should be treated as legalised for all purposes in India. That matters for a power of attorney signed abroad, covered below, far more than for KYC copies.

The August 2026 paper would add one more attester: authorised officials of overseas banks with which Indian banks have relationships. Until a final circular says so, a local bank's stamp counts only if it is an overseas branch of an Indian scheduled commercial bank.

In-person verification, or IPV, is mandatory for every registered intermediary. The official who does it records a name, designation, organisation, signature and date on the KYC form. There are two reliefs worth knowing. IPV done by one SEBI-registered intermediary can be relied on by another, so a properly completed NRI KYC at your depository participant should not need repeating at the portfolio manager. And IPV is waived where KYC is completed through Aadhaar authentication or documents come through DigiLocker.

Video KYC, which SEBI calls video in-person verification, has been allowed since 2020. The session is live, with random questions and a time-stamped recording. The difficulty for non-residents is paragraph 51 of the Master Circular. It requires the intermediary's app to geo-tag the session so that requirements such as physical location being in India are met.

That single phrase is why an NRI sitting in Dubai or New Jersey generally cannot complete a brand-new digital KYC today. The December 2025 circular removed the India-location condition only for re-KYC of existing clients, with the safeguard that the GPS location must match the country on the address proof and the app must block spoofed IP addresses.

The August 2026 proposal would change this for first-time onboarding from FATF-compliant countries, with liveness checks, an authorised official on the call and a concurrent audit. The same paper explains why e-sign has not filled the gap: Aadhaar e-sign needs an Indian mobile number for the one-time password, and between June 2025 and June 2026 only about 1.45% of NRI KYC records were based on it.

That leaves three routes today: complete NRI KYC during a trip to India, send an attested physical set from abroad, or rely on an existing, correct non-resident KYC record. Ask the manager which of these it supports before you start.

A PMS account is a bundle of linked accounts, and the papers for each have to agree with one another. SEBI's investor material lists what a non-resident needs to deal in Indian securities: an NRE or NRO savings account, a PIS-designated account where shares are bought on a stock exchange on a repatriable basis, a non-resident demat account and a trading account. The PIS permission letter is issued by an authorised dealer bank. Whether to fund from NRE or NRO, and whether your mandate needs PIS at all, is a separate decision with tax and repatriation consequences; here it is enough that the bank account comes first and everything else is opened against it.

On the PMS side the manager does much of the opening for you. Every portfolio manager must appoint a custodian, and SEBI's Investor Charter in the Master Circular for Portfolio Managers describes onboarding as opening the demat account, funding it from your verified bank account, and mapping it to the custodian. Expect separate forms from the bank, the depository participant and the custodian. Nominee registration is meant to happen with account opening, so decide on nominees before the forms arrive.

For bank verification, SEBI's FAQ says a successful online penny-drop check removes the need for a cancelled cheque. Where the check fails or does not return a joint holder's name, the cheque or a statement is asked for.

The contract papers are the same for residents and non-residents, but a non-resident usually signs them on paper and by courier, so mistakes cost more time.

The PMS agreement. A portfolio manager must sign a written agreement with you before managing a rupee, and Schedule IV of the 2020 Regulations lists what it must contain, from the scope of services and investment objectives to fees, risk factors and taxation aspects such as tax deducted at source. Read the PMS agreement closely for its clauses on tax deduction and termination.

The Disclosure Document. It must be given to you before you sign the agreement and must be available on the manager's website. SEBI does not approve or certify it.

The fee annexure. The agreement must carry a separate annexure listing every fee and charge, illustrated on a sample portfolio of Rs 50 lakh over one year in three scenarios: up 20%, down 20% and unchanged. Where a performance fee applies, clients onboarded on or after 1 October 2024 also get multi-year illustrations. The text must be at least font size 11. You sign this annexure separately and add a note that you have understood the fee structure, handwritten on paper or typed or written with a stylus in digital mode. Without that note the annexure is incomplete and the set comes back.

The MITC. The manager must also give a Most Important Terms and Conditions document, in a standard format, which you acknowledge.

The power of attorney. SEBI's Investor Charter refers to franking and signing a power of attorney so the manager can act on your portfolio. For a non-resident there are two extra layers. RBI restricts what a power of attorney holder may do on your bank accounts: on an NRE account, withdrawals for permissible local payments or remittance to you; on an NRO account, local rupee payments, remittance of current income, or remittance to you, within repatriation limits. And a power of attorney signed abroad has to be made usable in India. The routes usually described are execution before the Indian consulate, or notarisation followed by apostille where the country is a Hague Convention member; which one is accepted is the manager's call. Stamp duty is a state subject, and Indian stamp law generally expects a document executed abroad to be stamped within a short period of reaching India, widely cited as three months. Confirm the exact route with the manager before you sign.

Getting the file right once pays off beyond this one account.

• One KYC serves many accounts. A KRA record that has been validated is portable. The next intermediary can fetch it instead of asking for the same papers.
• One verification can be reused. Because IPV by one SEBI intermediary can be relied on by another, a clean record at the depository participant shortens the manager's work.
• You choose the attester. The list is fixed by SEBI, not by the manager, so you can pick whichever option is nearest or cheapest.
• Costs are visible before you sign. The fee annexure and MITC put every charge in a standard format that can be compared across managers.
• There is a clock. SEBI's Investor Charter gives the manager 14 days from receipt of all requisite documents to open a non-resident PMS account, including demat, bank and trading accounts, subject to review of the documents for accuracy and completeness.
• Later updates are easier. Since December 2025 existing NRI clients can redo KYC digitally from abroad.
• Direct onboarding is an option. Managers must offer onboarding without a distributor and may levy only statutory charges at that point.

Paperwork is the second decision. The first is which strategy the paperwork is for, and that is where PMS Sahi Hai does its work. The site describes itself as India's first AI-powered PMS and AIF marketplace, and its research tool, Nyra, as an AI-powered research platform covering PMS, AIF and GIFT City funds, with more than 900 tracked offerings scored on a single 0 to 10 Nyra Score. The pages are equally clear about what Nyra is not: an analytical tool, not a SEBI-registered investment adviser, whose output is informational and not personalised advice.

For a non-resident, three parts of the site are useful before the first form is signed.

• Compare before you commit. The PMS comparison view lets you filter strategies and set up to four side by side. A PMS agreement and its fee annexure are easier to read when you already know how the same manager's numbers sit against others.
• The NRI hub. The NRI section covers GIFT City funds, treaty positions by country and the US and Canada PFIC question, and it explains the NRE and NRO distinction in a line. That context decides which account type your forms should carry.
• Related reading. The site's guides on the steps an NRI takes to open a PMS account, on the route from overseas funds to an Indian demat account and on the general PMS onboarding process cover the journey that this checklist deliberately leaves out.

One thing should be said plainly. The site's NRI hub outlines a remote process and mentions emailing documents, but it does not publish an itemised document list or attestation rules, and nothing on the site says Nyra collects or checks KYC papers. The KYC itself is done by the portfolio manager, its custodian and the KRA. What the firm offers on the paperwork side is a person to ask: the contact page promises a first reply within two business hours and a 15-minute conversation, with no upfront fees. PMS Sahi Hai operates through Nyra Capital Partners Consultancy Pvt Limited, an APMI-registered distributor (APRN08358). A sensible use of that call is to ask which of the documents above a specific manager insists on, and in what form, before you book a notary.

Most rejections trace back to a rule described above. This table pairs the usual defects with the fix.

Some difficulties are not your mistake and no checklist removes them.

• Fresh digital KYC still needs you in India. Until SEBI finalises its proposal, overseas applicants depend on attested paper and couriers.
• Notarisation is slow. SEBI's own consultation paper calls it "time-consuming" and "cumbersome".
• Requirements are not uniform. A manager, its custodian and your bank may each ask for something the others do not, and none of them is wrong to do so.
• A power of attorney signed abroad adds a legalisation step that has nothing to do with investing.
• Country of residence can narrow your choices. Some Indian fund houses are reported to decline investors resident in the United States or Canada; whether a given portfolio manager accepts you is a question to ask on day one.

Only one part of the timeline is set by a regulator: the 14 days SEBI's Investor Charter allows once every requisite document has been received. Everything before that depends on you, your bank and the attester. Plan in weeks, and start the PAN correction, the attestation appointment and the courier first.

Print the table and write a date against each row.

The paperwork for a non-resident PMS account looks long because four rulebooks touch it: SEBI's KYC norms, SEBI's portfolio manager rules, RBI's account rules and the income-tax reporting regime. Read together they ask for a modest set of papers. The difficulty is form: who certified the passport copy, how old the address proof is, whether the fee annexure carries your note.

Fix the PAN status. Choose the attester from SEBI's list and get the stamp wording from the manager. Decide whether you will verify in India or by attested paper. Line up the bank, demat and contract forms so the account type is the same on all of them. Then send one complete set. If you are still choosing the strategy, compare it on PMS Sahi Hai and put your structural questions to Nyra first; the paperwork should follow the decision, not lead it.

Watch for SEBI's final word on digital KYC for people outside India and for the notification of the new Portfolio Managers Regulations. Until then, the version above is the one your file will be judged against.

This article is general information, not legal or tax advice. Confirm the current requirements with your portfolio manager, your authorised dealer bank and a tax adviser before acting.

Ask your portfolio manager for its non-resident checklist and lay it beside the stage-by-stage table above. Where the two differ, ask which rule the extra item comes from. Fix the PAN status and book the attestation first, then send one complete, correctly certified set.

If you would like a second pair of eyes before that envelope leaves, book a 15-minute call with PMS Sahi Hai. Tell the team where you live, which account you plan to fund from and which strategy you are considering, and use Nyra to compare that strategy with its peers while your notary appointment is pending.