What Happens to Your PMS If the Fund Manager Shuts Down?

Ishaan Agrawal
Founder, PMS Sahi Hai
Published 10 Aug 2026Updated Aug 2026 10 min read
The short answer

In a Portfolio Management Service (PMS), your stocks and cash sit in your own demat and bank account, not in a pooled fund — so if your portfolio manager shuts down, there's nothing to "unwind." A SEBI-registered custodian, independent of the manager, already holds your securities in your name. Since October 2025, SEBI also has a formal circular governing how one portfolio manager's business (and its clients) can transfer to another, with prior regulatory approval required. None of this means a shutdown is friction-free — the rules leave real gaps around individual opt-outs, tax treatment of transfers, and provider-specific timelines — but it does mean your money isn't trapped just because your manager exits the business. This article walks through exactly what happens, using SEBI's actual regulations, a live 2025 enforcement case, and a comparison to how AIFs and mutual funds handle the same scenario.

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Disclosure

PMS Sahi Hai is a distributor of Portfolio Management Services and Alternative Investment Funds, APMI-registered (Registration No. APRN08358). This article is for education only and is not investment advice, a recommendation, or an offer to buy or sell any security. Investments in securities markets are subject to market risks; read all scheme-related documents carefully. Past performance is not indicative of future results. Consult your advisor before investing.

Written by
Ishaan Agrawal
Founder, PMS Sahi Hai

Ishaan founded PMS Sahi Hai to make India's PMS, AIF and GIFT City markets legible to serious investors — comparing every SEBI-registered manager on the same comparative basis, with no shelf products and no commission bias.

Frequently asked

Is PMS safe in India?

Ans: PMS is regulated by SEBI, and the core protection is structural: your securities and cash sit in your own demat and bank account, not in a pooled fund, and a SEBI-registered custodian — kept separate from the portfolio manager — holds your securities in custody. That doesn't eliminate market risk or the risk of manager underperformance, but it does mean a portfolio manager's business failure doesn't automatically put your holdings at risk the way, say, an unsecured company bankruptcy would.

Can I lose all my money if my PMS provider shuts down?

Ans: Losing your money specifically because your provider shuts down is unlikely, since your securities are already registered in your own name and held by an independent custodian, not the portfolio manager itself. You can still lose money from ordinary market movements or investment decisions made before the shutdown — that risk never goes away — but the shutdown event itself isn't what puts your capital at risk.

Who actually holds my securities in a PMS?

Ans: Your securities are held in your own individual demat account, and SEBI (Portfolio Managers) Regulations, 2020 require every portfolio manager offering discretionary services to appoint an independent, SEBI-registered custodian to hold and safeguard them. The portfolio manager itself never takes custody or ownership of your assets — it only has trading authority under a Power of Attorney.

What happens to my Power of Attorney if my portfolio manager shuts down?

Ans: A Power of Attorney only authorizes your portfolio manager to place trades on your behalf — it never transfers ownership of your assets. If the manager exits the business, that authority effectively ends with the relationship, and you (or a new manager you choose to appoint, under a fresh POA) regain full control over trading decisions on the securities already sitting in your demat account.

Do I have to pay tax if my PMS account is transferred to a new manager?

Ans: This is a genuine open question: neither SEBI's regulations nor its October 2025 circular on PMS business transfers spell out the tax treatment of an involuntary manager-to-manager transfer. If this happens to you, it's worth confirming directly with a tax advisor and your new portfolio manager rather than assuming either way.

How do I check if a PMS provider is SEBI-registered?

Ans: Every SEBI-registered portfolio manager has a registration number you can verify directly on SEBI's website before investing, rather than relying on a claim made in a pitch deck. As of early 2026, SEBI's data shows 506 registered portfolio managers — the highest count in over a decade — so checking the specific registration number of the firm you're considering is a quick, meaningful step.

What is the minimum investment required for PMS?

Ans: The minimum investment for Portfolio Management Services in India is ₹50 lakh, as mandated by SEBI. That's significantly higher than mutual funds, which is one reason PMS is positioned for HNI (high-net-worth individual) investors rather than mass-retail investors.

What happens to my AIF if the fund winds up before its tenure ends?

Ans: Unlike PMS, an AIF is a pooled trust, so winding one up follows a formal process under Regulation 29 of the SEBI (Alternative Investment Funds) Regulations, 2012 — typically triggered by the fund's tenure expiring, a SEBI direction, or a resolution passed by 75% of investors by value. Once triggered, the fund enters a liquidation period of up to 12 months to sell down positions and distribute proceeds, and for trust-structured AIFs, the trustee can also initiate this process directly if it believes doing so serves investors' interests.

How is PMS shutdown risk different from AIF shutdown risk?

Ans: The difference comes down to structure. In a PMS, you individually own the underlying securities in your own demat account, so if the manager exits, there's nothing to unwind — your holdings are already yours. In an AIF, your money is pooled with other investors' into a trust, so winding it up means liquidating the fund's collective portfolio and distributing proceeds proportionally — a process that takes months and depends heavily on how liquid the fund's underlying investments are.

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