Regular plan vs direct plan mutual fund
Every mutual fund scheme offered by an asset management company (AMC) in India is required to provide two separate plan options: a regular plan and a direct plan. The Securities and Exchange Board of India (SEBI) mandated the availability of direct plans through a circular dated 22 October 2012, effective from 1 January 2013. The two plans invest in an identical portfolio of securities under the same fund manager, but differ in the expense ratio charged to investors, reflecting the presence or absence of distributor commission.
Understanding the distinction between the two plans is foundational to mutual fund investing in India, because the cost differential, compounded over multi-year investment horizons, produces materially different corpus outcomes. This article explains the structural difference, the regulatory framework, the quantitative impact on returns, the intermediary ecosystem, and the practical considerations that influence which plan an investor accesses.
Regulatory background
SEBI’s circular SEBI/IMD/CIR No. 18/198647/2010 initially discussed fee structures; the specific mandate for direct plans emerged from the circular CIR/IMD/DF/21/2012 dated 22 October 2012. The circular required every SEBI-registered mutual fund to offer a separate direct plan for direct investments made by investors without routing through a distributor or agent. AMCs were required to use the suffix “Direct” in the scheme name (e.g., “Axis Bluechip Fund - Direct Plan - Growth”) to distinguish direct plan options from regular plan options.
AMFI maintains separate International Securities Identification Numbers (ISINs) and separate net asset values (NAVs) for the regular plan and direct plan of every scheme. Since both plans invest identically, the NAV difference between the two plans at any point in time reflects the accumulated effect of the difference in expense ratios over time.
Structure of expense ratio
The total expense ratio (TER) of a mutual fund scheme covers fund management fees, administration costs, marketing and distribution expenses, registrar and transfer agent fees, custodian charges, statutory levies, and other operational expenses. SEBI prescribes maximum TER limits by scheme category under Regulation 52 of the SEBI (Mutual Funds) Regulations, 1996, as amended.
Regular plan TER
In a regular plan, the TER includes a distribution commission or trail commission paid to the mutual fund distributor (MFD) or bank who sold and services the investment. This commission is not paid directly by the investor as a visible charge; instead, it is embedded within the scheme’s expense ratio. The trail commission typically ranges from 0.25% to 1.5% per annum depending on the fund category, the specific distributor, and whether the investment is a new inflow or existing AUM.
Illustrative regular plan TERs (approximate, as of 2023-24) by category:
| Fund category | Typical regular plan TER |
|---|---|
| Large-cap equity fund | 1.5% to 1.9% per annum |
| Mid-cap equity fund | 1.7% to 2.1% per annum |
| Small-cap equity fund | 1.8% to 2.2% per annum |
| ELSS | 1.5% to 2.0% per annum |
| Flexi-cap equity fund | 1.5% to 2.0% per annum |
| Index fund (Nifty 50) | 0.5% to 1.0% per annum |
| Liquid fund | 0.4% to 0.7% per annum |
| Debt short-duration fund | 0.7% to 1.2% per annum |
Direct plan TER
The direct plan TER excludes the distributor commission component. The remainder (fund management fee, administrative costs, statutory levies) constitutes the direct plan TER. SEBI’s regulations on maximum TER do not separately cap direct and regular TERs; they require the direct plan TER to be lower than the regular plan TER of the same scheme.
Illustrative direct plan TERs (approximate, as of 2023-24) by category:
| Fund category | Typical direct plan TER |
|---|---|
| Large-cap equity fund | 0.5% to 0.9% per annum |
| Mid-cap equity fund | 0.6% to 1.0% per annum |
| Small-cap equity fund | 0.6% to 1.1% per annum |
| ELSS | 0.6% to 1.1% per annum |
| Flexi-cap equity fund | 0.5% to 1.0% per annum |
| Index fund (Nifty 50) | 0.05% to 0.2% per annum |
| Liquid fund | 0.15% to 0.35% per annum |
| Debt short-duration fund | 0.25% to 0.7% per annum |
NAV differential
Because the regular plan incurs a higher expense ratio, its daily NAV grows at a slower rate than the direct plan NAV for the same scheme, even though both plans hold identical securities. The NAV gap between the direct and regular plans widens progressively over time.
For a scheme where the direct plan TER is 0.75% per annum and the regular plan TER is 1.75% per annum, the difference is 1.0% per annum. On a 15-year investment at a gross pre-expense return of 12% per annum:
| Scenario | Annual return (net of TER) | Rs 1 lakh grows to |
|---|---|---|
| Direct plan (TER 0.75%) | 11.25% | Rs 4,76,000 (approx.) |
| Regular plan (TER 1.75%) | 10.25% | Rs 4,20,000 (approx.) |
| Difference | 1.0% per annum | Rs 56,000 (approx.) |
The exact differential depends on the specific TER gap, the investment horizon, and the gross return of the scheme. For categories with larger TER gaps (mid-cap, small-cap) and longer investment horizons, the compounding effect is more pronounced.
Key comparison dimensions
| Dimension | Regular plan | Direct plan |
|---|---|---|
| Expense ratio | Higher (includes distributor commission) | Lower (no distributor commission) |
| NAV | Lower (due to higher expense deduction) | Higher (due to lower expense deduction) |
| Who can invest | Any investor via distributor, bank, or online platform | Any investor directly via AMC website, Zerodha Coin, Groww, Kuvera, MF Central, AMC portals |
| Advice and service | Distributor provides onboarding, paperwork, portfolio review | No distributor service; investor is self-directed |
| Commissions paid | Yes, trail commission to distributor from TER | None |
| Portfolio | Identical to direct plan of same scheme | Identical to regular plan of same scheme |
| Taxation | Same as direct plan | Same as regular plan |
| SEBI regulation | SEBI MF Regulations 1996 + subsequent circulars | Same |
| Lock-in (ELSS) | 3 years | 3 years |
| Exit load | Same as direct plan | Same as regular plan |
| Liquidity | Same as direct plan | Same as regular plan |
Distribution intermediary ecosystem
Mutual fund distributors (MFDs)
MFDs are individuals or entities registered with AMFI under an AMFI Registration Number (ARN). They are authorised to sell regular plan mutual fund schemes and receive trail commissions from the AMC. MFDs are required to pass the NISM Series-V-A: Mutual Fund Distributors Certification Examination before registration. As of 2024, over 1.5 lakh ARN holders are registered with AMFI.
Banks with distribution licences (ARNs) are major regular plan distributors. Nationalised and private banks channel significant SIP and lump-sum flows into regular plans, receiving trail commission income on AUM managed through their distribution networks.
Registered investment advisers (RIAs)
RIAs are SEBI-registered advisers (under SEBI (Investment Advisers) Regulations, 2013) who charge clients a fee for investment advice and are prohibited from receiving distribution commissions. An RIA can advise on both regular and direct plans. Operationally, many RIAs recommend direct plans and charge a separate advisory or platform fee directly to the client, so the total cost to the client may be the direct plan TER plus the RIA fee.
Direct plan platforms
SEBI’s 2013 circular enabled platforms to route investor orders to AMCs without distributor commission, allowing direct plans to be invested in through:
- AMC websites and mobile applications directly
- Zerodha Coin (demat-format holding through CDSL)
- Groww (SOA-format and demat-format)
- Kuvera (SOA-format, algorithmic portfolio review)
- Paytm Money (SOA-format)
- MF Central (CAMS and KFintech joint portal)
- BSE StARMF (BSE-operated MF transaction platform)
Impact on SIP corpus
For systematic investment plans (SIPs), the compounding differential between direct and regular plans grows with the monthly SIP amount and the investment duration.
For a Rs 10,000 monthly SIP in a flexi-cap equity fund, assuming a gross pre-expense return of 13% per annum and a TER differential of 1.0% per annum (direct plan 0.8%, regular plan 1.8%):
| Investment period | Direct plan corpus | Regular plan corpus | Difference |
|---|---|---|---|
| 5 years | Rs 8.6 lakh | Rs 8.3 lakh | Rs 0.3 lakh |
| 10 years | Rs 23.3 lakh | Rs 21.8 lakh | Rs 1.5 lakh |
| 20 years | Rs 1.00 crore | Rs 88.5 lakh | Rs 11.5 lakh |
| 30 years | Rs 3.20 crore | Rs 2.70 crore | Rs 50 lakh |
These figures are illustrative. Actual returns depend on the fund’s performance, the exact TER differential, SIP date execution, and exit load applicability.
Tax treatment
The tax treatment of gains on mutual fund investments is identical for regular and direct plans, since both hold the same securities. Capital gains are classified as:
- Equity-oriented funds (holding more than 65% equity): Short-term capital gains (STCG) at 20% for units held less than 12 months; long-term capital gains (LTCG) at 12.5% with exemption of Rs 1.25 lakh per financial year for units held 12 months or more (post-July 2024 Finance Act rates).
- Debt-oriented funds (holding 65% or more debt): Taxed at the investor’s applicable income tax slab rate irrespective of holding period (post-April 2023 amendment removing indexation benefit).
The higher NAV of the direct plan does not change the tax category or rates. Both plans are eligible for ELSS tax benefits under Section 80C if the scheme is classified as an ELSS.
Switching from regular to direct plan
Investors can switch from a regular plan to the direct plan of the same scheme. A switch is treated as a redemption from the regular plan followed by a fresh purchase in the direct plan, triggering a taxable event on any gains realised on the regular plan units at the time of switch. For ELSS units under lock-in, switching is not possible until the three-year lock-in period expires.
Platforms such as Zerodha Coin (via the “Switch to Direct” workflow) and fund houses’ own portals facilitate this process. The investor receives the direct plan NAV on the purchase leg and is liable for capital gains tax on the regular plan redemption leg.
Practical considerations
Case for direct plans
An investor with the financial knowledge to monitor fund categories, evaluate manager changes, rebalance asset allocation, and handle tax-loss harvesting can benefit from the lower TER of direct plans. Over a 15-20 year equity accumulation phase, the TER saving compounded can amount to a significant percentage of the final corpus.
Direct plan platforms that provide analytics (expense ratio tracking, category diversification, return comparison) reduce the information disadvantage that previously made self-directed investing more difficult.
Case for regular plans
An investor who relies on a distributor for scheme selection, documentation, nominee registration, periodic review, and rebalancing receives advisory and service value from the distributor relationship that may justify the embedded commission. Investors who are unfamiliar with fund categories, asset allocation frameworks, or tax implications may find the distributor’s guidance beneficial.
The trail commission model means the distributor has an ongoing economic interest in the investor’s AUM remaining invested, aligning incentives for long-term holding. However, it may also create incentives to recommend schemes with higher commission rates.
Regulatory transparency
SEBI requires AMCs to disclose the TER for both plans daily on the AMFI website and on the AMC’s own website. Investors can compare the regular and direct plan TERs of any specific scheme directly from AMFI’s TER disclosure portal (amfiindia.com/research-info/fund-data/total-expense-ratio).
SEBI 2018 TER rationalisation
In October 2018, SEBI issued a circular reducing the maximum permissible TER for all equity schemes. The revised slabs are based on AUM:
- First Rs 500 crore: 2.25% for regular equity funds
- Next Rs 250 crore: 2.00%
- Next Rs 1,250 crore: 1.75%
- Next Rs 3,000 crore: 1.60%
- Next Rs 5,000 crore: 1.50%
- On assets over Rs 10,000 crore: 1.05%
Large AMCs managing high AUM are thus required to charge lower maximum TERs. The direct plan TER must be lower than the regular plan TER by at least the distribution commission component.
Summary comparison table
| Attribute | Regular plan | Direct plan |
|---|---|---|
| Expense ratio | Higher (includes 0.25%–1.5% distributor trail) | Lower (only fund management + admin costs) |
| NAV | Lower; diverges further from direct plan over time | Higher; gap widens annually |
| Distributor service | Available | Not applicable |
| Suitable for | Investors who prefer guided advice and managed onboarding | Self-directed, cost-conscious investors |
| Access platforms | Banks, MFDs, online distributors | AMC direct, Coin, Groww, Kuvera, Paytm Money, MF Central |
| Commission model | Trail commission to distributor | None |
| Portfolio | Same as direct plan | Same as regular plan |
| Taxation | Identical to direct plan | Identical to regular plan |
| Exit load | Same as direct plan | Same as regular plan |
See also
- Mutual fund
- Mutual fund industry in India
- AMFI
- SEBI
- Zerodha Coin
- Groww
- Kuvera
- How to switch from regular to direct plan (Coin)
- Mutual fund TER concept
References
- SEBI circular CIR/IMD/DF/21/2012 dated 22 October 2012, Introduction of direct plan in mutual fund schemes.
- SEBI (Mutual Funds) Regulations, 1996, Regulation 52, Maximum total expense ratio limits.
- SEBI circular SEBI/HO/IMD/DF3/CIR/P/2018/169 dated 18 October 2018, Reduction of total expense ratio.
- AMFI, Total Expense Ratio disclosures, amfiindia.com.
- Finance Act 2023, Amendment to Section 112A and debt fund taxation.
- Finance (No.2) Act 2024, Revised capital gains rates applicable from 23 July 2024.