SEBI fund manager qualification and scheme limits (India)

SEBI’s fund manager qualification and scheme limits framework for mutual funds in India prescribes the minimum qualifications required for individuals appointed as fund managers by asset management companies (AMCs), the maximum number of schemes a single fund manager may manage simultaneously, and the disclosure requirements relating to fund manager assignments in the Scheme Information Document (SID) and Statement of Additional Information (SAI). The framework is embedded in the SEBI (Mutual Funds) Regulations, 1996 (particularly Regulation 25) and the SEBI Master Circular, and is administered by the SEBI Investment Management Department.

Qualification requirements

A fund manager appointed by an AMC must possess:

1. Minimum educational qualification: A post-graduate degree or diploma in management, finance, commerce, or economics, or a professional qualification such as Chartered Accountant (CA), Chartered Financial Analyst (CFA), or Company Secretary (CS). SEBI circulars have clarified that NISM (National Institute of Securities Markets) Certification in Mutual Funds (Series-V-A) is additionally required.
2. Minimum experience: At least five years of relevant experience in financial analysis, portfolio management, or securities research.
3. NISM certification: NISM Series-V-B (Mutual Fund Foundation) or the relevant NISM mutual fund module, as prescribed.
4. Fit and proper criteria: The fund manager must satisfy SEBI’s fit and proper criteria, no criminal record, no regulatory disbarment, no conflict of interest that cannot be managed through Chinese wall procedures.

Maximum number of schemes per fund manager

SEBI circular SEBI/HO/IMD/IMD-PoD-1/P/CIR/2022/… (October 2022) codified the limit:

A single fund manager may manage a maximum of 10 schemes simultaneously.

Prior to this explicit cap, AMCs had been assigning fund managers to 15–25 schemes, raising concerns about dilution of attention and potential conflicts in execution decisions across similar mandates.

Exceptions to the 10-scheme limit:

• Dedicated fund of funds schemes (where the fund manager’s role is selecting underlying schemes rather than individual securities): FoF schemes are not counted toward the 10-scheme limit if the underlying investment decisions are delegated to the underlying fund managers.
• Index funds and ETFs: Passively managed schemes may be managed by a single fund manager beyond the 10-scheme limit because the investment decision is rule-based (tracking the index), not discretionary.

For debt fund managers: A separate limit may apply for schemes within the same AMC that share a common investment mandate (e.g., overnight and liquid funds may be assigned to the same manager as they are similar in strategy).

Multiple fund managers per scheme

SEBI permits, and for large schemes encourages, the assignment of two or more fund managers to a single scheme, particularly where:

• The scheme has an equity sleeve and a debt sleeve (e.g., hybrid conservative funds: one equity fund manager, one debt fund manager).
• The scheme has a domestic sleeve and an overseas sleeve.
• The AUM exceeds ₹5,000 crore (SEBI has informally encouraged co-management for operational resilience).

When multiple managers are assigned, the SID must specify which manager handles which portion of the portfolio.

Disclosure requirements

AMCs must disclose fund manager assignments in:

• SID: Name, qualification, years of experience, and list of other schemes managed by the same fund manager.
• SAI: Summary table of all fund managers, their qualifications, and scheme assignments.
• Monthly portfolio disclosure (AMFI website): Name of the fund manager alongside the portfolio.
• Account statement: Currently not mandatory, but AMFI recommends AMCs notify investors of fund manager changes.

A change in fund manager is not a “fundamental attribute” change and does not trigger the mandatory exit window under Regulation 18(15A). However, SEBI guidance requires AMCs to communicate fund manager changes to investors within 30 days on the AMC website and through a press release.

Chinese wall requirements

Fund managers are subject to SEBI’s Chinese wall requirements under the SEBI (Prevention of Insider Trading) Regulations. Specifically:

• A fund manager for an equity scheme may not trade in securities (for personal account) that are under consideration for the scheme’s portfolio.
• Cross-portfolio information sharing between fund managers of different schemes within the same AMC must follow prescribed information barrier protocols.

See also: SEBI insider trading rules for fund managers.

Accountability and designated employee rule

Fund managers are “designated employees” under SEBI’s accountability and designated employee rule, which requires them to invest a specified portion of their compensation in the schemes they manage. This skin-in-the-game requirement (detailed further in the SEBI MF skin-in-game rule) is intended to align fund manager incentives with investor outcomes.

See also

• Mutual fund
• SEBI (Mutual Funds) Regulations, 1996
• Scheme Information Document
• Statement of Additional Information
• SEBI MF skin-in-game rule
• SEBI MF designated employee rule
• SEBI MF insider trading rules
• SEBI Investment Management Department
• Mutual fund industry in India

References

1. SEBI (Mutual Funds) Regulations, 1996, Regulation 25.
2. SEBI Circular on maximum scheme limit for fund managers, October 2022.
3. SEBI Master Circular SEBI/HO/IMD/IMD-PoD-1/P/CIR/2024/137, 27 May 2024.
4. AMFI, “NISM certification requirements for fund managers”, amfiindia.com.