Read the Disclosure Document before you invest
Regulation 22 of the SEBI (Portfolio Managers) Regulations, 2020 requires us to provide you with the Disclosure Document at least two days before you sign the client agreement. It contains the full fee schedule, all risk factors, related-party disclosures, litigation history and audited performance. If anything on this website appears to conflict with the Disclosure Document, the Disclosure Document prevails.
Documents & policies
Filed with SEBI under Regulation 22 of the SEBI (Portfolio Managers) Regulations, 2020. Contains fees, risk factors, performance and related-party disclosures.
A working spreadsheet for computing management and performance fees under each option, with the SEBI-prescribed illustration across return scenarios. Annexure E of our website compliance pack.
Rights, obligations, services and timelines, per the SEBI circular dated 09 December 2021.
Complaints received and disposed of, in the SEBI-prescribed three-table format, updated within 7 days of month end.
Distributors empanelled by the Portfolio Manager. Currently none.
Investor awareness
Prescribed by SEBI and APMI. We reproduce them here because they are the fastest way to spot a portfolio manager who is not behaving properly — including us.
Statutory disclosures
No guaranteed returns
Portfolio management services do not offer any guaranteed or assured return. Neither Redberyl nor any of its partners, employees or distributors is authorised to promise, indicate or imply a return. Any such representation should be reported to our Compliance Officer immediately.
Registration is not an endorsement
Registration with SEBI and any certification obtained from SEBI in no way guarantee the performance of the portfolio manager or provide any assurance of returns to investors.
Direct on-boarding
Investors may on-board directly with Redberyl without the intervention of any distributor or agent. Where you do so, no distribution or placement commission is charged to your portfolio. Contact contact@redberyl.in to on-board directly.
Conflicts of interest
Redberyl maintains a register of related-party transactions and of conflicts between the firm, its partners, its employees and its clients. Employee dealing is subject to pre-clearance and monitoring under our Code of Conduct and the SEBI (Prohibition of Insider Trading) Regulations, 2015. Material conflicts are disclosed in the Disclosure Document.
Litigation and regulatory action
Details of any pending litigation and of any penalty, direction or action taken by SEBI or any other regulatory or government authority against Redberyl, its partners or its Principal Officer are set out in the Disclosure Document and are updated whenever the position changes. State the current position here — e.g. "As at date, there is no pending litigation and no regulatory action."
Beware of impersonation
We communicate only from @redberyl.in email addresses and from the numbers listed on our Contact page. We never ask for your passwords or OTPs, never accept transfers to personal accounts, and do not operate stock-tip channels on WhatsApp or Telegram. Report impersonation to compliance@redberyl.in.
Website content
Nothing on this website constitutes an offer, invitation or solicitation to buy or sell any security, nor investment, legal, accounting or tax advice tailored to any person. Securities named anywhere on this site, if any, are for illustration only and are not recommendations. Information is provided as at the date stated and may become out of date.
Regulatory links
Securities and Exchange Board of India
SEBI list of registered portfolio managers
SEBI Complaint Redress System
Online Dispute Resolution portal
Association of Portfolio Managers in India
Investor education and industry PMS data
SEBI investor education mobile app
Annexure D
Accredited Investor Framework under the SEBI (Portfolio Managers) Regulations, 2020, as applicable to portfolio management services.
The concept of a class of investors (typically termed accredited, qualified or professional investors) who understand financial products and the risks and returns associated with them, and who can take informed investment decisions, is recognised globally by many securities and financial market regulators. Such investors are also considered capable of dealing in relatively riskier products because of their financial capacity and ability to absorb possible losses. Accordingly, issuers and providers of investment products or services are often offered a regulation-light regime when dealing with accredited investors.
SEBI introduced Accredited Investors in India with uniform eligibility criteria and a flexible regulatory framework. SEBI amended the SEBI (Portfolio Managers) Regulations, 2020 with effect from 03 August 2021 and issued circular SEBI/HO/IMD/IMD-I/DF9/P/CIR/2021/620 dated 26 August 2021 (as modified by SEBI circular SEBI/HO/AFD/PoD1/CIR/2023/189 dated 18 December 2023).
Accredited Investor (AI)
Any person who fulfils the applicable eligibility criteria and is granted a certificate of accreditation by an Accreditation Agency. The Central Government and the State Governments, developmental agencies set up under their aegis, funds set up by them, qualified institutional buyers as defined under the SEBI (Issue of Capital and Disclosure Requirements) Regulations, 2018, Category I foreign portfolio investors, sovereign wealth funds and multilateral agencies, and any other entity as may be specified by SEBI from time to time, shall be deemed to be accredited investors and may not be required to obtain a certificate of accreditation.
Accreditation Agency
A subsidiary of a recognised stock exchange or a subsidiary of a depository or any other entity as may be specified by SEBI from time to time. Entities currently recognised by SEBI as Accreditation Agencies:
Large Value Accredited Investor
An Accredited Investor who has entered into an agreement with the Portfolio Manager for a minimum investment of INR 10 crores.
Under the SEBI (Portfolio Managers) Regulations, 2020
| Particulars | Applicability |
|---|---|
| Contents of agreement specified under Schedule IV of the SEBI (Portfolio Managers) Regulations, 2020 shall not apply to the agreement between the Portfolio Manager and the investor | Large Value Accredited Investor |
| The requirement of minimum investment of INR 50 lakhs per client shall not apply | Accredited Investor |
| The Portfolio Manager may offer discretionary or non-discretionary or advisory services for investment up to hundred percent of the assets under management in unlisted securities, subject to the terms agreed between the client and the Portfolio Manager | Large Value Accredited Investor |
| The quantum and manner of exit load applicable to the client as provided under the PMS regulations shall not apply and shall be governed through bilaterally negotiated contractual terms | Large Value Accredited Investor |
| Category | Criteria |
|---|---|
| Individual; Hindu Undivided Family; Family trust; Sole proprietorship | Annual Income ≥ INR 2 Crore; OR Net Worth ≥ INR 7.5 Crore, of which at least INR 3.75 Crore is in financial assets; OR Annual Income ≥ INR 1 Crore and Net Worth ≥ INR 5 Crore, of which at least INR 2.5 Crore is in financial assets |
| Body corporate | Net worth ≥ INR 50 Crore |
| Trust other than family trust | Net worth ≥ INR 50 Crore |
| Partnership firm under the Indian Partnership Act, 1932 | Each partner independently meets the eligibility criteria for accreditation |
| Category | Particulars |
|---|---|
| Individual; Karta of HUF; Sole Proprietor | The value of the primary residence shall not be considered for calculation of net worth |
| Body Corporate | Net worth = (Capital + free reserves) − (Accumulated losses + deferred expenditure not written off) |
| Trustee | Net worth = (Book value of all assets, other than intangible assets) − (Book value of total liabilities) |
The prospective investor shall provide a copy of the Accreditation Certificate to the Portfolio Manager together with an undertaking that:
The Portfolio Manager may obtain additional undertakings that do not dilute the above, shall independently verify accreditation status with the concerned Accreditation Agency, and shall disclose relevant conditions and regulatory concessions before entering into an agreement. The agreement shall cover concessions agreed, conditions for availing them, consequences if the investor becomes ineligible during the tenure, and modalities for withdrawal of Consent.
Forward-looking developments (not yet applicable to Portfolio Managers as on 21 October 2026)
SEBI has notified the SEBI (Portfolio Managers) Regulations, 2026 on 07 October 2026, coming into force from 01 April 2027. Until then, the SEBI (Portfolio Managers) Regulations, 2020 continue to apply. Revised accredited-investor changes under AIF regulations (including additional market-exposure criteria, accreditation routes, LLPs, and PROI deeming) are expected to apply to Portfolio Managers from 01 April 2027, subject to detailed modalities from SEBI. Till then, accreditation for availing PMS shall continue to be obtained from an Accreditation Agency as set out here.
A prospective investor may apply to either Accreditation Agency.
See the user manual and updates on the CVL portal.
See process, eligibility and documentation updates on the NDML portal.
Indicative agency fee schedules (processing plus certification for two- or three-year tenure) are published by CVL and NDML on their portals and may change. Always confirm current charges on the agency website before applying.
Self-certified copies, per Annexure 2 to SEBI circular SEBI/HO/AFD/PoD1/CIR/2023/189 dated 18 December 2023.
| Requirement | Individual / HUF / Sole Proprietorship | Body Corporate | Trust |
|---|---|---|---|
| Proof of identity and address | PAN; and any Officially Valid Document | PAN; and document of incorporation | PAN; and registered trust deed |
| Authorisation for seeking accreditation | Not applicable | Letter from the authorised signatory | Letter from the authorised signatory |
| Proof of financial information (any one; years furnished affect validity) | ITR / ITR acknowledgement(s); or audited financial statements; or current-year statements audited by the statutory auditor (if set up that year); or net worth certificate | Audited financial statements; or current-year statements audited by the statutory auditor (if set up that year); or net worth certificate | Same as body corporate (family trusts may also furnish ITR / ITR acknowledgement) |
| Undertaking | Declaration that submissions are true and correct, failing which the application may be rejected | ||
| Other | Any other document sought by the Accreditation Agency to verify genuineness | ||
