A new ₹25 lakh investment route has just entered India’s wealth-management landscape.
On September 24, 2026, the Securities and Exchange Board of India (SEBI) approved PRIM — Portfolio Managers Route for Investing in Mutual Fund Units as part of its overhaul of the portfolio-management framework.
PRIM will allow portfolio managers to construct portfolios using direct plans of Mutual Funds, including ETFs, index funds and Specialised Investment Funds (SIFs) offered by Indian asset management companies.
The number attracting immediate attention is the entry threshold:
PRIM Minimum Investment: ₹25 Lakh
That is half the ₹50 lakh minimum generally applicable to conventional Portfolio Management Services (PMS).
But for investors, the more important question is:
If you can already invest in Mutual Funds yourself, why would you put ₹25 lakh into PRIM?
That is where the new framework becomes interesting.
PRIM is not primarily about gaining access to Mutual Funds. Investors already have access to them.
Its potential value lies in outsourcing portfolio construction, fund selection, asset allocation, monitoring and rebalancing to a professional portfolio manager.
So the real comparison is not simply:
PRIM vs Mutual Funds.
It is:
A professionally managed Mutual Fund portfolio vs building and managing your own Mutual Fund portfolio.
Let us understand the difference.
What Is SEBI PRIM?
PRIM stands for Portfolio Managers Route for Investing in Mutual Fund Units.
Under the framework approved by SEBI on September 24, 2026, portfolio managers will be able to offer managed portfolios using direct plans of eligible Mutual Fund products, including ETFs, index funds and SIFs.
The minimum investment per client is ₹25 lakh.
It is important to understand what PRIM is not.
PRIM is not a new category of Mutual Fund.
Instead, it creates a portfolio-management structure around Mutual Fund investments.
In simple terms, the underlying investments may be Mutual Funds and related eligible products, while a portfolio manager takes responsibility for constructing and managing the overall portfolio within the applicable regulatory framework.
Why Does the ₹25 Lakh Minimum Matter?
Traditional PMS generally requires a minimum investment of ₹50 lakh.
PRIM reduces the entry threshold for this Mutual Fund-focused portfolio-management structure to:
₹25 lakh
That potentially creates a middle ground between two approaches.
At one end is an investor who independently selects and manages Mutual Funds.
At the other is a conventional PMS investor meeting the ₹50 lakh minimum, where the portfolio manager has access to a wider permitted investment universe.
PRIM sits differently.
It provides a route through which an investor with ₹25 lakh or more can potentially delegate management of a portfolio built primarily using eligible Mutual Fund products.
But a lower minimum does not automatically make PRIM a better investment option.
Investors still need to understand:
What additional service am I receiving, what am I paying for it, and do I actually need it?
PRIM vs Mutual Funds vs Traditional PMS
| Feature | DIY Mutual Fund Portfolio | PRIM | Traditional PMS |
|---|---|---|---|
| Minimum investment | No ₹25 lakh PRIM minimum | ₹25 lakh | Generally ₹50 lakh |
| Portfolio allocation | Investor decides | Portfolio Manager | Portfolio Manager |
| Investment universe | Mutual Funds selected by investor | Eligible direct-plan MFs, ETFs, index funds and SIFs | Wider permitted investment universe |
| Professional portfolio-level management | Not automatically included | Yes | Yes |
| Rebalancing responsibility | Investor | Portfolio Manager | Portfolio Manager |
| Direct Mutual Fund plans | Investor can choose them independently | Yes | Depends on strategy |
| Portfolio-management fee | None for a self-managed portfolio, though scheme expenses apply | Applicable | Applicable |
| Typical use case | Investor comfortable managing own MF portfolio | ₹25 lakh+ investor seeking professional portfolio construction | Higher-ticket investor seeking conventional PMS |
The critical difference is therefore not merely what you invest in.
It is:
Who makes the portfolio-level decisions?
What Can PRIM Invest In?
The new framework permits PRIM portfolios to invest through direct plans of Mutual Funds, including:
- Mutual Fund schemes
- ETFs
- Index funds
- Specialised Investment Funds (SIFs)
The use of direct plans is significant.
Direct Mutual Fund plans do not contain the distributor commission structure associated with regular plans.
However, that does not make PRIM cost-free.
PRIM introduces a separate portfolio-management layer, so investors need to evaluate the total cost of the structure, rather than looking only at the expense ratios of the underlying funds.
SEBI has also introduced a safeguard relating to potential conflicts of interest.
Investment in schemes belonging to an affiliated, group or associate AMC will be capped at 25%.
This limits the extent to which a portfolio could be concentrated in schemes connected to the portfolio manager.
How Much Can a PRIM Portfolio Manager Charge?
Cost could become one of the most important factors when comparing PRIM with a self-managed Mutual Fund portfolio.
Under the approved framework:
Fixed management fee: Maximum 1% of client AUM
A performance-based fee model is also permitted.
Consider a simple illustration.
If an investor places ₹25 lakh under PRIM and the portfolio manager charges the maximum 1% fixed management fee:
₹25,00,000 × 1% = ₹25,000 per year
This is only a simplified illustration of the portfolio-management fee.
The underlying Mutual Fund schemes will continue to have their own expense ratios, and applicable taxes and other permitted expenses may also need to be considered.
That leads to a crucial question:
Is the portfolio-management service worth the additional cost?
For some investors, it may be.
For others, it may not be.
Mutual Funds Already Have Fund Managers. Why Does PRIM Need Another Manager?
This is perhaps the most interesting question created by PRIM.
A Mutual Fund itself already has a professional fund manager.
So why put another portfolio manager above those Mutual Funds?
Because the two managers perform different functions.
A Mutual Fund manager manages the securities inside one particular scheme.
A PRIM portfolio manager manages your allocation across different schemes and eligible products.
For example, an investor could potentially have exposure across:
- Large-cap equity
- Mid-cap equity
- Small-cap equity
- Debt
- Gold
- International markets
- Index strategies
- SIF strategies
Each underlying fund may already be professionally managed.
But someone still has to decide:
How much should go into each category?
Which funds should be selected?
Are multiple funds creating unnecessary overlap?
Has a market rally made the portfolio more aggressive than intended?
When should the portfolio be rebalanced?
This portfolio-level decision-making is where PRIM seeks to add another layer of professional management.
Riddhi Siddhi Share Brokers has previously explored the asset-allocation question in detail in our guide:
Small Cap, Mid Cap, Gold or International: Where Should Your SIP Go in 2026?
The underlying principle is similar: choosing an investment product is only one part of building a portfolio.
Is PRIM Better Than Building Your Own Mutual Fund Portfolio?
There is no universal answer.
PRIM may address a genuine need for some investors, but having ₹25 lakh available to invest does not automatically mean an investor requires professional portfolio management.
Consider two different investors.
Investor A: The DIY Investor
This investor understands asset allocation, can evaluate Mutual Fund categories, monitors portfolio overlap and has the discipline to rebalance periodically.
Such an investor may reasonably ask:
Why should I pay an additional management fee for something I am comfortable managing myself?
That is an important consideration.
Investor B: The Investor Who Wants to Delegate
Another investor may have accumulated substantial investible assets but may not want to continuously decide:
- Which funds to own
- How much to allocate to each asset class
- When to rebalance
- Whether portfolio risk has increased
- Whether funds overlap significantly
- How different investments fit together
For such an investor, professional portfolio construction, monitoring and accountability may have value.
PRIM is therefore not automatically “better” than investing in Mutual Funds yourself.
It offers a different management structure.
The Hidden Problem: More Mutual Funds Do Not Always Mean Better Diversification
As portfolios become larger, investors often accumulate more schemes.
One SIP becomes three.
Three funds become seven.
Over time, an investor may own multiple flexi-cap, large-cap, mid-cap, small-cap, index, sectoral, hybrid and international funds.
On paper, that can look highly diversified.
But is it?
Several Mutual Funds can own many of the same underlying stocks.
An investor can therefore own ten funds while having substantially less diversification than the number of schemes suggests.
There is another issue:
Portfolio Drift
Suppose an investor originally constructs a portfolio with:
60% equity + 40% other assets
After a strong equity-market rally, that allocation could gradually move towards:
70% equity + 30% other assets
The investor has effectively taken on more equity exposure without consciously deciding to increase risk.
Periodic rebalancing can restore the portfolio towards its intended allocation.
Portfolio monitoring and rebalancing are among the areas where professional portfolio management may potentially add value.
PRIM Does Not Make Investment Risk Disappear
The words professionally managed should never be confused with risk-free.
PRIM portfolios remain exposed to the risks associated with their underlying investments.
Depending on portfolio construction, these can include:
- Equity-market risk
- Interest-rate risk
- Credit risk
- Liquidity risk
- Concentration risk
- Market volatility
- Fund-selection risk
- Asset-allocation risk
Professional management cannot eliminate these risks.
Nor does PRIM guarantee better returns than a self-managed Mutual Fund portfolio.
A professionally constructed portfolio can still underperform.
The relevant question is therefore not:
Will PRIM give me higher returns?
A better question is:
Does the portfolio-management service, discipline and structure justify its additional cost for me?
Does Every Investor With ₹25 Lakh Need PRIM?
No.
The minimum investment threshold determines who can potentially access the structure.
It does not determine who needs it.
An investor with ₹25 lakh could still construct and manage a diversified Mutual Fund portfolio independently.
Similarly, an investor with substantially more than ₹25 lakh may still prefer to manage investments personally.
The decision may depend on factors such as:
- Investment knowledge
- Time available for portfolio monitoring
- Portfolio complexity
- Ability to maintain investment discipline
- Understanding of asset allocation
- Need for professional oversight
- Cost sensitivity
- Risk profile
- Financial goals
- Investment horizon
Portfolio size is only one factor.
You Do Not Need ₹25 Lakh to Start Investing in Mutual Funds
The publicity around PRIM’s ₹25 lakh threshold could unintentionally create another misconception.
You do not need ₹25 lakh to begin investing in Mutual Funds.
The ₹25 lakh threshold applies specifically to PRIM.
Regular Mutual Fund investing, including SIPs, remains accessible with much smaller amounts, subject to individual scheme requirements.
For many investors, the more useful starting questions remain:
What am I investing for?
When will I need this money?
How much volatility can I realistically tolerate?
What asset allocation is appropriate for my circumstances?
If you are trying to understand the role of different Mutual Fund categories, read:
Small Cap, Mid Cap, Gold or International: Where Should Your SIP Go in 2026?
And if falling markets or disappointing short-term returns are making you question an existing SIP, read:
Together, these articles explain two important sides of Mutual Fund investing:
Where to allocate → How to remain disciplined
From Mutual Funds to Private Markets: Larger Portfolios Need Different Decisions
As investible wealth increases, the discussion often expands beyond Mutual Funds and listed equities.
Some affluent investors, family offices and institutions also study unlisted shares and pre-IPO opportunities as a separate part of their overall investment universe.
These investments have very different characteristics, including liquidity, valuation and exit risks, and should not be treated as substitutes for Mutual Funds.
For readers researching this segment, our associated private-market platform VaultStreet Advisors publishes educational content on India’s unlisted and pre-IPO market.
For example, institutional and family-office participation in the private market was recently examined in:
₹700 Crore Bet on Pre-IPO: What JM Financial’s New Fund Signals for India’s Unlisted Share Market
The broader lesson applies across Mutual Funds, listed shares and private markets:
A portfolio should be constructed around goals and risk — not simply around the number of available investment products.
Could PRIM Change the Conversation Around Mutual Fund Investing?
For years, much of the retail Mutual Fund conversation has focused on one question:
Which Mutual Fund should I buy?
PRIM may help shift part of the wealth-management discussion towards another question:
How should my entire portfolio be constructed?
That distinction matters.
A collection of individually good funds is not automatically a well-constructed portfolio.
Portfolio construction involves considering:
Asset allocation → Correlation → Concentration → Risk → Time horizon → Rebalancing → Role of each investment
Whether an investor eventually chooses PRIM, builds a Mutual Fund portfolio independently or follows another permitted investment route, these principles remain relevant.
PRIM vs DIY Mutual Funds: 7 Questions to Ask
Before considering PRIM, an investor with ₹25 lakh or more may want to ask:
1. Can I construct my own asset allocation?
If yes, understand precisely what additional value a portfolio manager would provide.
2. Do I actually rebalance my portfolio?
Knowing that rebalancing is important and consistently doing it are two different things.
3. Has my existing portfolio become unnecessarily complicated?
More schemes can create duplication rather than diversification.
4. What will I pay?
Understand the complete fee structure rather than considering only the expense ratios of the underlying Mutual Funds.
5. What exactly will the portfolio manager do?
Understand the investment process, fund-selection methodology, asset allocation, monitoring and rebalancing framework.
6. Am I comparing like with like?
PRIM, conventional PMS and independently held Mutual Funds are structurally different approaches.
7. Am I expecting PRIM to guarantee better returns?
It cannot.
Professional management and guaranteed performance are not the same thing.
Frequently Asked Questions About SEBI PRIM
What is PRIM?
PRIM stands for Portfolio Managers Route for Investing in Mutual Fund Units. It is a new framework approved by SEBI that enables portfolio managers to construct managed portfolios using direct plans of eligible Mutual Fund products, including ETFs, index funds and SIFs.
What is the minimum investment in PRIM?
The minimum investment under PRIM is ₹25 lakh per client.
Is PRIM a new Mutual Fund?
No. PRIM is not a new Mutual Fund category. It is a portfolio-management route using eligible Mutual Fund products.
How is PRIM different from conventional PMS?
PRIM has a ₹25 lakh minimum investment and focuses on eligible direct-plan Mutual Fund products. Conventional PMS generally requires a ₹50 lakh minimum and can operate across a wider permitted investment universe.
Can PRIM invest in ETFs and index funds?
Yes. The approved framework includes direct plans of Mutual Funds, including ETFs and index funds, as well as eligible Specialised Investment Funds.
What is the maximum fixed management fee under PRIM?
The fixed portfolio-management fee is capped at a maximum of 1% of client AUM. A performance-based fee model is also permitted.
Can a PRIM portfolio manager invest entirely in its group’s Mutual Funds?
No. Investment in schemes of affiliated, group or associate AMCs is capped at 25%.
Does PRIM guarantee better returns?
No. Professional portfolio management does not guarantee positive or superior investment returns.
Is PRIM safer than investing directly in Mutual Funds?
PRIM does not eliminate the risks associated with the underlying investments. Risk will depend on the assets, schemes and overall portfolio construction.
Do I need ₹25 lakh to invest in Mutual Funds?
No. The ₹25 lakh minimum applies to PRIM. Ordinary Mutual Fund investments and SIPs can generally be started with substantially smaller amounts, subject to individual scheme requirements.
Bottom Line: What Does PRIM Really Change?
SEBI’s PRIM framework introduces an interesting new structure into India’s wealth-management market.
Until now, an investor considering professional portfolio management faced a significant gap:
Build and manage a Mutual Fund portfolio → or consider conventional PMS with a ₹50 lakh minimum.
PRIM introduces another structure at ₹25 lakh.
But its real proposition is not access to Mutual Funds.
Investors already have that.
The proposition is:
Professional management of a portfolio built using Mutual Fund products.
That makes the most important question surprisingly simple:
Are you paying for access — or are you paying for portfolio management?
If you can confidently select funds, establish an appropriate asset allocation, monitor overlap and rebalance your portfolio, managing Mutual Funds yourself remains an available approach.
If you prefer to delegate those responsibilities, PRIM creates another regulated framework to understand.
Either way, the decision should begin with your financial goals, risk profile, investment horizon and costs — not merely with the arrival of a new investment structure.
Trade in Your Account. Stay in Control. Get Execution Support.
Investing and active trading require different approaches.
While PRIM and Mutual Funds focus primarily on portfolio building, active traders face another challenge:
Monitoring markets, managing positions and executing trades while continuing with their regular work and responsibilities.
For eligible clients who prefer support with this process, Riddhi Siddhi Share Brokers provides Assisted Trading Services / Trade Execution Support.
Your trading happens in your own account.
You continue to have access to your trading account through the web application and mobile application, while Riddhi Siddhi Share Brokers provides Trade Execution Support as applicable.
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Disclaimer
Riddhi Siddhi Share Brokers is an NSE & BSE Authorised Person of a leading stock broker.
This article is for educational and informational purposes only. It does not constitute investment advice, portfolio management advice, research, a recommendation, solicitation or an offer to buy or sell any security, Mutual Fund, PMS, PRIM strategy or other financial product.
Riddhi Siddhi Share Brokers is not offering PRIM through this article.
Mutual Fund investments and securities-market investments are subject to market risks. Past performance does not guarantee future returns. Assisted Trading / Trade Execution Support does not eliminate market risk or assure profits.
Investors should independently evaluate applicable risks, costs, taxation and product documentation and consult an appropriately SEBI-registered adviser or other qualified professional where required before making investment decisions.