Both sit above ordinary mutual funds in ticket size and strategy flexibility, but they're structured very differently — and that difference affects your entry amount, taxation, and even whose name the underlying securities sit in. Here's a factual, side-by-side comparison, sourced to SEBI's current regulations for each.
SIF (Specialised Investment Fund): a SEBI-regulated category launched within an existing mutual fund AMC's framework. You buy units in a pooled scheme — the same basic structure as a mutual fund, just with wider strategy freedom (limited short positions via derivatives, higher single-issuer exposure limits) than a regular mutual fund is allowed.
PMS (Portfolio Management Service): a SEBI-licensed portfolio manager runs a portfolio of individual securities directly in your own demat account — you personally own the underlying shares, not units in a pooled vehicle. Two clients in the same PMS strategy can technically end up holding slightly different stocks or quantities depending on when they joined.
| Parameter | SIF | PMS |
|---|---|---|
| Minimum Investment | ₹10 lakh per PAN, across all SIF strategies at one AMC (not per scheme) — waived entirely for SEBI-accredited investors | ₹50 lakh per client, must generally be maintained even after partial withdrawal |
| Regulatory Framework | SEBI SIF framework (Dec 2024 circular, effective framework from Feb 2025), operating under mutual fund regulations | SEBI (Portfolio Managers) Regulations, 2020 |
| Ownership of Securities | Pooled — you hold units in the scheme, like a mutual fund | Direct — securities sit in your own demat account in your name |
| Structure Options | Open-ended, close-ended, or interval, depending on the strategy | Discretionary (manager decides) or Non-Discretionary (you approve each trade) |
| Distribution | Can be distributed by AMFI-registered Mutual Fund Distributors | Requires a separate SEBI-registered Portfolio Manager relationship — distributors typically cannot sell PMS the way they sell mutual funds/SIFs |
| Taxation | Taxed at the fund level like a mutual fund — LTCG/STCG rules for equity-oriented SIFs, debt-fund taxation rules for debt-oriented ones | Taxed on your own trades — every buy/sell in your PMS portfolio is a taxable event for you personally, reported on your own capital gains statement |
| Fee Structure | Expense ratio charged at the scheme level, capped like mutual fund fee norms | Typically a management fee plus, often, a performance fee (e.g. a share of profits above a hurdle rate) — varies by portfolio manager |
| Transparency | NAV published, holdings disclosed periodically like a mutual fund scheme | You can see your own exact holdings in real time (it's your demat account) — but performance isn't standardised/published the way scheme NAVs are |
| Portability | Redeem and reinvest elsewhere — standard mutual-fund-style liquidity, subject to the specific scheme's structure | Direct securities can sometimes be transferred in-kind to another PMS provider without a full sale, depending on the arrangement |
Note on Direct Plan taxation: LTCG/STCG treatment applies per the tax rules for the SIF's specific category (equity-oriented, debt-oriented, or hybrid) — confirm exact current rates with a tax advisor before investing.
SEBI has floated a consultation paper (July 2026) proposing a new, separate "Mutual Fund-only PMS" category with a lower ₹25 lakh entry threshold — specifically for portfolios that invest only in mutual fund schemes, ETFs, and SIFs, rather than individual stocks. This is a proposal under consultation, not yet a finalised rule — the ₹50 lakh threshold for traditional (direct-equity) PMS remains in effect as of today. Worth watching if it's finalised, since it would meaningfully change where the SIF-vs-PMS entry-ticket gap sits.
This isn't a recommendation — it's a description of how each structure is generally used:
If a SIF's structure fits what you're looking for, you can explore every live SIF strategy currently available — real AMFI-sourced NAV, returns, and scheme details — on our SIF Intelligence Centre.
Explore the SIF Intelligence Centre →