SEBI's New Fund Category Sits Between a Mutual Fund and a PMS

Specialised Investment Funds - SIFs - became effective from 1 April 2025, filling a gap between mutual funds, which are open to any investor but restricted in what strategies they can run, and PMS or AIF structures, which allow more flexibility but sit at a much higher entry ticket. A SIF, run by an existing AMC through a separate investment strategy, can take positions a regular mutual fund scheme can’t - larger derivative exposure, more concentrated positions - while still being distributed and regulated broadly like a fund.

The Rs 10 Lakh Gate Is Per AMC, Not Per Strategy

The entry point is ₹10 lakh. The detail worth getting right is what that ₹10 lakh actually measures: it isn’t ₹10 lakh per strategy. It’s a minimum applied cumulatively at the investor’s PAN level, across every SIF strategy offered by that AMC. An investor already holding ₹10 lakh in one of an AMC’s SIF strategies can add money to a second SIF strategy from the same AMC without clearing the threshold again - the ₹10 lakh gate applies once per AMC relationship, not once per product inside it.

The Count Resets at the AMC Boundary

This changes how the minimum actually behaves for someone spreading money across an AMC’s SIF range rather than concentrating in one strategy. It also means an investor already past the threshold with one AMC starts fresh at ₹10 lakh again with a different AMC’s SIF range - the cumulative counting resets at the AMC boundary, not at some account-wide industry level.

The category is new enough that most explanations of it still describe the ₹10 lakh minimum in the generic, per-product way mutual fund minimums are usually described - a reasonable assumption that happens to be wrong here, and worth checking directly against an AMC’s SIF offer document before assuming how a second or third strategy from the same house will be gated.

Check the AMC’s SIF offer document before assuming how a second strategy is gated. Most explanations still describe the minimum the per-product way mutual fund minimums work, which is a reasonable assumption and the wrong one here.