The world of finance and investments is vast, with a plethora of options available for investors. Among these, Alternative Investment Funds (AIFs) and Portfolio Management Services (PMS) stand out as prominent choices for high-net-worth individuals. While both offer unique advantages, they cater to different investor needs and operate under distinct regulatory frameworks. This article delves deep into the nuances of AIF Category 3 and PMS, shedding light on their differences, benefits, and challenges.


AIF Category 3


Investment Strategy

Allows for a wide range of complex trading strategies, including derivatives and algorithm-based trading.

Typically more conventional, focusing on equities, fixed income, and other traditional assets.

Investment Vehicle

Pooled fund where multiple investors contribute.

Individual portfolios tailored to each investor's preferences.

Potential Returns

Potentially higher due to dynamic strategies and leverage.

Varies based on the chosen strategy and market conditions.

Access to Securities

Can invest in both listed and unlisted securities.

Primarily invests in listed securities, though some might venture into unlisted spaces.

Regulatory Framework

Stringent regulations set by SEBI with regular audits.

Regulated by SEBI but might be perceived as having a less rigorous framework compared to AIFs.


Ability to employ leverage to amplify potential returns.

Typically does not employ leverage.

Investor Base

Attracts both individual and institutional investors.

Primarily targets high-net-worth individuals.

Investment Mandates

Highly flexible, allowing for niche sectors and emerging trends.

More standardized, though can be customized based on individual preferences.

Fee Structure

"2 and 20" model (2% management fee and 20% performance fee).

Flexible; can be fixed, performance-based, or a combination.


High scalability due to pooled nature.

Might be more challenging to scale as each portfolio is individualized.


Managed by professionals with expertise in diverse strategies.

Managed by portfolio managers focusing on individual client needs.


1. Regulatory Framework: The Backbone of Financial Instruments

  • AIF Category 3: The Securities and Exchange Board of India (SEBI), the regulatory body overseeing the securities market in India, introduced the SEBI (Alternative Investment Funds) Regulations in 2012. This was a landmark move to bring alternative investments under a structured regulatory framework. AIFs are classified into three categories, with Category 3 AIFs being the most dynamic. They are characterized by their ability to employ diverse or complex trading strategies. This includes investments in both listed and unlisted derivatives, making them a versatile option for seasoned investors.

The inception of the AIF regulations was a response to the evolving investment landscape. As global markets became more interconnected, there was a need for sophisticated investment vehicles that could tap into diverse opportunities. Category 3 AIFs, with their flexible investment mandates, were SEBI's answer to this demand.

  • PMS: Portfolio Management Services have been a part of the Indian investment ecosystem for a longer time. Regulated under the SEBI (Portfolio Managers) Regulations, 2020, PMS offers a more tailored investment solution. Unlike mutual funds where investors buy units of a pooled fund, in PMS, each investor has a distinct portfolio managed by a professional. This bespoke approach has made PMS a preferred choice for those who seek personalized attention and strategies.

The evolution of PMS in India can be traced back to the liberalization era when the Indian economy opened its doors to foreign investments. With increasing wealth and a growing class of affluent individuals, there was a demand for more individual-centric investment solutions. PMS, with its promise of customization, filled this gap effectively.

2. Investment Strategy: Crafting the Roadmap to Wealth

  • AIF Category 3: The hallmark of Category 3 AIFs is their dynamic investment strategy. These funds are not restricted by rigid mandates, allowing fund managers to craft strategies based on market conditions. From quantitative models, algorithm-based trading to arbitrage opportunities, the world is their oyster. This dynamism is both their strength and challenge. While it allows for potentially higher returns, it also comes with increased risks. Investors in Category 3 AIFs are often those who have a deep understanding of market mechanics and are not averse to taking calculated risks.

A notable aspect of Category 3 AIFs is their ability to invest in unlisted securities. In a country like India, where numerous promising businesses are yet to go public, this provides a golden opportunity. Investors can tap into the growth stories of these companies before they become mainstream.

  • PMS: The essence of PMS lies in its customization. Each portfolio is crafted keeping in mind the individual's financial goals, risk appetite, and investment horizon. Whether it's a young entrepreneur looking to build wealth or a retired professional seeking regular income, PMS can be tailored to fit all. The portfolio manager plays a pivotal role, acting as both a strategist and advisor. Regular interactions, updates, and reviews are part of the PMS experience, ensuring that the investor is always in the loop.

Over the years, PMS strategies have evolved. From a predominantly equity-focused approach, today's PMS offerings include a mix of assets – from bonds, real estate to commodities. This diversification is a response to the changing global economic landscape and the need to hedge against uncertainties.

3. Minimum Investment: The Entry Ticket

  • AIF Category 3: Alternative investments, given their sophisticated nature, come with a higher entry barrier. The minimum investment for AIFs is set at INR 1 crore. This ensures that only those with significant capital and an understanding of complex financial instruments enter this space. The high ticket size is also reflective of the fund's strategy, which often involves tapping into niche opportunities that require substantial investments.
  • PMS: PMS, while still catering to the affluent, has a lower entry threshold. With a minimum investment of INR 50 lakhs, it's accessible to a larger group of investors. This lower barrier has been instrumental in popularizing PMS, especially among the burgeoning class of new-age entrepreneurs and professionals.

4. Structure: Pooling Resources vs. Individual Focus

  • AIF Category 3: AIFs operate on a fund structure. Investors pool their resources, which are then collectively invested based on the fund's strategy. This pooling allows for diversification, as the fund can tap into multiple opportunities simultaneously. It also fosters a sense of collective growth, with all investors benefiting from the fund's performance.
  • PMS: PMS stands out for its individual-centric approach. Each investor's portfolio is distinct, crafted based on their unique needs. This means that two investors with the same PMS provider might have entirely different portfolios. This structure is ideal for those who seek a more hands-on approach to investing, where they can discuss, deliberate, and decide on their portfolio's direction.

5. Leverage: Amplifying Gains and Risks

  • AIF Category 3: One of the defining features of Category 3 AIFs is their ability to employ leverage. By borrowing capital, these funds can amplify their investment size, leading to potentially higher returns. However, leverage is a double-edged sword. While it can magnify gains, it can also exacerbate losses. Hence, leverage in AIFs is used judiciously, with strict risk management protocols in place.
  • PMS: The use of leverage in PMS is less common and is often based on the agreement between the investor and the portfolio manager. Given the personalized nature of PMS, any decision to employ leverage is taken after thorough discussions, ensuring that the investor is comfortable with the associated risks.

6. Fees: The Cost of Expertise

  • AIF Category 3: The fee structure in AIFs is a combination of management fees and performance fees. Management fees are fixed and are charged for the operational aspects of the fund. Performance fees, on the other hand, are variable and are linked to the fund's performance. This dual fee structure ensures that the fund's interests are aligned with those of the investors.
  • PMS: PMS fees are a mix of fixed and performance-based charges. The fixed fee is for the portfolio manager's expertise, while the performance fee rewards them for outperformance. This structure ensures that the portfolio manager is incentivized to deliver the best possible returns.

7. Liquidity: Converting Investments into Cash

  • AIF Category 3: Given their investment in niche areas and unlisted securities, Category 3 AIFs might have certain lock-in periods. Liquidity can vary based on the fund's strategy and terms. Investors are usually made aware of these terms at the onset, ensuring transparency.
  • PMS: Liquidity in PMS is generally higher, given its focus on listed securities. However, it's essential to note that liquidity is also influenced by the underlying assets. For instance, a portfolio focused on blue-chip stocks will have higher liquidity than one investing in small-cap stocks.

8. Target Investors: Understanding the Audience

  • AIF Category 3: Category 3 AIFs are not for the faint-hearted. They are tailored for seasoned investors who understand market intricacies and are comfortable with higher risks. These investors are often individuals or institutions with substantial capital and a long-term investment horizon.
  • PMS: PMS, with its promise of customization, appeals to a broad spectrum of high-net-worth individuals. Whether it's a business magnate, a celebrity, or a successful professional, PMS has something for everyone. The personalized approach ensures that each investor's unique needs are addressed, making it a versatile investment option.

Historical Context: The Evolution of Investment Vehicles

The history of investment vehicles in India is as rich and varied as its culture. From the traditional chit funds and community savings groups to the sophisticated investment instruments of today, the journey has been transformative.

  • AIF Category 3: The inception of AIFs in India was a response to the global financial crisis of 2008. The crisis underscored the need for more regulated and transparent investment vehicles. SEBI, recognizing the evolving landscape, introduced the AIF regulations in 2012. Category 3 AIFs, in particular, were designed to offer investors a platform to tap into unconventional opportunities, beyond the traditional stocks and bonds. The flexibility in investment mandates allowed these funds to explore areas like commodities, derivatives, and algorithm-based trading.

Globally, similar funds, often termed as hedge funds, have been in existence for decades. The success of hedge funds in markets like the US and UK served as a blueprint for Category 3 AIFs in India. However, the Indian version was tailored to suit the unique market dynamics and investor profile of the country.

  • PMS: The roots of PMS in India can be traced back to the early 2000s. As the Indian economy liberalized, there was a surge in wealth creation. This new class of affluent individuals sought investment avenues beyond the traditional mutual funds. PMS, with its promise of customization and individual attention, fit the bill perfectly.

The global counterpart to PMS would be wealth management services offered by financial institutions in countries like Switzerland and Luxembourg. These services, like PMS, focus on offering bespoke investment solutions to high-net-worth individuals.

Case Studies: Successes and Challenges

  • AIF Category 3: A notable success story in the Category 3 AIF space is that of a fund that tapped into the e-commerce boom in India. Investing in early-stage e-commerce startups, the fund reaped significant returns as these startups went on to become unicorns. However, it wasn't always smooth sailing. The fund had to navigate challenges like regulatory uncertainties, competition from global players, and the inherent risks of startup investments.

Another fund focused on algorithm-based trading faced challenges during the demonetization phase in India. The sudden withdrawal of currency notes led to market volatility, affecting the fund's algorithms. However, with quick recalibrations and a robust risk management strategy, the fund managed to minimize losses and emerge stronger.

  • PMS: A PMS focusing on infrastructure stocks in the late 2000s is a testament to the benefits of a customized approach. Recognizing the government's push towards infrastructure development, the portfolio manager heavily invested in infrastructure stocks. This strategy paid off handsomely as these stocks outperformed the market. However, the same PMS faced challenges during the economic slowdown, as infrastructure projects were stalled, and stocks plummeted. The portfolio manager, leveraging the flexibility of PMS, quickly shifted focus to defensive stocks, minimizing losses for investors.

Global Comparisons: India vs. The World

The investment landscape in India, while unique, shares several similarities with global markets.

  • AIF Category 3: Hedge funds in the US, similar to Category 3 AIFs in India, employ diverse trading strategies. The key difference lies in the regulatory framework. While SEBI has set clear guidelines for leverage, investment mandates, and disclosures for AIFs, the US Securities and Exchange Commission (SEC) has a different set of regulations for hedge funds. The success of hedge funds managed by stalwarts like George Soros and Ray Dalio offers lessons for Category 3 AIFs in India.
  • PMS: Wealth management services in countries like Switzerland focus on preserving and growing wealth. The emphasis is on diversification, with investments spread across geographies and asset classes. PMS in India, while offering diversification, is more equity-centric. The challenges faced by wealth managers in Switzerland, especially with the crackdown on black money, offer lessons in transparency and compliance for PMS providers in India.

The Road Ahead: Future Trends

The investment landscape is ever-evolving, and both AIF Category 3 and PMS need to adapt to stay relevant.

  • AIF Category 3: The future for Category 3 AIFs lies in technology. With advancements in artificial intelligence and machine learning, algorithm-based trading will become more sophisticated. There's also a trend towards ethical investing, with funds focusing on ESG (Environmental, Social, and Governance) criteria. Category 3 AIFs, with their flexible mandates, are well poised to tap into these trends.
  • PMS: The future of PMS lies in personalization. With advancements in data analytics, portfolio managers will be able to craft even more tailored portfolios. There's also a move towards including alternative assets like art, wine, and cryptocurrencies in portfolios.

Operational Differences between AIF Category 3 and PMS

  1. Fund Structure:
    • AIF Category 3: Operates as a pooled investment vehicle where multiple investors contribute to a common fund. This fund is then invested collectively based on the fund's strategy.
    • PMS: Each investor has a distinct and separate portfolio. The assets are held in the individual investor's name, and the portfolio is managed uniquely based on the investor's preferences and risk profile.
  2. Investment Decisions:
    • AIF Category 3: Investment decisions are made by the fund manager based on the predefined strategy of the fund. Individual investors do not have a say in individual investment choices.
    • PMS: The portfolio manager may consult with the client before making significant investment decisions, especially if it deviates from the initially agreed-upon strategy.
  3. Reporting:
    • AIF Category 3: Investors receive periodic reports (usually quarterly or annually) that provide an overview of the fund's performance, asset allocation, and other relevant details.
    • PMS: Given its personalized nature, investors often receive more detailed and frequent reports, sometimes even monthly. These reports provide insights into individual holdings, performance metrics, and strategic changes.
  4. Entry and Exit:
    • AIF Category 3: Often has a lock-in period during which investors cannot redeem their investments. Post the lock-in, there may be specific windows or timelines for redemption.
    • PMS: Generally offers higher liquidity, allowing investors to add or withdraw funds with fewer restrictions. However, the exact terms can vary based on the agreement between the investor and the portfolio manager.
  5. Fee Structure:
    • AIF Category 3: Typically has a "2 and 20" fee structure, which means a 2% management fee and a 20% performance fee on the profits. However, this can vary among funds.
    • PMS: The fee structure can be more flexible, with some opting for a fixed fee, some for a performance-based fee, and others combining both.
  6. Asset Custody:
    • AIF Category 3: Assets are held collectively under the fund's name by a designated custodian.
    • PMS: Assets are held by a custodian in the individual investor's name.
  7. Taxation:
    • AIF Category 3: Taxation occurs at the fund level. The fund may be subject to certain taxes on its investment returns, which can impact the net returns to investors.
    • PMS: Tax implications arise at the individual investor level based on their portfolio's performance and transactions.
  8. Regulatory Audits and Compliance:
    • AIF Category 3: Being a regulated entity, it is subject to periodic audits and must adhere to various compliance requirements set by SEBI.
    • PMS: While also regulated by SEBI, the compliance requirements differ. PMS providers must ensure transparency, proper risk disclosures, and adhere to the mandates agreed upon with investors.
  9. Investor Agreements:
    • AIF Category 3: Investors enter into a collective investment agreement that outlines the terms of the fund, including fees, strategy, and other operational details.
    • PMS: Each investor signs a personalized portfolio management agreement that details the terms of service, fees, investment strategy, and other individualized aspects.
  10. Diversification:
  • AIF Category 3: Given the pooled nature of funds, investments are typically diversified across sectors, assets, or strategies, depending on the fund's mandate.
  • PMS: The level of diversification depends on the individual investor's risk profile and preferences. Some portfolios might be highly diversified, while others may focus on specific sectors or themes.

What factors should you consider while choosing between an AIF Category 3 and PMS (Portfolio Management Services)

Starting a business in the investment sector is a significant decision that requires careful consideration of various factors. If someone is contemplating between establishing an AIF Category 3 and a PMS, they should evaluate the following aspects:

  1. Target Audience:
    • AIF Category 3: Suitable for sophisticated investors who are well-versed with complex trading strategies and are comfortable with higher risks. These investors typically have a higher risk appetite and seek unconventional investment opportunities.
    • PMS: Targets high-net-worth individuals who prefer a more personalized investment solution tailored to their specific needs, risk profile, and financial goals.
  2. Capital Requirement:
    • AIF Category 3: Starting an AIF often requires significant capital, given the regulatory requirements and the need to attract institutional investors.
    • PMS: While still requiring substantial capital, starting a PMS might be less capital-intensive than an AIF, especially when beginning on a smaller scale.
  3. Operational Complexity:
    • AIF Category 3: Managing a pooled investment vehicle with diverse strategies, especially one that can employ leverage, can be operationally complex. It requires robust risk management systems, advanced trading platforms, and a skilled team.
    • PMS: While still demanding, managing individual portfolios offers more flexibility. The operational setup might be simpler, especially if focusing on traditional asset classes.
  4. Regulatory and Compliance:
    • AIF Category 3: AIFs are subject to stringent regulatory requirements, periodic audits, and compliance checks by SEBI. The compliance burden can be heavy, especially for new entrants.
    • PMS: Also regulated by SEBI, PMS has its set of compliance requirements. However, the regulatory framework might be perceived as less rigorous compared to AIFs.
  5. Scalability:
    • AIF Category 3: Given its pooled nature, AIFs can scale significantly as they attract more investors. This scalability can lead to higher assets under management (AUM) and potentially higher profits.
    • PMS: Scalability might be more challenging since each new client requires a tailored approach. However, a successful PMS with a strong track record can still attract substantial AUM.
  6. Fee Structure:
    • AIF Category 3: Typically follows the "2 and 20" model (2% management fee and 20% performance fee). This can be lucrative, especially if the fund performs well.
    • PMS: Fees are more flexible and can be negotiated with individual clients. A strong performance can justify higher fees.
  7. Reputation and Track Record:
    • AIF Category 3: Success often hinges on the fund's performance. A strong track record can attract institutional investors and larger ticket sizes.
    • PMS: Reputation is crucial. Personalized service, consistent performance, and client relationships play a significant role in attracting and retaining clients.
  8. Long-term Vision:
    • AIF Category 3: If the vision is to create a diversified investment platform with multiple funds and strategies, starting with an AIF might be the right choice.
    • PMS: If the focus is on offering bespoke investment solutions and building deep client relationships, PMS might align better with this vision.
  9. Exit Strategy:
    • AIF Category 3: A successful AIF can be an attractive acquisition target for larger financial institutions or can be scaled to become a significant player in the industry.
    • PMS: Exit options might include selling the client base to a larger wealth management firm or merging with a bigger entity.
  10. Personal Expertise:
  • AIF Category 3: Requires expertise in diverse trading strategies, risk management, and a deep understanding of both listed and unlisted securities.
  • PMS: Requires a deep understanding of individual asset classes, client relationship management, and personalized portfolio construction.

Why should one choose AIF category 3 over PMS?


Choosing between AIF Category 3 and PMS depends on various factors, both from the perspective of an investor and a fund manager or business owner. Here are reasons why one might opt for AIF Category 3 over PMS:

  1. Diverse Trading Strategies:
    • AIF Category 3 allows for a wide range of trading strategies, including complex ones. This flexibility can be attractive for those looking to tap into unconventional opportunities, such as derivatives, quantitative models, and algorithm-based trading.
  2. Pooled Investment Vehicle:
    • Investors in AIF Category 3 contribute to a common fund, which is then collectively invested based on the fund's strategy. This pooling allows for diversification and the ability to tap into opportunities that might require substantial capital.
  3. Potential for Higher Returns:
    • Given the dynamic investment strategies and the ability to employ leverage, AIF Category 3 can offer potentially higher returns, albeit with higher risks.
  4. Access to Unlisted Securities:
    • AIF Category 3 funds can invest in unlisted securities, providing investors with an opportunity to benefit from the growth of companies before they go public.
  5. Structured Regulatory Framework:
    • AIF Category 3 operates under a well-defined regulatory framework set by SEBI, ensuring transparency, regular audits, and investor protection.
  6. Leverage:
    • One of the defining features of AIF Category 3 is the ability to use leverage to amplify potential returns. While this increases risk, it can be an attractive feature for seasoned investors seeking higher returns.
  7. Institutional Participation:
    • AIF Category 3 funds often attract institutional investors, which can lead to larger ticket sizes and a more significant pool of capital to work with.
  8. Innovative Investment Mandates:
    • The flexible mandates of AIF Category 3 allow fund managers to explore niche sectors, emerging trends, and unique investment themes, which might not be feasible in a PMS setup.
  9. Performance Fee Structure:
    • The "2 and 20" fee model (2% management fee and 20% performance fee) can be lucrative for fund managers, especially if the fund performs well. This structure aligns the interests of the fund manager with those of the investors.
  10. Scalability:
  • AIFs, given their pooled nature, can scale significantly as they attract more investors. This scalability can lead to higher assets under management (AUM) and potentially higher profits for fund managers.
  1. Professional Management:
  • AIF Category 3 funds are typically managed by seasoned professionals with expertise in diverse trading strategies, risk management, and market dynamics.