Short answer: potentially, yes.

SEBI already allows Accredited Investors to invest in Portfolio Management Services (PMS) without the usual ₹50 lakh minimum. Until now, however, an NRI generally had to qualify as an Accredited Investor under the existing eligibility framework.

On September 24, 2026, SEBI's Board approved a change that would deem persons resident outside India under FEMA, including NRIs and FPIs, to be Accredited Investors.

That could make the ₹50 lakh PMS minimum much less relevant for NRIs.

But there is an important catch: the September 24 decision was a Board approval, not the final notification itself. As of September 28, 2026, the existing SEBI regulations still reflect the earlier Accredited Investor framework, so NRIs should not treat the announcement alone as an immediately effective exemption.

Three things stand between that and your investment:

• The change isn't in force yet. SEBI still has to notify amended regulations and issue implementation circulars.

• The exemption lets managers go lower. It doesn't make them. Each portfolio manager decides whether to offer a lower ticket size and on what terms.

• FEMA, KYC, PAN, bank-account and tax rules don't change. The accredited status only touches SEBI's investment-size thresholds.

The rest of this article explains each part and what you can do in the meantime.

Why does Accredited Investor status matter?

The term Accredited Investor (AI) refers to an investor who meets SEBI's criteria for being financially sophisticated enough to receive certain regulatory flexibilities.

Those flexibilities already exist across products such as PMS and AIFs.

For PMS, the existing regulations say a portfolio manager generally cannot accept less than ₹50 lakh from a client. But that minimum does not apply to an Accredited Investor, provided the required disclosures are made and the terms are agreed between the investor and portfolio manager.

A similar principle applies to AIFs. The normal minimum investment is ₹1 crore, but the AIF regulations specifically carve out Accredited Investors from that minimum.

So the important relationship is:

That distinction has existed for years.
What is new for NRIs is who can qualify as an Accredited Investor.

What SEBI approved on September 24, 2026

The SEBI Board meeting of September 24, 2026 (PR No. 59/2026) approved a revised Accredited Investor framework.

Persons Resident Outside India, as defined under the Foreign Exchange Management Act, 1999, including Foreign Portfolio Investors, will be deemed to be Accredited Investors.

What it means for you: If FEMA treats you as a non-resident, you won't need to prove income or net worth to qualify as an Accredited Investor. Today an individual needs an annual income of at least ₹2 crore, or a net worth of at least ₹7.5 crore, plus a certificate from an accreditation agency.

What it doesn't mean: Your NRI status doesn't unlock every product or remove any other requirement.

The same meeting also approved:

• Manager-led accreditation. AIF, SIF and PMS managers can accredit investors themselves, instead of only through an accreditation agency.

• A new eligibility test. Investors with ₹5 crore of securities-market assets can qualify.

• Three-year validity. Accreditation lasts three years and can be used across AIF, SIF and PMS products within the same group.

• New SEBI (Portfolio Managers) Regulations, 2026. These include a new ₹25 lakh route for mutual fund portfolios (covered below).

SEBI floated the non-resident proposal in its consultation paper on reviewing the Accredited Investor framework on August 13, 2026, and took public comments until September 3, 2026.

You would no longer need to qualify as an Accredited Investor by proving the existing Indian income or net-worth thresholds if you fall within the new deemed-accreditation category. That is the part of the reform that potentially changes access to lower-ticket PMS and AIF investments.

Is the change already in effect?

No. A SEBI Board approval is a policy decision. It becomes law only when SEBI notifies the amended regulations in the Gazette and issues circulars setting out how intermediaries should apply it. As of September 28, 2026, neither has happened for the Accredited Investor changes.

The PMS rules show why this matters. The current SEBI (Portfolio Managers) Regulations, 2020 define an Accredited Investor as someone "granted a certificate of accreditation by an accreditation agency." Until that definition is amended, a portfolio manager has no legal basis to treat an NRI without a certificate as accredited.

What to do now: If a PMS or AIF distributor offers you a sub-minimum ticket "under the new NRI rule" before notification, ask which circular they're relying on.

What changes for NRIs?

Today, the Accredited Investor framework generally works through specified eligibility criteria and accreditation.

For example, under the existing AIF framework, an individual can qualify based on combinations of income and net worth. Accreditation is normally evidenced through an accreditation certificate.

SEBI's September 24 decision introduces a different route for persons resident outside India. Instead of asking an NRI to establish that they meet those Indian financial thresholds, the proposal would treat the person's FEMA non-resident status itself as the basis for deemed accreditation. This matters because Accredited Investor status is the gateway to several existing regulatory concessions.

But it is important to separate two things:

Regulatory status:
An NRI would be treated as an Accredited Investor under the new framework.

Product access:
The PMS, AIF or other investment provider would still need to offer the relevant product or concession under its applicable rules and documentation.

In other words, deemed accreditation does not mean every PMS or AIF must accept every NRI at any amount they choose.

The practical bottleneck: Most PMS strategies are built for ₹50 lakh+ tickets because of their fees, operations and compliance costs. Expect some managers to offer lower entry points to NRIs and many not to. Check each strategy's disclosure document once the rules are live.

One more nuance: there is a separate category, the Large Value Accredited Investor (₹10 crore or more with one manager), which gets extra flexibility on contract terms and unlisted securities. Deemed status doesn't make you one. That still depends on how much you invest.

A second route below ₹50 lakh: PRIM

The new Portfolio Managers Regulations, 2026, approved at the same meeting, create the Portfolio Managers Route for Investing in Mutual Fund Units (PRIM). According to Cafemutual:

• Minimum ticket: ₹25 lakh. This is the client's minimum. The ₹2 crore net-worth figure in some reports applies to portfolio managers registering only for PRIM, not to investors.

• What it invests in: Only direct plans of mutual funds, including ETFs, index funds and Specialised Investment Funds (SIFs). It doesn't hold individual stocks.

• Fees: A fixed management fee capped at 1% of assets under management. Performance-linked fees are allowed.

Why this matters for NRIs: PRIM is a managed portfolio below ₹50 lakh that doesn't depend on Accredited Investor status. It isn't a stock-picking PMS, and SEBI hasn't said anything specific about NRI eligibility. It also isn't in force until the 2026 regulations are notified.

What changes for NRI investments in AIFs

AIFs follow the same logic under different numbers. Under the SEBI (Alternative Investment Funds) Regulations, 2012, the minimum commitment is ₹1 crore per investor per scheme, and Accredited Investors are exempt. SEBI's September 2025 Board agenda confirms this.

Once NRIs are deemed accredited, that exemption covers them too. It also opens two categories that are currently restricted:

• Accredited-Investor-only AIF schemes, which have lighter regulatory requirements

• Angel funds, which since 2025 accept only Accredited Investors

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As with PMS, fund managers set their own minimum commitments above the regulatory floor. Many AIFs will keep ₹1 crore for all investors.

AIF investment by non-residents also follows Schedule VIII of the FEMA (Non-Debt Instruments) Rules, 2019. Whether the fund is treated as foreign-owned depends on its sponsor and manager structure, and this is unaffected by SEBI's change.

The key point is that Accredited Investor status and minimum investment are separate concepts. Accreditation can remove a regulatory floor, but it does not force a manager to lower its own commercial minimum.

What hasn't changed for NRIs

Accredited Investor status is purely a SEBI concept about investment-size thresholds and investor protection. Nothing in the September 24 decision touches:

• FEMA account rules. You still fund Indian investments through an NRE (repatriable) or NRO (non-repatriable) account. The account you use decides whether you can take the money and gains out of India.

• Demat and trading setup. A PMS holds stocks in a demat account in your name, so you still need an NRI demat account with the correct NRE/NRO linkage. For repatriable equity trading, your designated bank's Portfolio Investment Scheme (PIS) process still applies.

• KYC and PAN. The manager still needs full KYC: PAN, passport, overseas address proof and FATCA/CRS declarations. Deemed status removes the income/net-worth proof, but you still have to prove who you are and that you're a non-resident.

• Taxation. Gains from a PMS are taxed in your hands, and tax is deducted at source for NRIs. Treaty benefits still need a Tax Residency Certificate and the prescribed forms. Your country of residence may tax the same income, so check the treaty between India and that country.

• Country-of-residence restrictions. Some Indian managers don't onboard US or Canadian residents at all, because of FATCA reporting and home-country tax rules on foreign funds. This is each firm's own policy, and SEBI's change doesn't override it.

• Foreign-securities investing. The new PMS rules let managers invest in foreign securities, but that route runs under the RBI's Liberalised Remittance Scheme, which is built for resident individuals. Don't assume it applies to NRI portfolios.

So, can an NRI invest in PMS with less than ₹50 lakh?

The regulatory framework points to yes, once the September 24, 2026 Accredited Investor change is formally implemented.

The reason is not that SEBI has simply reduced the PMS minimum from ₹50 lakh.

It has not.

The ₹50 lakh minimum remains the general rule. What changes is the investor's status.

SEBI already exempts Accredited Investors from that minimum. The September 24 Board decision would extend deemed Accredited Investor status to persons resident outside India under FEMA, including NRIs.

The practical chain is therefore:

NRI under FEMA → deemed Accredited Investor under the new framework → Accredited Investor exemption from the PMS minimum → potential access to PMS below ₹50 lakh.

The word potential matters.

The final ticket will still depend on the PMS provider, its investment approach and the terms agreed with the client.

For an NRI, the biggest change is therefore not simply a lower investment threshold. It is the removal of one of the hurdles that previously stood between non-resident investors and the Accredited Investor framework.

What NRIs should check before investing

Before the rules are notified:

• Don't commit money on the promise of a sub-₹50 lakh PMS or sub-₹1 crore AIF ticket.

• Get your accounts in order: NRE/NRO accounts, an NRI demat account and up-to-date KYC. These take the longest to sort out from abroad.

Once the circulars are out:

• Confirm the product accepts deemed Accredited Investors. Ask for it in writing, along with the actual minimum for your ticket size.

• Read the undertaking before you sign it. By accepting Accredited Investor treatment, you confirm you understand and can bear the product's risks. Some investor protections are lighter by design.

• Check the fees at your ticket size. A fixed fee plus a performance fee eats more of a ₹20 lakh portfolio than a ₹1 crore one.

• Check your country-of-residence eligibility. This matters most if you live in the US or Canada.

• Compare PMS with PRIM or mutual funds. Lower entry doesn't make a product right for your amount.

The paperwork is where most NRIs lose weeks: an NRI demat account, notarised or attested KYC documents, and originals couriered to India. Rupeeflo helps NRIs open Zerodha NRI demat accounts and handle document notarisation and courier from their phone, so your accounts are ready when the rules go live.

FAQs

Do I need to apply to become an Accredited Investor as an NRI?
Under the approved framework, no. Anyone resident outside India under FEMA is deemed accredited. You'll still need to confirm your non-resident status through KYC. The manager may also ask you to sign an undertaking to use the relaxations, as current rules require.

Does this apply to OCI card holders and foreign citizens?
The provision covers "persons resident outside India" under FEMA, and residency is what decides this, not citizenship. OCIs and foreign nationals living abroad fall within it. They are still subject to the separate FEMA rules for their category.

I'm a returning NRI. Am I still covered?
Only while FEMA treats you as resident outside India. Once you become resident, you need to meet the income, net-worth or securities-market-asset tests to be accredited.

Is the ₹50 lakh PMS minimum being scrapped for everyone?
No. It still applies to investors who aren't accredited. The new ₹25 lakh PRIM route is a separate mutual-fund-only option.

When will the change take effect?
SEBI hasn't given a date. It depends on SEBI notifying the amended regulations and issuing circulars. Watch SEBI's circulars page.

Does accredited status reduce my tax?
No. Tax depends on the product, the holding period, your residency and the tax treaty between India and your country.