NISM Series XXI-A Eligibility: Who Needs It?
NISM certifications have no degree requirement. What matters is the role you hold. Here is who Series XXI-A is mandatory for.
If a SEBI-registered portfolio manager engages you to distribute its Portfolio Management Services, you must pass NISM Series XXI-A. SEBI made this mandatory through notification SEBI/LAD-NRO/GN/2021/48 dated September 7, 2021, and the requirement now sits in paragraph 1.7.2 of SEBI's master circular for portfolio managers.
Anyone else may take the exam. NISM's FAQ says it is open to PMS distributors, interested students and professionals, or any other individual. NISM states no minimum age or educational qualification for it. The one hard condition is PAN: NISM issues the passing certificate only to candidates who have furnished PAN in their registration details.
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You need XXI-A if you are
- checkAn individual mutual fund distributor or IFA who wants to place clients' money with a PMS
- checkA relationship manager at a bank, broker or wealth firm that is empanelled as a distributor with one or more portfolio managers
- checkSales staff at a distribution firm who pitch PMS investment approaches to clients
- checkAnyone else a portfolio manager engages as a distributor of its services
XXI-A or XXI-B?
The two PMS certifications are for different sides of the business. Pick by role, not by seniority.
Who it is for
Series XXI-A
Distributors engaged by a portfolio manager
Series XXI-B
The portfolio manager's principal officer and employees with decision-making authority on fund management
SEBI notification
Series XXI-A
SEBI/LAD-NRO/GN/2021/48, Sept 7, 2021
Series XXI-B
SEBI/LAD-NRO/GN/2021/49, Sept 7, 2021
Typical job
Series XXI-A
Sourcing and servicing PMS clients
Series XXI-B
Running the portfolios
Master circular para
Series XXI-A
1.7.2
Series XXI-B
1.7.1
| Series XXI-A | Series XXI-B | |
|---|---|---|
| Who it is for | Distributors engaged by a portfolio manager | The portfolio manager's principal officer and employees with decision-making authority on fund management |
| SEBI notification | SEBI/LAD-NRO/GN/2021/48, Sept 7, 2021 | SEBI/LAD-NRO/GN/2021/49, Sept 7, 2021 |
| Typical job | Sourcing and servicing PMS clients | Running the portfolios |
| Master circular para | 1.7.2 | 1.7.1 |
Deadlines and the transition exemption
From paragraph 1.7.2 of the master circular:
- Distributors already working on September 7, 2021
- The portfolio manager had to ensure they passed XXI-A within two years of the notification.
- Distributors engaged after that date
- The portfolio manager must ensure they pass XXI-A within one year from the date of their employment or engagement.
- ARN or Series V-A holders as on September 7, 2021
- A distributor who on that date held a valid AMFI Registration Number or a Series V-A certificate was exempt from XXI-A until that registration or certificate's validity ran out. The circular does not say a later renewal extends the exemption, so check with the portfolio manager's compliance officer before relying on it.
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Passing XXI-A is not the only step
Since SEBI's May 2, 2024 circular (paragraph 2.4A of the master circular), every person or entity distributing PMS must also register with APMI, the portfolio managers' industry body, and the portfolio manager must check this. Distributors must also follow a code of conduct and self-certify compliance within 15 calendar days of each financial year's end.
How XXI-A tests this
Expect one or two questions on who needs which certification. The usual trap is swapping XXI-A and XXI-B: a principal officer needs XXI-B, a distributor needs XXI-A. A second trap is assuming an ARN alone lets you sell PMS. The ARN exemption covered only the 2021 transition, tied to the validity of the ARN or certificate held on that date; XXI-A plus APMI registration is the standing requirement.
FAQs
Who is eligible for the NISM Series XXI-A exam?expand_more
Anyone. NISM's FAQ lists PMS distributors, students, professionals and any other individual. You need PAN in your registration details to receive the certificate.
Is NISM XXI-A mandatory to sell PMS?expand_more
Yes. SEBI's September 7, 2021 notification requires every associated person engaged by a portfolio manager as a PMS distributor to pass XXI-A. A new distributor must pass within one year of being engaged.
Can I sell PMS with only an ARN or Series V-A?expand_more
Only under the 2021 transition exemption, which applied to ARN or V-A held on September 7, 2021 and lasted until that registration or certificate's validity. Today the requirement is XXI-A plus APMI registration.
What is the difference between NISM XXI-A and XXI-B?expand_more
XXI-A is for people who distribute PMS. XXI-B is for the portfolio manager's principal officer and staff with fund management decision-making authority.