The Securities and Exchange Commission of Pakistan has issued an updated Master Circular for Asset Management Companies and Investment Advisers, consolidating all mutual fund and investment advisory regulations issued between January 6, 2009 and June 30, 2026 into a single reference document. This consolidation effort addresses a fairly practical regulatory challenge, since financial institutions and investors previously had to navigate a fragmented set of circulars issued over more than a decade and a half rather than referring to one comprehensive document covering the full regulatory landscape.
Among the more consumer-relevant changes, SECP has increased the investment limit for low-risk investors using simplified digital accounts. Sehl Sarmayakari accounts, limited to money market and low-risk income schemes, now carry a cumulative investment limit of 1 million rupees and a transaction limit of 300,000 rupees, while Sahulat Sarmayakari accounts carry a cumulative limit of 3 million rupees and a transaction limit of 1 million rupees. These raised limits give retail investors using simplified, digitally onboarded accounts considerably more room to invest through low-risk instruments than the previous thresholds allowed.
The Circular also defines the framework for digital onboarding of investors through regulated financial institutions, including OTP-verified portal access, real-time video verification, NADRA biometric checks, and enhanced due diligence for high-risk customers, formalising the digital verification infrastructure that has increasingly underpinned how Pakistani investors access mutual fund and investment products remotely. Beyond onboarding, the Circular includes SECP regulations relating to Infrastructure Funds, ESG Funds, Digital Asset Management Companies, and Investment Plans. Infrastructure schemes must invest in sectors such as transport, energy, water, and social infrastructure while maintaining minimum net assets of 100 million rupees, while ESG schemes must keep at least 50 percent of assets aligned with a declared ESG strategy such as negative screening, integration, or impact investing. Digital AMCs seeking no-objection certificates from trustees must meet OWASP-aligned cybersecurity requirements, and each Investment Plan is required to carry a separate Key Fact Statement while maintaining segregated assets.
The Master Circular additionally covers regulations relating to the categorisation of Collective Investment Schemes and investment avenues, disclosure requirements, Constant Proportion Portfolio Insurance-based schemes, Exchange Traded Funds, performance benchmarks for Collective Investment Schemes, and the selling and marketing of mutual funds, alongside sales loads and expenses, valuation and provisioning, distribution of CIS units, outsourcing arrangements, risk management and compliance, mergers of open-end schemes, procedures for unit holders’ meetings, separately managed accounts, and closed-end schemes. SECP has further clarified requirements for Key Fact Statements, Trust Deed formats, and Market Development Fund regulations, and issued guidelines on digitalisation, advertisements, risk management, and mandatory certification of Non-Banking Finance Company professionals under the Pakistan Markets and Regulations Program, Fundamentals of Capital Market, and Mutual Fund Distributors Certification. According to the regulator, in case of any conflict between the Master Circular and a relevant original circular, the original circular shall prevail, preserving the legal precedence of specific prior circulars even as the consolidated document becomes the primary reference point going forward.
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