What you pay for advice at ₹25 lakh, ₹50 lakh and ₹1 crore: distributor, app, flat fee, percentage fee, PMS

"I have 50 lakh in mutual funds. Do I need an adviser or is an app enough?" The question comes up constantly, and the usual answers are either "you can do it yourself" or "it depends". Both are true and neither helps.

The useful version of the question is arithmetic. There are five ways to pay for help with a portfolio in India, and each one costs a different amount at ₹25 lakh, ₹50 lakh and ₹1 crore. Each one is also required by SEBI to do a different amount for you. Once both are on one page, the choice is smaller than it looks. This guide lays it out. It does not tell you which to pick; that depends on you, and personal advice is what the second and third rows of the table are registered to give. Corpus is in the process of SEBI registration and, unless and until that is granted, this site is education only.

The five ways to pay

1. Commission, through a regular plan. You pay nothing directly. The fund house pays your distributor a trail commission every year out of the regular plan's expense ratio, so the plan's NAV grows more slowly than the direct plan of the same scheme. One large broker's disclosure for the July to September 2026 quarter shows equity trail rates from fund houses ranging from 0.50% to 1.95% a year. Fund-house rate cards for the same quarter show base trail on diversified equity funds from about 0.85% to 1.6% a year before GST, with some fund houses stepping the rate down after the third year and others paying a flat rate. In June 2026, Outlook Money's reading of AMFI data put the average gap between regular and direct expense ratios across 43 flexi cap schemes at 1.14 percentage points in March 2026, narrowing to 1.12 by May after SEBI's new expense rules took effect.

2. A SEBI registered investment adviser, flat fee. SEBI allows two fee modes. The fixed mode is capped at ₹1,51,000 a year per family of clients, revised every three years. In practice, freefincal's list of flat-fee planners (updated August 2026) shows first-year fees from ₹11,000 to ₹1,25,000, with renewals typically at half. Published prices on individual RIA sites this month run from ₹13,000 to ₹15,000 a year at the low end, through ₹25,000 to ₹30,000 plus GST for a first plan, to ₹50,000 plus GST, and ₹1,50,000 at one hourly-fee practice that takes only families above a stated net worth.

3. A SEBI registered investment adviser, percentage fee. The other mode: a percentage of assets under advice, capped at 2.5% a year per family. Published schedules are far below the cap. One advisory firm charges 0.75% a year on portfolios from ₹50 lakh to under ₹2 crore, stepping down to 0.50% at ₹10 crore and above; a direct-plan platform's advisory tier charges from 0.8% plus GST on portfolios above ₹50 lakh, with a minimum fee. An adviser may switch a client between the two modes with consent, and may collect at most one year's fee in advance.

4. A subscription app. A flat annual charge for research, portfolio analysis or model portfolios. Published prices in 2026 sit between roughly ₹1,000 and ₹5,000 a year, some quoted before GST and some inclusive, and some billed monthly or quarterly. Whether the app may tell you what to do with your money depends on its registration, not its price (see below).

5. Portfolio management services. A manager runs a separate portfolio in your name. The regulatory minimum is ₹50 lakh. Fixed fees in the industry run from about 1% to 2.5% a year, often with a performance fee above a hurdle, and some charge an exit load in the first year. From 1 April 2027, SEBI's new PMS regulations add a mutual-fund-only route with a ₹25 lakh minimum and the fixed management fee capped at 1% of assets.

And the sixth way, which is not a way to pay: a direct-plan platform with no advice. SEBI's execution-only platform framework (2023) covers apps that let you transact in direct plans for no commission. Such a platform is an agent of the fund house or of you, and SEBI's circular says its tools may not provide research, opinions or advisory activity. You get execution and data. The thinking is yours.

What each one costs at three sizes

Annual cost, before GST where the fee is a fee, using the mid-range figures above. Treat every number as illustrative.

So, three things the table makes visible.

The commission you are already paying may be the largest line. A ₹50 lakh portfolio held entirely in regular plans, at the March 2026 average gap of 1.14 points, is paying about ₹57,000 a year for distribution. That recurs every year as part of the plan's expense ratio. Your half-yearly CAS for September and March shows the actual rupee commission paid on your holdings, so you do not have to estimate it.

Flat fees get cheaper as the portfolio grows; percentage fees do not. At ₹25 lakh a ₹25,000 plan is 1% of assets, which is in the same range as a regular plan. At ₹1 crore the same plan is 0.25%, and the 0.75% adviser is now ₹75,000 a year. This is why the "adviser or app" question has a different answer at different sizes: the cost of a human plan falls in percentage terms while the cost of commission and percentage advice stays flat or rises.

And the cheapest line is not comparable to the others. A subscription app at ₹3,000 and a planner at ₹25,000 are not two prices for the same thing. The next section is what each is required to do.

What SEBI requires each one to do for you

The first row is the one where SEBI's regulations require a documented risk profile, a suitability assessment, a written rationale and a yearly audit. SEBI's own count, in a speech by its chairman in March 2026, was about 1,000 registered investment advisers in the country, 470 of them individuals, and the number has fallen since 2021. An individual adviser who crosses 300 clients, or ₹3 crore of fees in a year, has to convert to a non-individual registration. That is the supply side of the "do I need an adviser" question, and it is small.

The fourth row is where most confusion lives. An app that charges ₹2,000 a year and shows you a model portfolio may be an RIA, in which case it is bound by everything in row one, or it may be registered as a research analyst, or as nothing. The price tells you nothing. The registration number on the site does.

So which one, at which size

This is a description of what the numbers tend to show, not a recommendation.

At ₹25 lakh, the first question is usually not "which adviser" but "what am I paying now". If the portfolio is in regular plans, the half-yearly CAS will show a commission figure in the low tens of thousands a year. A one-time flat-fee plan is in the same range. Whether it is worth paying depends on whether you have questions a plan would answer; if your questions are "what do I own and what does it cost", the answers are in your own statements and the guides on this site cover how to read them.

At ₹50 lakh, every option is affordable and the costs start to separate. Commission at the March 2026 average gap is about ₹57,000 a year. A percentage-fee adviser is about ₹37,500. A flat-fee plan is ₹25,000 falling to ₹12,500. The subscription app is ₹3,000. Personal advice on what to change is, under SEBI's regulations, the role of a registered investment adviser; a distributor's advice is limited to being incidental to the products it distributes, and an app without a registration is giving you data and education.

At ₹1 crore, the percentage lines start to matter more than the flat ones. A 0.75% adviser costs three times a flat-fee plan every year; a 1.5% PMS costs six times. Fees that scale with assets are a separate question to put directly to the adviser, with the SEBI fee caps and the required written rationale in mind.

In every column, the fee is one input. The others are whether the person is permitted to advise you, what they are required to document, who else is paying them, and what you can check on a register. Those are on the second table, and all of them can be checked in a few minutes on SEBI's and AMFI's websites.

Frequently asked questions

Do I need a financial adviser for a 50 lakh portfolio?
There is no rule that you do. What changes with size is cost: at ₹50 lakh the commission on regular plans is about ₹57,000 a year at the March 2026 average gap, a flat-fee plan is typically ₹13,000 to ₹50,000, and a percentage-fee adviser at 0.75% costs about ₹37,500. Personal advice on what to change is the role SEBI's regulations assign to a registered investment adviser.

What is the maximum fee a SEBI registered investment adviser can charge?
Either 2.5% of assets under advice a year per family, or a fixed fee of up to ₹1,51,000 a year per family, excluding GST. The fixed cap is revised every three years.

How much do fee-only financial planners charge in India?
Published first-year fees run from about ₹11,000 to ₹1,25,000 on freefincal's list, with the individual fee pages we read in October 2026 sitting between ₹13,000 and ₹50,000, and renewals usually at around half.

Is a subscription investing app allowed to tell me which funds to buy?
Only if it is registered with SEBI as an investment adviser (INA number) and has assessed your suitability. A research analyst registration (INH) permits research, not personal advice. An execution-only platform may not advise at all.

What is the minimum investment for PMS in India?
₹50 lakh under the current regulations. From 1 April 2027, a mutual-fund-only PMS route (PRIM) opens at ₹25 lakh with the fixed fee capped at 1% of assets.

Sources: SEBI (Investment Advisers) Regulations, 2013, consolidated to November 2025 (regulations 13, 15, 15A, 16, 17, 19, 22); SEBI Master Circular for Investment Advisers, 6 February 2026 (fee modes and caps, mode switching, advance fees); SEBI circular of 2 April 2025 on advance fees; SEBI chairman's address, 16 March 2026; SEBI Recognised Intermediaries list, October 2026; SEBI circular of 13 June 2023 on execution-only platforms; SEBI circular of 20 September 2016 on commission disclosure in the half-yearly CAS; SEBI (Portfolio Managers) Regulations, 2026, effective 1 April 2027, and SEBI press release of 24 September 2026 (PRIM); ICICI Direct commission disclosure, July to September 2026; Invesco, Old Bridge and The Wealth Company distributor rate cards, July to September 2026; Outlook Money, 9 June 2026, on regular versus direct TER gaps from AMFI data; freefincal, list of flat-fee-only financial planners, August 2026; published fee pages of Insightful, Vivektaru, Sahaj Money, PLNR, Fiduciaries.in, Finnovate and Scripbox, read 21 October 2026; PowerUp Money and Value Research pricing pages; Dezerv and Business Today pages on PMS fee structures. All rupee figures in the tables are illustrative calculations from these published rates. Corpus is in the process of registering as an investment adviser with SEBI. Nothing on this page is investment advice. Investment in securities market are subject to market risks. Read all the related documents carefully before investing.