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Starting 1st April 2026, SEBI has changed how mutual fund expenses are calculated. The old system called TER (Total Expense Ratio) has been split into two parts: BER (Base Expense Ratio) for fees and costs, and SER (Statutory Expense Ratio) for taxes like GST, STT, and stamp duty.
The idea is good — investors can now clearly see how much goes to the fund house and how much goes to the government as tax. But the way this change has been put into practice is hurting a large number of Mutual Fund Distributors (MFDs) and Financial Advisors across India.
Let us understand with a simple example. Suppose an AMC was paying you ₹100 as commission earlier.
| Step | Old System | New System |
|---|---|---|
| AMC pays you | ₹100 (everything included) | ₹84.75 (without GST) |
| GST given separately by AMC? | No — already inside | Only if you submit invoice |
| You pay GST to government? | Only if registered (18%) | Only if registered (18%) |
| What if you are NOT registered? | You keep ₹100 | You keep only ₹84.75 |
The impact depends entirely on your GST status. There are three types of MFDs:
If your annual commission income is less than ₹20 Lakh, you are not required to register for GST. Under the old system, this was actually an advantage — you kept the full ₹100 because there was no GST to pay.
Now? You still don't pay GST. But your commission has been cut to ₹84.75. And with the 5 bps exit load removal (1% assumption of brokerage), it drops further to about ₹79.75.
| What Happens | Before | After | Impact |
|---|---|---|---|
| Commission received | ₹100 | ₹84.75 | |
| GST refund from AMC | None | None | |
| GST paid to government | None | None | |
| Exit load reduction (5 bps) (assumption 1% brokerage rate) | None | ₹5.00 | |
| Money in your pocket | ₹100 | ₹79.75 | -20.25% |
If you are registered under regular GST (18%), the new system doesn't hurt as much. Your base commission drops to ₹84.75, but you can raise a GST invoice on the AMC and get ₹15.25 reimbursed.
| What Happens | Before | After | Impact |
|---|---|---|---|
| Commission received | ₹100 | ₹84.75 | |
| GST refund from AMC | None | ₹15.25 | |
| GST paid to government | ₹15.25 | ₹15.25 | |
| Income after GST | ₹84.75 | ₹84.75 | |
| Exit load reduction (5 bps)(assumption 1% brokerage rate) | None | ₹5.00 | |
| Money in your pocket | ₹84.75 | ₹79.75 | -5.90% |
If you fall under the GST Composition Scheme (turnover between ₹20 Lakh and ₹50 Lakh in some states like Maharashtra), you pay a flat 6% levy. But here's the problem — you cannot issue a proper GST tax invoice, and you cannot claim any refund from the AMC.
| What Happens | Before | After | Impact |
|---|---|---|---|
| Commission received | ₹100 | ₹84.75 | |
| GST refund from AMC | None | None | |
| Composition levy (6%) | ₹6.00 | ₹5.09 | |
| Income after levy | ₹94.00 | ₹79.66 | |
| Exit load reduction (5 bps) (assumption 1% brokerage rate) | None | ₹5.00 | |
| Money in your pocket | ₹94.00 | ₹74.66 | -20.57% |
Many MFD families have 2–4 separate ARN registrations — husband, wife, son, daughter — each earning independently. If each person earns less than ₹20 Lakh, every single one of them faces the full 15–20% income cut.
If your family holds multiple individual ARNs, consider merging them into a single Corporate ARN by forming a Private Limited Company or LLP. This one step can solve many of your problems:
This document is prepared by The Excelist Learning Solutions Private Limited for educational and informational purposes only. It does not constitute legal, tax, or financial advice. The information is based on SEBI (Mutual Funds) Regulations, 2026, AMFI Best Practices Guidelines Circular No. 123/2025-26, and publicly available regulatory documents as of March 2026. Readers are advised to consult their own legal, tax, and financial advisors before making any decisions based on this information. The Excelist Learning Solutions Pvt. Ltd. and its directors, officers, and employees shall not be liable for any loss or damage arising from the use of this document. Past regulatory frameworks do not guarantee future outcomes. All examples used are illustrative and do not represent any specific individual or entity.