Mutual Funds, Minus the Marketing · Part 12 of 30
SEBI fund categories decoded: what the label on the tin actually constrains
Why there are labels at all
Until 2017 an Indian fund house could run three “large cap” funds with three different definitions of large, and a scheme called Opportunities could hold anything. Comparing funds meant first working out what each one actually was.
SEBI’s categorisation circular of October 2017 fixed that with two rules. Each fund house may run only one scheme per category (with a few exceptions such as index funds), and every category is defined by a hard portfolio constraint — a minimum the scheme must hold, checked continuously, not a description of intent.
That second rule is the useful part. A category name is a promise about the portfolio that the manager cannot break without SEBI noticing. Knowing exactly what each promise is — and, just as important, what it leaves open — is what lets you compare like with like, which the benchmarks post argued is most of the work in evaluating a fund.
Definitions below start from that circular (SEBI/HO/IMD/DF3/CIR/P/2017/114, 6 October 2017 (categorisation and rationalisation of mutual fund schemes), as amended in 2020), later consolidated in SEBI’s Master Circular for Mutual Funds, 27 June 2024 (clause 2.6). SEBI then replaced that clause with a revised categorisation circular (HO/24/13/15(2)2026-IMD-RAC4/I/5764/2026, 26 February 2026): value, contra, dividend yield and focused funds now need at least 80% in equity rather than 65%, a fund house may run both a value and a contra fund as long as their portfolios overlap by no more than 50%, sectoral and thematic funds face a similar overlap cap, and the “solution-oriented” category was discontinued. Existing schemes got six months to comply (three years for the sectoral/thematic overlap cap). From 1 April 2026 these rules sit in SEBI’s Master Circular for Mutual Funds, HO/24/13/11(1)2026-IMD-POD-1/I/7602/2026, 20 March 2026 (paras 3.7 and 3.8), which folds in the February 2026 circular; the equity thresholds below match its para 3.8.1. The earlier 65% figure for these categories comes from the 2017 framework and was not re-read for this post. SEBI revises these, so check the current text before relying on one.
Market cap bands: who counts as large, mid and small
Every equity category starts from one list. Twice a year AMFI (the Association of Mutual Funds in India) ranks all listed companies by average market capitalisation and publishes the cut-offs:
Large cap = ranks 1 to 100
Mid cap = ranks 101 to 250
Small cap = ranks 251 onwards
Two consequences people miss. The bands are defined by rank, not by a rupee size, so the 100th company today is a far bigger business than the 100th company in 2017 — “large cap” has quietly inflated. And because the list is republished every six months, a stock can move from mid to large (or back) without anything happening to the company. A mid-cap fund holding it then has one month to rebalance to the updated list.
Equity categories
| Category | The hard rule | Core band |
|---|---|---|
| Large cap | At least 80% of assets in large-cap stocks | Stocks ranked 1st to 100th by market cap |
| Large & mid cap | At least 35% in large caps AND at least 35% in mid caps | Ranks 1-100 and 101-250 |
| Mid cap | At least 65% in mid-cap stocks | Ranks 101st to 250th |
| Small cap | At least 65% in small-cap stocks | Rank 251st onwards |
| Multi cap | At least 75% in equity, with at least 25% EACH in large, mid and small caps | All three bands, forced |
| Flexi cap | At least 65% in equity; no minimum in any band | Anywhere the manager likes |
| Focused | At most 30 stocks; at least 80% in equity | Any band |
| Value | At least 80% in equity, following a value strategy | Any band |
| Contra | At least 80% in equity, following a contrarian strategy; a fund house running both value and contra must keep their overlap at or below 50% | Any band |
| Dividend yield | At least 80% in equity, mostly dividend-paying stocks | Any band |
| Sectoral / thematic | At least 80% in one sector or one theme | That sector or theme only |
| ELSS (equity-linked savings scheme) | At least 80% in equity, 3-year lock-in, tax deduction under the old regime | Any |
| Index fund / ETF (exchange-traded fund), filed under “Other schemes” | At least 95% in the securities of the index it tracks | Whatever the index holds |
That’s the equity group only. SEBI also defines debt categories (below), hybrid categories, life-cycle funds, and an “other schemes” group that holds index funds, ETFs and funds of funds — hybrids and the rest are out of scope here.
Read the rules for what they don’t say.
Large cap must keep 80% in the top 100 — but the other 20% is free, and a “large cap” fund’s excess return over the Nifty can come from that 20%, which is not large-cap exposure at all.
Flexi cap has no band minimums whatsoever. Two flexi-cap funds can be 80% large cap and 60% small cap respectively and both be perfectly compliant. Comparing them to each other, or to one benchmark, tells you very little until you look at where the money actually sits.
Multi cap is the opposite: it forces at least a quarter each into large, mid and small, so it is structurally more mid-and-small-heavy than most “flexi” funds. The two names sound interchangeable. The portfolios are not. (The flexi-cap category was created in November 2020 precisely because the multi-cap rule was tightened in September 2020, and many funds that had called themselves multi cap moved over rather than be forced into small caps.)
Index fund / ETF is the one category where the constraint is total: at least 95% in the index’s securities. That’s what makes the arithmetic in this series clean — there’s no discretionary residue to explain.
🧒 Explain it like I'm 10 (optional — skip if this is already clear)
Think of a school sports day with age groups. “Under-10” means every runner must be under 10 — the rule is checked, so you know a race is fair.
But imagine one race called “Open” where anyone can run, and another called “Mixed” where the organiser must pick a third of the team from each age group. Both sound like “everyone welcome”. They’re completely different races. If you compared an Open team full of 15-year-olds against a Mixed team, the Open team would win, and it would mean nothing.
Flexi cap is the Open race. Multi cap is the Mixed one.
Debt categories: duration by name, credit by rule
Debt categories are sliced two ways at once, and the debt funds post explained why both matter: duration decides how much the NAV moves when rates move; credit quality decides whether a borrower might not pay.
Most debt categories are defined by Macaulay duration — the weighted-average time to the portfolio’s cash flows, a close cousin of the modified duration used to estimate price sensitivity. A few are defined by what they hold instead.
| Category | The hard rule | What it implies |
|---|---|---|
| Overnight | Securities maturing in 1 day | Rate: ~none. Credit: ~none. |
| Liquid | Debt and money-market paper maturing within 91 days | Rate: very low. Credit: low, mostly top-rated. |
| Ultra short duration | Macaulay duration 3 to 6 months | Rate: low. |
| Low duration | Macaulay duration 6 to 12 months | Rate: low. |
| Money market | Money-market instruments maturing within 1 year | Rate: low. Credit: depends on paper. |
| Short duration | Macaulay duration 1 to 3 years | Rate: moderate. |
| Medium duration | Macaulay duration 3 to 4 years | Rate: moderate to high. |
| Medium to long duration | Macaulay duration 4 to 7 years | Rate: high. |
| Long duration | Macaulay duration above 7 years | Rate: high. |
| Dynamic bond | Any duration; manager decides | Rate: whatever the manager is betting on. |
| Corporate bond | At least 80% in AA+ and above rated corporate bonds | Credit: low to moderate. |
| Credit risk | At least 65% in AA and below rated corporate bonds | Credit: HIGH by design. |
| Banking & PSU | At least 80% in debt of banks, PSUs (public sector undertakings) and public financial institutions | Credit: low. |
| Gilt | At least 80% in government securities, any maturity | Rate: usually high. Credit: sovereign. |
| Gilt with 10-year constant duration | At least 80% in G-secs (government securities), Macaulay duration held at 10 years | Rate: high and constant. |
| Floater | At least 65% in floating-rate instruments | Rate: low by construction. |
The row to stare at is credit risk: the category is defined as holding at least 65% in bonds rated AA and below. That is not a warning label someone forgot to remove — it is the mandate. The higher yield is the market’s price for exactly that.
Two more things the debt table reveals. Dynamic bond funds have no duration constraint at all, which means their rate risk is whatever the manager currently believes; two dynamic bond funds can be as different as an overnight fund and a gilt fund. And liquid funds are constrained by maturity (91 days) rather than duration, which is why their NAVs look like straight lines.
Why the label matters for comparison
Every performance comparison — returns, rolling returns, drawdowns, Sharpe ratios, rankings, star ratings — is only meaningful within a category, because the category constraint is what makes the funds comparable. A small-cap fund beating a large-cap fund over five years is not information about either manager; it is information about small caps over those five years.
That is also why category boundaries are where the mischief happens. A fund at the loose end of its category (a flexi cap that is really a small-cap fund; a “large cap” leaning hard on its free 20%) will top its category’s table in the years its tilt works, and look like a genius against peers who took the label literally.
Common mistakes
- Treating flexi cap and multi cap as synonyms. One has no band minimums; the other forces 25% into each band. They are structurally different products.
- Assuming “large cap” means 100% large cap. It means 80%. Check the factsheet for where the other 20% sits — the factsheet post shows where.
- Comparing across categories. A fund winning against a different category’s funds has told you about the category, not the fund.
- Reading “dynamic” as “safe”. It means unconstrained duration, which is the opposite of a promise.
- Not noticing a category change. Funds do get reclassified; a scheme’s five-year record may belong to a different mandate.
Sources
- SEBI circular on categorization and rationalization of mutual fund schemes (February 2026): the circular that revised the categories in February 2026.
- SEBI Master Circular for Mutual Funds (20 March 2026): the master circular that consolidates the category rules.
- AMFI, average market capitalisation list for the six months to 30 June 2025: the half-yearly list that classifies companies as large, mid or small cap.
Takeaway: SEBI’s categories are hard portfolio constraints, not marketing adjectives — large cap means 80% in the top 100 companies, credit risk means 65% in bonds rated AA or below, flexi cap means no band minimums at all. Know the constraint and you know what a fund’s record is actually a record of, which is the only basis on which comparing two funds means anything.
This post is for educational purposes only and is not investment advice. Wealth Primer explains concepts, not recommendations — nothing here is a suggestion to buy, sell, or hold any specific security or fund. The author is not a SEBI-registered Research Analyst or Investment Adviser. Any prices or figures used as worked examples are historical and shown only to illustrate a calculation. Past performance does not indicate future results. Please do your own research or consult a registered adviser before making investment decisions. See the privacy & disclaimer policy for more.