What is SEBI's BER, and how is it different from TER?

From 1 April 2026 SEBI split a fund's old Total Expense Ratio (TER) into two parts: the Base Expense Ratio (BER), which is the fund's own fees and running costs, and the Statutory Expense Ratio (SER), which holds taxes like GST, STT and stamp duty. GST is now shown separately in the SER instead of being buried inside the TER. For a distributor, the practical effect is that the GST on your brokerage is paid to you separately, and only after you raise a valid tax invoice.

What happens if I am not registered under GST?

If you are not GST-registered, or you do not raise the invoice, the AMC does not pay you the GST portion. On the same brokerage that works out to roughly 15% less in your hand than a registered distributor who invoices for it.

What SAC code and GST rate apply to mutual fund distributor commission?

18% GST under SAC code 997152 (brokerage and related securities services). It is CGST plus SGST when the fund house is in your own state, and IGST when it is in another state. The distributor charges it to the AMC under forward charge.

Do I need a GSTIN to raise the invoice?

Yes. GST registration is mandatory once your total commission income crosses 20 lakh rupees in a financial year (10 lakh in special category states). Only a registered distributor with a GSTIN can raise a valid tax invoice and receive the GST on the brokerage.

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SEBI BER · April 2026 · Brokerage GST

SEBI BER and GST: how a mutual fund distributor raises the invoice in 2026

Q: Why do mutual fund distributors have to raise a GST invoice after April 2026?

Because GST now sits outside the fund's expense ratio, the AMC pays your brokerage without GST and reimburses the 18% GST separately. It pays that GST only to a GST-registered distributor who raises a proper tax invoice for it and uploads it through KFIN or CAMS. No valid invoice means the GST is withheld.

From 1 April 2026, SEBI moved GST out of a fund's expense ratio. So the GST on your brokerage now reaches you only after you raise a signed tax invoice to each fund house and upload it on KFIN or CAMS. Here is what changed, in plain words, and how to get the invoice right.

MFD Office turns your KFIN or CAMS brokerage file into a signed invoice for every fund house at once. See the KFIN guide, the CAMS guide, and the invoice format and SAC code.

What changed on 1 April 2026, in one minute

SEBI reworked how a mutual fund shows its costs. The old single Total Expense Ratio (TER) was split into two parts. You will see these terms in AMC notes and on tax blogs, and MFDs now search for them by name:

Term	What it means for you
BER (Base Expense Ratio)	The fund's own fees and running costs. This is the "base" of the old TER, now shown on its own.
SER (Statutory Expense Ratio)	The taxes, GST, STT, stamp duty and the like, taken out of the TER and shown separately. Your brokerage GST now sits here.

Because GST is no longer buried inside the fund's expense ratio, the fund house (AMC) pays your brokerage without GST, and then reimburses the 18% GST on top, separately. It pays that GST only to a GST-registered distributor who raises a proper tax invoice for it. People also call this the "TER delinking" or "GST outside TER" change. The name to remember is simple: no valid invoice, no GST.

Registered and invoicing, or losing the GST

The change quietly splits distributors into two groups. The gap is the whole GST amount.

On the same brokerage	What reaches you
GST-registered, and you raise the invoice	Your brokerage plus the 18% GST, paid after your invoice is uploaded and accepted.
Not registered, or no invoice raised	Only the brokerage. The GST is withheld, which is roughly 15% less in your hand for the same work.

So the invoice is now the thing that pays you. It is not paperwork you can skip. Every GST-registered MFD needs a way to raise a correct, signed invoice for each fund house, every commission cycle. See one of your own invoices free, with no signup and no card.

Do you have to register under GST?

GST registration is mandatory once your total commission income crosses 20 lakh rupees in a financial year (10 lakh in special category states). Above that, you must register, raise a tax invoice for every payout, and file your returns. Below it you can stay unregistered, but then the AMC will not pay you the GST portion, so many distributors near the line choose to register.

What a valid invoice must contain

Each fund house checks these fields before it releases the GST. A missing or wrong field is the most common reason an invoice is rejected.

Field	What goes in it
Supplier (you)	Your name and address, ARN, GSTIN and PAN.
Recipient	Fund house name, address, state and GSTIN.
Invoice no. and date	A unique serial number for the period, in order, and the date.
Place of supply	The fund house's state and state code.
Description and SAC	Distribution commission for the month, with the SAC code.
Taxable value	The brokerage, before GST.
GST	CGST and SGST at 9% each in your own state, or IGST at 18% for another state.
Total	The total value in figures and in words.
Signature	Name of the signatory, designation or status, and the signature.

The SAC code: use 997152

Mutual fund distribution sits under GST heading 9971 at 18%. The correct SAC code for a distributor's commission is 997152, and it is what registrar indicative invoices carry.

997152

Correct for MFD commission. Brokerage and related securities services, which covers mutual fund distribution.

997164

Not this one. 997164 is pension fund management, a different service. It is sometimes cited online by mistake.

Please note: this is general information, not tax advice. Confirm your own position with your tax advisor, especially GST registration and return timing.

How to raise and upload it, step by step

The monthly job is the same on both registrars:

Download your brokerage file from KFIN or CAMS for the period.
Make one tax invoice per fund house, with the fields above, the correct 18% split, and your signature.
Put each invoice in the layout the registrar expects, and fill their Excel upload sheet to match.
Upload it in the registrar's window, usually about the 7th to the 15th, and the GST is released once it is accepted.
Report it in your GSTR-1 for the month (or IFF if you file quarterly under QRMP).

The slow way, and the MFD Office way

Most tools ask you to type the commission amount for each fund house, one at a time. That is fine for one or two, slow and easy to mistype across every AMC, every month.

By hand, or typing amount per fund house	With MFD Office
Look up each AMC's GSTIN, state and tax split, then type the amount for each one	Upload the real KFIN or CAMS file once. Every fund house is read for you.
Every GST figure re-keyed by hand, so a slip means a rejected invoice	Every GST figure is kept exactly as the registrar computed it
Sign and format each invoice yourself	Your signature is applied to every invoice, in the layout each registrar expects
Repeat for all of your fund houses, one by one, every month	The whole batch, up to every one of India's 40-plus AMCs, in a few minutes

Check the whole set before you pay. Inside a free MFD Office account you preview every invoice on screen for free, and your first 10 invoices cost nothing to download. Try it with your own file, or see pricing.

Common mistakes to avoid

Wrong SAC code. Use 997152, not a generic financial code and not 997164.
Wrong tax split. CGST and SGST for a fund house in your own state, IGST for another state. The total is 18% either way.
Wrong AMC GSTIN. Each fund house has its own GSTIN. The wrong one gets the invoice rejected.
Invoice numbers out of order. They must run in sequence for the financial year, with no gaps or repeats.
Missing ARN or signature. Both are checked at upload.

Your brokerage GST, done the right way

Upload your KFIN or CAMS file and see a real, correctly made invoice for your own fund houses. No signup, no card.

Try with your file, free

Common questions

Is BER the same as TER?

No. BER is one part of the old TER, the fund's own base fees. The taxes, including GST, were split out into the SER. For you, the point is that GST is now paid separately and only against a valid invoice.

Is GST charged under reverse charge?

No. You charge GST to the fund house under forward charge and show it on your invoice.

What if I do not raise the invoice?

The fund house does not pay you the GST portion. On the same brokerage that is roughly 15% less in your hand.

How do I file on each registrar?

See the KFIN guide and the CAMS guide. Most MFDs file on both, and MFD Office handles both.