
What is an index fund, and why can it never quite match its index?
By Himanshu Sakre·
The SEC defines an index fund as a passive fund built to achieve approximately the same return as an index, before fees. That last phrase does a lot of work, and it is why tracking an index perfectly is arithmetically impossible.
What is an index fund
An index fund is a fund that tries to match the return of a particular market index rather than beat it.
The SEC's own definition, from investor.gov, is more precise and worth reading closely. A passive fund is a mutual fund, exchange-traded fund or unit investment trust that follows an investment strategy designed to achieve approximately the same return as a particular index, before fees. And: passively managed mutual funds, ETFs and UITs are also called index funds.
Two things fall out of that immediately.
Index fund is a strategy, not a product type. It describes what the manager is trying to do. The wrapper can be a mutual fund, an ETF or a UIT, and the choice of wrapper changes how you buy it, how it is taxed and how it trades. We have covered the real difference between an ETF and a mutual fund separately.
The definition contains the word approximately, and the phrase before fees. Those are not hedging. They are the whole story.
Why it cannot match the index exactly
The SEC puts this more plainly than most fund marketing does: market indexes themselves have no expenses, so even a passively managed index fund can underperform its index because of fees and taxes.
An index is a calculation. It does not pay a manager, a custodian, a transfer agent or a commission. A fund does all of those things. The gap between the index and the fund is therefore built in, and the fund's job is to keep it small rather than to close it.
There is a second source of drift. The SEC notes a passive strategy can be implemented either by buying every security in the index or by holding a representative sampling. Sampling is normal and often sensible, particularly for indexes with thousands of illiquid constituents, but a sample is not the index, and it tracks it imperfectly by construction.
“market indexes themselves have no expenses, even a passively managed index fund can underperform its index due to fees and taxes”
What the expense ratio actually covers
Investor.gov defines the expense ratio as a fund's total annual operating expenses, including management fees, distribution or 12b-1 fees and other expenses, expressed as a percentage of average net assets.
That is a broader figure than a management fee alone, which is why comparing management fees across funds can mislead. We have written on what counts as a cheap expense ratio and what the number does and does not include.
The expense ratio is also not the only cost. Trading costs inside the fund, bid-ask spreads when you buy an ETF, and any brokerage commission sit outside it.
Why index funds are usually cheaper
The SEC's explanation is mechanical rather than ideological. Passive management usually translates into less trading of the fund's portfolio, which means lower transaction costs. Less trading also tends to realise fewer capital gains, which the SEC describes as more favourable income tax consequences. And overseeing a rules-based strategy requires less of the research apparatus that active management funds.
An older SEC study quantified part of this: it found that in 1999, other things held equal, the operating expense ratio of an index fund was 45 basis points lower than an equivalent non-index fund. That figure is from 1999 and should be read as historical rather than current, because fee competition has moved a great deal since.
Note the word usually in the SEC's framing. It is not a guarantee. An expensive index fund is entirely possible, and the strategy label does not cap the fee.
Not every fund calling itself an index fund is simple
The SEC has a separate bulletin on smart beta, quant funds and other non-traditional index funds. Its position is that these still count as passive, because the adviser seeks to track an index rather than using independent judgement to pick investments.
The subtlety is that the index itself can be anything. A bespoke index constructed around a particular factor or screen is still an index, and a fund tracking it is still technically passive, while behaving very differently from a fund tracking a broad market measure. The label tells you about the manager's discretion, not about what you own.
How to read one
Three questions, all answerable from the documents.
Which index, and how is it constructed? A broad market index and a custom factor index are different exposures wearing the same word.
Full replication or sampling? Both are legitimate; they drift differently.
What is the total expense ratio, and what sits outside it? The ratio covers operating expenses. Spreads, commissions and internal trading costs do not appear in it.
This is explanatory information about how a product category works, not advice about whether any fund suits your circumstances. That question belongs with a licensed adviser who knows them.
Frequently asked questions
What is an index fund?
It is a fund that aims to match the return of a particular market index rather than beat it. The SEC's investor.gov defines a passive fund as a mutual fund, ETF or unit investment trust following an investment strategy designed to achieve approximately the same return as a particular index, before fees, and states that passively managed funds of these kinds are also called index funds. Index fund therefore describes a strategy, not a wrapper.
Why can't an index fund exactly match its index?
Because the index has no costs and the fund does. The SEC states this directly: market indexes themselves have no expenses, so even a passively managed index fund can underperform its index due to fees and taxes. An index is a calculation that pays no manager, custodian or commission. A fund pays all of those. The gap is structural, and keeping it small is the job rather than closing it.
What is tracking difference and why does it happen?
It is the gap between what the fund returned and what the index returned. Fees are the most consistent contributor, since they come out of fund assets and never out of the index. A second source is how the fund is built: the SEC notes a passive strategy can be implemented by buying all the securities in the index or a representative sampling, and a sample tracks imperfectly by construction. Cash held for redemptions, dividend timing and taxes add further drift.
What does the expense ratio include?
Investor.gov defines it as a fund's total annual operating expenses, including management fees, distribution or 12b-1 fees, and other expenses, expressed as a percentage of average net assets. That is broader than the management fee alone, which is why comparing headline management fees between funds can mislead. It also does not capture everything you pay: internal trading costs, bid-ask spreads on an ETF and any brokerage commission sit outside it.
Are index funds always cheaper than active funds?
Usually, which is the SEC's own word, not always. Investor.gov attributes the typical cost advantage to mechanics: passive management generally means less portfolio trading, so lower transaction costs, fewer realised capital gains and therefore more favourable tax consequences, and lower fees. None of that caps what a particular index fund may charge. An expensive index fund is possible, and the strategy label alone does not tell you the price.
What is the difference between an index fund and an ETF?
They answer different questions. Index fund describes the strategy, which is tracking an index rather than selecting investments. ETF describes the wrapper, which is a fund that trades on an exchange through the day. An ETF can track an index or be actively managed, and an index fund can be structured as a mutual fund, an ETF or a unit investment trust. The wrapper affects how you buy and sell, pricing through the day, and tax treatment.
Is a smart beta fund an index fund?
By the SEC's reasoning, yes. Its bulletin on smart beta, quant funds and other non-traditional index funds says these still count as passive because the adviser seeks to track an index rather than using independent judgement to manage investments. The important caveat is that the index itself can be custom-built around a particular factor or screen. The passive label describes the manager's discretion, not how broad or conventional the underlying exposure is.
What does representative sampling mean?
It means the fund holds a subset of the index's constituents chosen to behave like the whole, rather than every single one. The SEC lists it as a legitimate way to implement a passive strategy alongside full replication. It is common where an index contains thousands of securities or includes holdings that are illiquid or expensive to trade. The trade-off is that a sample is not the index, so tracking is less precise by design.
Do index funds pay dividends?
If the securities the fund holds pay dividends, those flow through to the fund and are distributed to shareholders according to the fund's schedule, which varies. Dividend handling is also one of the reasons for tracking difference, because an index typically assumes dividends are reinvested instantly while a fund receives, holds and then distributes or reinvests them on real dates. The specific policy is set out in the fund's prospectus.
Where can I check these facts for myself?
The SEC's investor.gov carries the glossary entries for index fund and passive fund, the bulletins on mutual funds and ETFs, and the separate bulletin on non-traditional index funds. For any individual fund, the prospectus states the index tracked, the replication method, the expense ratio and the distribution policy. Those are the primary documents, and they are more reliable than fund marketing material for all four of those facts.
Sources
What each one is, and whose it is.
- 1
Index Fund (glossary), SEC, investor.gov
DocumentationIndependent of the vendor - 2
Passive Fund or Passively Managed Fund (glossary), SEC, investor.gov
DocumentationIndependent of the vendor - 3
Smart Beta, Quant Funds and other Non-Traditional Index Funds, SEC, investor.gov
DocumentationIndependent of the vendor - 4
Mutual Funds and ETFs: A Guide for Investors, SEC, investor.gov
DocumentationIndependent of the vendor - 5
Report on Mutual Fund Fees and Expenses (1999 data), US Securities and Exchange Commission
DocumentationIndependent of the vendor