SEBI Research Analyst compliance, answered

71 questions on the SEBI (Research Analysts) Regulations, 2014 and the Master Circular, each with the exact wording and a link to the document on sebi.gov.in.

Fees

• How much fee can I charge an individual or HUF client?
• How much fee can I take in advance, and what if a client leaves early?

Registration & Deposit

• What deposit do I need to maintain with RAASB?
• What qualification and NISM certification do I need?
• Do all my employees who work as analysts need their own SEBI registration?
• What are the SEBI registration and renewal fees?
• Can I be registered as both an Investment Adviser and a Research Analyst?
• What happens to my registration if I die, sell the practice, or change its structure?
• How do I surrender my registration, and what survives it?
• If I hire sales or support staff, which NISM exam do they need?
• If my address, email or circumstances change, must I tell SEBI?
• Do clients who pay me nothing count towards my deposit and my client numbers?
• What is a part-time Research Analyst, and what extra rules apply?
• When do I have to renew my NISM certification?
• I am a sole proprietor. Do I register as an individual or as a firm?

Trading Restrictions

• Can I trade in stocks that I recommend or cover?

Disclosures

• What must I disclose when appearing on TV, YouTube, or public media?
• Must I have a website, and what has to appear on it?
• What must I put on my WhatsApp, YouTube and social media accounts?
• What must appear on every report and client communication?

Code of Conduct

• Can I promise or guarantee returns to a client?
• What exactly does the Code of Conduct require of me?

Conflict of Interest

• Can I provide both research and distribution (e.g. mutual fund/PMS) services to the same client?
• Can I run another business alongside my research practice?
• Can my spouse or parent sell distribution products to my research clients?

Client Onboarding

• Do I need signed client consent on terms & conditions (MITC) for every client?
• Is KYC mandatory for all my research clients?

Records

• Do I need to record calls/interactions with every client, including institutions?
• Has call recording been relaxed for institutional clients?
• Which records must I keep, and for how many years?
• What are the rules about market rumours, blogs and chat forums?
• If I employ an analyst, must I monitor their personal trading?

Investor Grievance

• Within how many days must I resolve a client complaint?
• What must I do with the Investor Charter?
• Do I have to be on the SMARTODR platform, and what does a dispute cost me?
• What complaints data must I publish every month?
• Do I have to display anything physically in my office?

Research Reports

• What are the rules for recommending a model portfolio?
• What disclosures must appear inside every research report?
• Can I send a trading call on WhatsApp without writing a research report?
• If I use a rating or score, what must I publish about it?
• Can I give my report to premium clients before everyone else?

Scope

• What kinds of communication are NOT treated as a 'research report' under RA rules?
• Can a person located outside India issue research reports on Indian securities?
• Who is exempt from registering as a Research Analyst?
• Are proxy advisers covered under RA Regulations?
• Do journalists giving stock tips on TV need SEBI registration?
• Do RA Regulations only cover equity shares, or all securities?
• I only do technical analysis. Does that put me outside the RA rules?

Governance

• Do I need to appoint a compliance officer?
• What are the rules if I use AI tools in my research process?
• Who can conduct my annual compliance audit — does it have to be ICAI or ICSI?
• Do I need an accessibility audit of my website? (deadline 31 January 2027)
• Does the cyber security framework (CSCRF) apply to me?
• Do I need written internal policies, and what must they cover?
• What must I do with the compliance audit report once it is done?
• What may I outsource, and what stays my responsibility?

Branding

• Do I have to use the words 'Research Analyst' in my name/correspondence?

Regulatory Framework

• Which Master Circular is currently in force for Research Analysts?

Performance & Track Record

• Can I show my past performance or track record to clients or on my website?
• What is PaRRVA and what are the current rules and deadlines for sharing certified past performance?
• Once my data is PaRRVA-verified, exactly how can I advertise it (website, QR code, etc.)?
• What exact disclaimer must accompany any past performance data I share?

Payments

• Do I need a validated @valid UPI ID to collect fees from clients?
• What is SEBI Check, and do I have to tell clients about it?
• How may I actually collect my fees — is cash allowed, and what is CeFCoM?

Advertising

• What are the rules for advertising my research services?
• What is the Common Advertisement Code and what does it change for me?
• Can my research report itself count as an advertisement?

Association

• Can I pay a finfluencer for leads, or work with someone who is not SEBI registered?

Reporting

• What do I have to file with RAASB, and when?