Can I give my report to premium clients before everyone else?
In force
No. A report may not go to a particular client, a class of clients, or your own dealing side ahead of other clients who are entitled to receive it.
This bites directly on tiered subscriptions where a higher plan gets the call first. If both tiers are entitled to the report, both get it at the same time.
If you distribute someone else's research, two further duties apply. You must review it for any untrue statement of material fact or false or misleading information, and you must disclose that provider's conflicts of interest or give a web address that leads to them.
Those two duties fall away only where you have no business or contractual relationship with the provider.
What SEBI says, word for word
Regulation 22(1)“A research report shall not be made available selectively to internal trading personnel or a particular client or class of clients in advance of other clients who are entitled to receive the research report.”Source: SEBI (Research Analysts) Regulations, 2014 — Regulation 22(1) Open document ↗
Regulation 22(2)“shall review the third party research report for any untrue statement of material fact or any false or misleading information”Source: SEBI (Research Analysts) Regulations, 2014 — Regulation 22(2) Open document ↗