Can I trade in stocks that I recommend or cover?
In force
No — Regulation 16 puts a 30-day-before / 5-day-after blackout around your own research report: you (and your associates) cannot deal in a security you recommend or follow starting 30 days before publishing the report until 5 days after it's out.
You also cannot trade contrary to your own recommendation — e.g. issuing a 'buy' while you personally sell.
You cannot buy or receive securities of an issuer ahead of its IPO if that issuer is in the same line of business as companies you cover.
These restrictions apply to independent RAs, part-time RAs, individuals employed as RAs, and their associates — and also apply at the entity level if a research entity hasn't properly segregated research from its other business lines.
You also may not buy or receive securities of an issuer before its IPO where that issuer is principally in the same line of business as companies you follow or recommend.
There is one lawful way out of the blackout, and it is narrow. It can be lifted for significant news about the subject company, or an unanticipated change in your own financial circumstances, but only with prior written approval given under your approved internal policies. No policy, no exception.
What SEBI says, word for word
FAQ Circular, Q26“Independent research analysts, part-time research analysts, individuals employed as research analyst or their associates shall not deal or trade any securities that the research analyst recommends or follows within 30 days before and 5 days after the publication of a research report on the subject company.”Source: SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/105, dated July 23, 2025 (explaining Regulation 16) Open document ↗
Regulation 16(4)“shall not purchase or receive securities of the issuer before the issuer's initial public offering, if the issuer is principally engaged in the same types of business as companies that the research analyst follows or recommends”Source: SEBI (Research Analysts) Regulations, 2014 — Regulation 16(4) Open document ↗
Regulation 16(6)“subject to prior written approval as per the terms specified in the approved internal policies and procedures”Source: SEBI (Research Analysts) Regulations, 2014 — Regulation 16(6) Open document ↗
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