Do clients who pay me nothing count towards my deposit and my client numbers?
In force
Yes. Your client count is fee-paying plus non-fee-paying, added together.
That total drives two things: the deposit slab you must maintain with RAASB, and the client numbers in your half-yearly report.
It can quietly move you from the ₹1 lakh slab to ₹2 lakh or ₹5 lakh without your fee income changing at all.
You also need terms-and-conditions consent from these clients, not merely disclosure. Disclosure alone is enough only for institutional clients and qualified institutional buyers.
SEBI's meaning here is narrower than it sounds. A non-fee-paying client is someone receiving research as a value-added extra alongside another paid service at family or group level. It is not a stranger on a free mailing list.
The same logic makes bundled research regulated research. If a client pays you for something else and gets research included, that research is provided for consideration even though no research fee was charged.
What SEBI says, word for word
FAQ Circular, Q34“Thus, the number of clients of RA/research entity shall mean total of fee-paying clients and non-fee paying clients of RA/research entity.”Source: SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/105, dated July 23, 2025 Open document ↗
Master Circular, ¶1.8(b)“research services being provided by research analyst or research entity to any of its clients availing its other services as registered intermediary in another capacity shall be considered as research services 'for consideration' even though no fee is charged by such research analyst or research entity directly from the client.”Source: SEBI Master Circular No. HO/38/12/11(1)2026-MIRSD-POD/I/4360/2026, dated February 6, 2026 Open document ↗
More on 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?