Do I need to record calls/interactions with every client, including institutions?
In force
Yes — the requirement to maintain records of client interactions (call recordings, emails, SMS) applies to both fee-paying and non-fee-paying clients, and even to institutional/QIB clients.
The point is grievance-readiness: every investor, regardless of type, has a right to an effective grievance mechanism, so the documentation trail must exist.
One practical relief: call recording isn't required if the interaction happened over email or another channel that already leaves a digital footprint — so email-only client interactions are fine without a separate voice recording.
From 9 November 2026 this changes for institutional investors only. SEBI notified an amendment on 8 October 2026 making call recording for institutional investor clients no longer mandatory. Everything above still applies to every other client, and the other records for institutional clients are still required. The separate answer on that amendment has the dates and the definition.
What SEBI says, word for word
FAQ Circular, Q33(iii)“The requirement of maintenance of records of interactions with clients such as call recordings, emails, etc. is applicable for fee-paying as well as non-fee paying clients... RAs/research entities shall ensure compliance with the provision for maintenance of records of interactions even in case of their clients who are institutional investors or QIBs.”Source: SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/105, dated July 23, 2025 Open document ↗
FAQ Circular, Q33(iii)“call recording is not required if the interaction with client is made through means such as email, etc. for which digital footprint is available.”Source: SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/105, dated July 23, 2025 Open document ↗