If I employ an analyst, must I monitor their personal trading?
In force
Yes. If you employ individuals as research analysts, you must monitor and record their personal trading activity.
It is not enough that the employee follows the trading restrictions. The duty to watch and to keep the record is yours.
This does not apply to a practice with no employees, but it starts the day you make your first analyst hire, and it needs a standing process rather than an occasional check.
What SEBI says, word for word
FAQ Circular, Q25“Research analysts/Research entities who employ individuals as research analysts are required to monitor and record the personal trading activities of the individuals employed as research analyst with them.”Source: SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/105, dated July 23, 2025 Open document ↗