Has call recording been relaxed for institutional clients?
In force
Yes, and it is now law. SEBI notified the Research Analysts (Amendment) Regulations, 2026 on 8 October 2026, published in the Gazette of India, Extraordinary, Part III Section 4. A proviso after regulation 25(1)(vii) makes call recording of communications with clients who are institutional investors no longer mandatory.
When it starts. The notification says the regulations come into force on the thirtieth day from publication in the Official Gazette. The Gazette issue is dated 9 October 2026 while SEBI records the amendment as 10 October 2026, so the thirtieth day is either 8 or 9 November. The relief removes an obligation, so the only risk is stopping too early. Keep recording until 9 November 2026 and you are right on either reading.
Who counts as institutional. A new clause 2(1)(ia) ties the term to clause (y) of regulation 2(1) of the SEBI (Issue of Capital and Disclosure Requirements) Regulations, 2018. It is a defined list, not a judgement about a client’s size or sophistication. Check the client is actually in that list before treating them as institutional.
What does not change. Calls with every other client are recorded as before. For institutional clients the proviso lifts the call recording alone, so emails, messages and the rest of the interaction trail under regulation 25 are still kept, for the same period as before.
The relief is permissive. If your system records every call anyway, you may carry on recording all of them.
What SEBI says, word for word
Amendment Regulations, proviso to reg. 25(1)“Provided that the requirement to maintain call recordings of communications with clients which are institutional investors shall not be mandatory.”Source: SEBI (Research Analysts) (Amendment) Regulations, 2026, F. No. SEBI/LAD-NRO/GN/2026/321, dated October 8, 2026 Open document ↗
Amendment Regulations, cl. 2(1)(ia)“"institutional investor" shall have the same meaning as assigned to it in clause (y) of sub-regulation (1) of regulation 2 of the Securities and Exchange Board of India (Issue of Capital and Disclosure Requirements) Regulations, 2018;”Source: SEBI (Research Analysts) (Amendment) Regulations, 2026, F. No. SEBI/LAD-NRO/GN/2026/321, dated October 8, 2026 Open document ↗
Amendment Regulations, cl. 2“They shall come into force on the thirtieth day from the date of their publication in the Official Gazette.”Source: SEBI (Research Analysts) (Amendment) Regulations, 2026, F. No. SEBI/LAD-NRO/GN/2026/321, dated October 8, 2026 Open document ↗