What kinds of communication are NOT treated as a 'research report' under RA rules?
In force
Several categories are explicitly carved out of the definition of 'research report', so you don't need RA registration merely to produce these:
• General commentary on securities market trends
• Discussion of broad-based indices
• Commentary on economic, political, or market conditions
• Periodic reports/statements for mutual fund/AIF unit holders or PM/IA clients
• Purely internal communications not shared with clients or prospects
• Offer documents/prospectuses circulated under SEBI regulations
• Statistical summaries of company financial data
• Technical analysis of demand/supply for a sector or index (note: technical analysis on an individual security with a buy/sell/hold call is NOT exempt — the exemption is only for sector/index-level supply-demand commentary).
What SEBI says, word for word
FAQ Circular, Q4“"Research report" does not include the following communications: comments on general trends in the securities market; discussions on the broad-based indices; commentaries on economic, political or market conditions; periodic reports or other communications prepared for unit holders of Mutual Fund or Alternative Investment Fund or clients of Portfolio Managers and Investment Advisers; internal communications that are not given to current or prospective clients... technical analyses relating to the demand and supply in a sector or the index.”Source: SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/105, dated July 23, 2025 Open document ↗
FAQ Circular, Q5“Providing research services (including buy/sell/hold recommendation) on a security or securities based on any methodology (including the technical analysis) is not exempted from the purview of the RA Regulations. However, technical analyses relating to the demand and supply for a particular sector or index is exempted.”Source: SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/105, dated July 23, 2025 Open document ↗
More on Scope
- Can a person located outside India issue research reports on Indian securities?
- Who is exempt from registering as a Research Analyst?
- Are proxy advisers covered under RA Regulations?
- Do journalists giving stock tips on TV need SEBI registration?
- Do RA Regulations only cover equity shares, or all securities?
- I only do technical analysis. Does that put me outside the RA rules?