From February 6, 2026 your obligations sit in one reference, and the 47 older circulars it lists are rescinded so far as they relate to Research Analysts.
SEBI's master circular dated February 6, 2026 brings every circular that applies to Research Analysts into one place. The 47 circulars listed in its Appendix, dated from March 23, 2011 to December 10, 2025, stand rescinded to the extent they relate to Research Analysts. Anything you did under those circulars is treated as done under the matching part of the master circular, and pending applications carry over. It is in force now.
The circular does not mark which provisions are new. Most of it repeats earlier circulars, and several deadlines in it, such as June 30, 2025 for model portfolio compliance and September 30, 2025 for partnership firms without a qualified partner, have already passed. Use it as your single checklist from now on.
Deposit and fees
Your deposit depends on the highest number of clients you had on any day of the previous financial year. Up to 150 clients means ₹1 lakh, 151 to 300 means ₹2 lakh, 301 to 1,000 means ₹5 lakh, and 1,001 or more means ₹10 lakh. You can hold it in a liquid mutual fund, an overnight mutual fund or a scheduled bank deposit, lien marked to RAASB, and you revise it by 30 April. Count non-fee paying clients too. FAQ 34 says your client number is fee-paying plus non-fee paying clients.
For individual and HUF clients who are not accredited investors, you can charge at most ₹1,51,000 a year per family, excluding statutory charges. Cash is not allowed. If a client ends the service early, you refund the unexpired period pro rata and charge no breakage fee. On advance fees the circular is inconsistent. Paragraph 1.9(f) allows up to one year if the client agrees, but the MITC text in Annexure B says the limit is one quarter. The circular does not resolve this, so check which wording your client documents use.
Your reporting calendar - Half-yearly report to RAASB within 30 days of September 30 and March 31. - Complaint data on your website and app by the 7th of each month, in the Annexure E format. - Annual compliance audit within six months of the financial year end, report to RAASB/SEBI within one month of the audit report and no later than October 31. - Audit status and any adverse findings, with action taken, published on your website, and the audit report given to clients. - An annual certificate on client-level segregation of research and distribution, kept on record as part of the audit. - A half-yearly undertaking to SEBI on the SaaS advisory.
With clients, you disclose the terms and conditions including MITC and get consent before you deliver any research or take any fee. Institutional investors and QIBs need disclosure only, not consent. You disclose how far you use AI tools, and you remain solely responsible for what those tools produce. You keep records of every service-related interaction, including with prospects before onboarding, for five years, or longer if a dispute is open. Every recommendation must be backed by a research report with the data and analysis behind it.
On past performance, you cannot advertise returns unless PaRRVA has verified the metrics. Until PaRRVA starts work, you may share figures certified by an ICAI or ICMAI member only when a client specifically asks, one to one, with the prescribed disclaimer, and never on your website or in public media. To keep doing this you must enrol with PaRRVA within three months of it starting. Two years after it starts, only PaRRVA-verified metrics are allowed. The circular does not give a start date for PaRRVA.
Anyone in your practice who deals with clients in connection with research must hold the relevant NISM certification within one year from July 23, 2025. Staff with no client contact, or whose work has no connection to your research, do not need it.
“RA or research entity are required to maintain these records for a period of five years.”
Master Circular for Research Analysts, paragraph 1.13(d)
The document
Master Circular for Research Analysts on sebi.gov.in.
This summary is prepared from the SEBI document linked above. Read the original before you act on it.