From November 8, 2026, you do not have to record calls with clients who are institutional investors. Your other record-keeping duties stay the same.
SEBI has made call recordings optional for your interactions with clients who are institutional investors. The circular is dated October 23, 2026, and the change takes effect from November 8, 2026.
SEBI says it has already notified an amendment to Regulation 25(1)(vii) of the RA Regulations to allow this. The circular now brings the Master Circular for Research Analysts dated February 6, 2026 in line with that amendment. The document does not give the date of the regulation amendment.
The main change is a new proviso in paragraph 1.13 of Chapter I of the Master Circular. Until now, you had to keep records of interactions with all clients, and call recordings were one of the listed forms. The proviso says the requirement to maintain call recordings of interactions with clients which are institutional investors shall not be mandatory. From November 8, 2026, you can stop recording calls with institutional clients.
The relief covers call recordings only. You must still keep records of interactions with all clients, including prospective clients before onboarding, wherever a conversation about your services takes place. The listed forms remain a physical record written and signed by the client, call recordings, email from a registered email id, a record of SMS messages, or any other legally verifiable record. The records start from the first interaction and continue until you complete your research services to that client.
Nothing changes for your other clients. If you speak to a retail client on a call about your services, you still record it. The FAQ at paragraph 33 of Annexure I of Chapter VII keeps the rule that these records apply to fee-paying and non-fee paying clients. It also keeps the clarification that you do not need a call recording when the interaction happens by email or another channel that leaves a digital footprint. The same institutional investor proviso has been added to this FAQ answer.
The retention period is unchanged. You keep these records for five years. If a dispute has been raised, you keep them until it is resolved. If SEBI asks you to preserve specific records, you keep them until SEBI tells you otherwise.
The circular does not define institutional investor. It does not say how you should identify or tag such clients, and it does not say what happens to call recordings you already hold for them.
RAASB has been asked to amend its bye-laws and rules to implement the change and to inform registered Research Analysts. All other provisions of the Master Circular remain unchanged.
“Provided that the requirement to maintain call recordings of interactions with clients which are institutional investors shall not be mandatory.”
Review of regulatory requirement for maintenance of call records of institutional clients by Research Analysts or Research Entities, paragraph 4.1, new paragraph 1.13(b)(i) of Chapter I of the Master Circular
The document
Review of regulatory requirement for maintenance of call records of institutional clients by Research Analysts or Research Entities on sebi.gov.in.
This summary is prepared from the SEBI document linked above. Read the original before you act on it.