SEBI lets individuals register as research analysts and investment advisers, including on a part-time basis, but with limits. A part-time RA or part-time IA may have no more than 75 clients and must use the words part-time in its description. An individual IA that crosses 300 clients or ₹3 crore in fees must apply to become a non-individual IA within 3 months.
Part-time research analysts
Under Regulations 2(1)(nd) and 13(iii) and (iv) of the RA Regulations and para 1.4 and FAQ 22 of the RA Master Circular, a part-time RA must call itself a part-time research analyst in all client correspondence and may have no more than 75 clients. It must disclose its other activities and keep them at arm's length from research.
It must also show a prominent disclaimer, in at least 10 point font, on non-SEBI services and their invoices, making clear that those activities are not under SEBI's purview. From 16 December 2024, part-time RAs are also covered by the personal trading restrictions.
Part-time and individual investment advisers
Under Regulation 13(c), (d), (e) and (h) of the IA Regulations and paras 1(vi) and 1(viii) of the IA Master Circular, individual IAs must use the words investment adviser in correspondence. A part-time IA must use part-time investment adviser and serve no more than 75 clients.
An individual IA whose practice crosses 300 clients or ₹3 crore in fees must apply to become a non-individual IA within 3 months. Non-individual IAs must include the words investment adviser in their name. Track both numbers every month so the 3 month window is not missed.
Limits at a glance
The table compares the main limits that apply to part-time and individual practices. Rows appear only where the rule is stated in the RA or IA regulations and master circulars, and the IA size threshold described above is covered in the text rather than repeated here.
| Rule | Research analyst | Investment adviser |
|---|---|---|
| Part-time client cap | 75 clients | 75 clients |
| Part-time description | Part-time research analyst | Part-time investment adviser |
| Distribution by individuals | Not allowed | Not allowed for the IA and family to advisory clients |
Distribution and segregation for individuals
An individual RA must not offer distribution services. An individual IA and its family must not offer distribution to advisory clients. These rules are simpler than the group-level segregation that applies to non-individuals, but they still mean any commission income from advised or researched clients is off limits.
Deposit sized by client count
Every RA and IA keeps a deposit lien marked to BSE, in liquid or overnight fund units or a scheduled bank deposit. It is sized by the peak client count in the previous financial year and revised by 30 April. A part-time practice capped at 75 clients sits in the first tier.
| Peak clients in previous financial year | Deposit |
|---|---|
| Up to 150 | ₹1 lakh |
| 151 to 300 | ₹2 lakh |
| 301 to 1,000 | ₹5 lakh |
| Above 1,000 | ₹10 lakh |
Names on websites and social media
The naming rules apply on the website, letterheads, messages and invoices. From 1 May 2026, every social media handle must also show the SEBI registered name and registration number on its home page and at the start of each piece of securities market content. For a part-time practice, the registered name and the part-time description should match everywhere.
Monitoring the thresholds
Track client numbers and fees monthly so that a cap or threshold never comes as a surprise. Remember that a family counts as one client for fee limits and segregation, and collect the annual declaration of dependent family members. For help keeping these checks on a schedule, XDQ Labs offers XDQ xAgents for RAs and IAs (/product/xfintech-agents/). This guide is general information, not legal or investment advice. Confirm with your compliance officer.
Frequently asked questions
How many clients can a part-time research analyst have?
No more than 75. A part-time RA must also call itself a part-time research analyst in all client correspondence, disclose its other activities and show a non-SEBI disclaimer in at least 10 point font on other services and invoices.
When must an individual IA become a non-individual IA?
When it crosses 300 clients or ₹3 crore in fees, it must apply to become a non-individual investment adviser within 3 months, under Regulation 13 of the IA Regulations. Non-individual IAs must include investment adviser in their name.
Can an individual RA or IA earn distribution commission?
No. An individual RA must not offer distribution services, and an individual IA and its family must not offer distribution services to advisory clients. Any commission income from advised or researched clients is therefore off limits for individuals.
What deposit does a small RA or IA need?
₹1 lakh lien marked to BSE for up to 150 clients, based on the peak client count in the previous financial year. The tiers rise to ₹2 lakh, ₹5 lakh and ₹10 lakh, and the amount is revised by 30 April.
Sources
- Master Circular for Research Analysts, 6 February 2026, SEBI, 2026
- Master Circular for Investment Advisers, 6 February 2026, SEBI, 2026
- SEBI (Research Analysts) Regulations, 2014, amended up to 10 October 2026, SEBI, 2026
- SEBI (Investment Advisers) Regulations, 2013, amended up to 25 November 2025, SEBI, 2025
- RAASB and IAASB enlistment portal, BSE Limited, 2026
