SEBI registered research analysts and investment advisers must keep a defined set of records for at least five years, from research rationale and KYC to every communication with clients and prospects. The rules sit in RA Regulation 25 and IA Regulation 19. From 9 November 2026, RAs no longer have to keep call recordings of communications with institutional investors, though other records still apply.
The legal basis
For RAs, Regulation 25(1) and 25(2) of the RA Regulations and para 1.13 of the RA Master Circular list the records. For IAs, Regulation 19(1) and 19(2) of the IA Regulations and para 1(xiii) of the IA Master Circular do the same. Both set a minimum of five years, and records should be kept longer while a dispute is pending.
What to keep
The lists overlap but are not identical. The table shows the main items for each. Where a cell says not listed or not applicable, the item does not appear in that regulation's list, though related duties may still create a record you should keep.
| Record | Research analyst | Investment adviser |
|---|---|---|
| Research reports or advice given | Signed and dated reports and recommendations | Advice given |
| Rationale | Rationale for each report or recommendation | Signed and dated rationale |
| KYC | KYC of fee paying clients | KYC |
| Client register with PAN | Yes | Yes |
| Terms, consent or agreement | Terms and consent | Signed agreements |
| Risk profile and suitability | Not applicable | Risk profiles and suitability assessments |
| Public appearance records | Yes | Not listed |
| Communication, including with prospects | Yes | Yes |
Communication records and call recordings
Both RAs and IAs must keep records of all communication, including with prospective clients. That means keeping emails, chats and call recordings from the first contact, not only after onboarding. IAs offering implementation services must also keep time-stamped call recordings of each consent given by phone.
The RA Amendment Regulations 2026, in force from 9 November 2026, removed the requirement for RAs to keep call recordings of communications with institutional investors. Other communication records with institutional investors, and all records with other clients, still apply. Update the retention schedule.
Rationale and research support
Rationale is the record that shows why a call or recommendation was made. RA reports must rest on data, analysis and a documented rationale, including for technical calls. IA advice needs a suitability note showing why it fits the client's risk profile. Signed and dated versions, which can be digitally signed, are the safest form.
Other records linked to compliance
Several other duties create records that belong in the same system, even where the regulation lists them elsewhere. Keeping them together makes the annual audit faster and simpler, because the auditor can see each obligation and its evidence in one place.
- Approved advertisements, kept for five years
- Monthly complaint tables and the grievance log
- Annual audit reports and segregation certificates
- Personal dealing pre-approvals and trade logs for RA analysts
- One to one requests for certified pre-PaRRVA data
- NISM certification register with expiry dates
Setting up a retention schedule
Write a retention schedule that names each record type, where it is stored, who owns it and how long it is kept. Set five years as the floor and add a hold for any record linked to an open complaint or dispute. Store client data in a way that keeps it secure, since the RA or IA is solely responsible for its confidentiality and integrity, including when AI tools are used.
Making records easy to find
A record that exists but cannot be found in time is little help in an audit or a complaint. Index records by client PAN and date. For help keeping records and checks organised, 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 long must a SEBI RA keep records?
At least five years under Regulation 25 of the RA Regulations, and longer while a dispute is pending. This covers reports, rationale, KYC, the client register, terms and consents, and all communication including with prospects.
Do research analysts still need to record calls with institutions?
No. From 9 November 2026, under the RA Amendment Regulations 2026, call recordings of communications with institutional investors are not mandatory. Other communication records still apply. Keep recordings for other clients as before.
What records must an investment adviser keep?
KYC, risk profiles, suitability assessments, signed agreements, advice given, signed and dated rationale, a client register with PAN, and records of all communication including with prospects, for at least five years.
Do I need to keep messages with prospective clients?
Yes. Both RAs and IAs must keep records of all communication, including with prospective clients. Archive emails, chats and call recordings from the first contact. Keep them for at least five years.
Sources
- SEBI (Research Analysts) Regulations, 2014, amended up to 10 October 2026, SEBI, 2026
- SEBI (Research Analysts) (Amendment) Regulations, 2026, Gazette of 9 October 2026, SEBI, 2026
- SEBI (Investment Advisers) Regulations, 2013, amended up to 25 November 2025, SEBI, 2025
- Master Circular for Research Analysts, 6 February 2026, SEBI, 2026
- Master Circular for Investment Advisers, 6 February 2026, SEBI, 2026
- SEBI circular on the Past Risk and Return Verification Agency (PaRRVA), April 2026, SEBI, 2026
