A SEBI registered research analyst in 2026 works under the RA Regulations, 2014, as amended up to 10 October 2026, read with the Master Circular for Research Analysts dated 6 February 2026. BSE supervises RAs as the Research Analyst Administration and Supervisory Body for five years from 25 July 2024. This checklist groups the main duties by area so you can test your own setup against each one.
The 2026 rulebook for research analysts
The RA Regulations have changed several times since late 2024. The Third Amendment Regulations 2024 came into force on 16 December 2024, the Second Amendment Regulations 2025 on 25 November 2025, and the Amendment Regulations 2026 on 9 November 2026. The Master Circular for Research Analysts dated 6 February 2026 (HO/38/12/11(1)2026-MIRSD-POD/I/4360/2026) pulls the circulars together, and later circulars add to it.
Anyone who gives research reports or buy, sell or hold recommendations on securities for consideration must be registered with SEBI and enlisted with BSE as RAASB. If you have not reread your policies since the master circular was issued, start there, because several clause numbers and templates now point to it.
Registration, certification and deposit
The individual RA, the principal officer and every client-facing associated person must hold the relevant NISM certification and renew it before it expires. The master circular set 23 July 2026 as the date by which associated persons had to be certified. The RA renewal exam, NISM Series XV-B, opens in the 12 months before expiry and a renewal certificate is valid for 3 years.
Registration stays valid until suspended or cancelled, but the SEBI fee must be paid every five years (₹1,000 for individuals and partnership firms) along with the BSE administrative fee. You must also keep a deposit lien marked to BSE, sized by the peak number of clients in the previous financial year and revised by 30 April.
| Peak clients in previous financial year | Deposit lien marked to BSE |
|---|---|
| Up to 150 | ₹1 lakh |
| 151 to 300 | ₹2 lakh |
| 301 to 1,000 | ₹5 lakh |
| Above 1,000 | ₹10 lakh |
Client terms, fees and payments
Before giving any research service or charging any fee, disclose the minimum mandatory terms in Annexure B and the standard MITC, and get the client's consent. Fees for individual and HUF clients who are not accredited investors are capped at ₹1,51,000 per year per family, excluding statutory charges. Advance fees cannot cover more than one year, early termination needs a pro rata refund, and no breakage fee is allowed.
Fees may come only through traceable banking channels such as cheque, demand draft, NEFT, RTGS, IMPS or UPI, never cash. You must obtain and display a validated @valid UPI ID under the circular of 11 June 2025. Client terms must also explain BSE's optional Centralised Fee Collection Mechanism (CeFCoM) and encourage clients to use it.
Research reports and personal conduct
Every research report must disclose financial interest, ownership of 1% or more, other material conflicts, compensation from the subject company in the past 12 months, any role in managing a public offer, any position as officer, director or employee, and any market making. Reports must define the rating system, including time horizon and benchmark, and rest on documented data, analysis and rationale.
Your written dealing policy must stop trading in a recommended or followed security from 30 days before to 5 days after a report, and must bar trading against your own call. When you or your staff speak on TV, the internet or social media, state your registration status and any financial interest in the company discussed.
- Model portfolios go out only through a research report with a true to label factsheet
- Disclose the extent of AI tool use when sharing terms with clients
- Show a daily closing price chart where a rating or target has been held for at least a year
Keeping research apart from distribution
An individual RA must not offer distribution services. A non-individual RA must make sure the same client does not receive both research and distribution within its group. Clients are tracked by PAN and a family counts as one client. The segregation needs an annual auditor certificate, obtained within six months of the end of the financial year.
A simple way to manage this is to ask each new client at onboarding which service they want, record the answer against their PAN, and collect the annual declaration of dependent family members so that the family view stays current.
Website, complaints and advertising
Keep a functional website that shows your registered name, logo, registration number and full address with phone, together with the standard disclaimer that SEBI registration, BSE enlistment and NISM certification in no way guarantee performance or assure returns. Publish the current investor charter, and post complaint data in the SEBI format by the 7th of each month for the previous month.
Resolve grievances within 21 calendar days and publish an escalation matrix that points to SEBI SCORES and the SMART ODR portal. Every advertisement, including social posts and messages, needs BSE's prior approval and the unaltered standard risk warning in at least 10 point font. From 1 May 2026, social media handles must show the registered name and number.
Records, audit and periodic filings
Keep signed and dated reports, recommendations, rationale, public appearance records, KYC of fee paying clients, a client register with PAN, the terms and consents, and records of all communication, including with prospects, for at least five years. From 9 November 2026, call recordings with institutional investors are no longer mandatory, though other records still apply.
| Obligation | When |
|---|---|
| Monthly complaints data | By the 7th of each month |
| Annual compliance audit completed | By 30 September |
| Audit report and adverse findings to BSE | Within one month of the report, no later than 31 October |
| Half-yearly periodic report to BSE | By 30 October and 30 April |
| Deposit revision | By 30 April |
| SaaS advisory undertaking | Half-yearly |
Putting the checklist to work
Gaps often sit between policy and practice: a fee plan that crosses the cap, a refund clause still written for the old rule, or a social post that went out without approval. Give each item above an owner and a review date. If you want help running these checks as a routine, 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
What is the fee limit for a SEBI research analyst?
For individual and HUF clients who are not accredited investors, research fees are capped at ₹1,51,000 per year per family of client across all research services, excluding statutory charges. BSE revises this limit once every three years using the Cost Inflation Index, after consulting SEBI.
How long must a research analyst keep records?
At least five years. This covers research reports, rationale, public appearance records, KYC, the client register with PAN, terms and consents, and communication with clients and prospects. Keep records longer while a dispute is pending.
When is the annual compliance audit due for RAs?
Complete the audit within six months of the financial year end, so by 30 September. Submit the report and any adverse findings with action taken to BSE or SEBI within one month of the report, and no later than 31 October.
Do research analysts need BSE approval for social media posts?
Yes. Every advertisement, including social media posts and messages, must be approved in advance by BSE, carry the registered details and the standard risk warning in at least 10 point font, and be kept for five years.
Sources
- Master Circular for Research Analysts, 6 February 2026, SEBI, 2026
- 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
- Clarification on eligibility of members of the Institute of Cost Accountants of India to conduct annual audit of Research Analysts, 25 March 2026, SEBI, 2026
- RAASB and IAASB enlistment portal, BSE Limited, 2026
- Frequently asked questions: Research Analyst certification renewal examination, NISM, 2026
