How to collect subscription payments as a SEBI Research Analyst

How to collect subscription payments as a SEBI Research Analyst

Collecting money is where an RA practice most often slips out of compliance without noticing. A UPI QR code in a WhatsApp chat, a payment taken before the agreement is signed, an annual plan that cannot be refunded: each one breaks a specific SEBI rule. This guide covers the order of steps, the fee rules, the payment modes SEBI accepts, choosing a gateway, GST invoices and refunds. References are to the SEBI Master Circular for Research Analysts (6 February 2026) unless stated otherwise.

The order of steps is a rule, not a preference

Para 1.12 says an RA must make sure "neither any research service is rendered nor any fee is charged until consent is received from the client on the terms and conditions". The terms must include the Most Important Terms and Conditions (MITC). So every subscription follows this sequence:

1. KYC of the fee-paying client (para 1.13).
2. Show the terms and MITC and record consent. Consent can be a physical signature or any legally acceptable mode, including Aadhaar-based e-sign.
3. Collect the fee.
4. Start the service.

Taking payment first and sending the agreement later reverses steps 2 and 3. That is the most common gap auditors find. For what the MITC must say, see our agreement and MITC guide, and for KYC options see digital KYC for RAs.

Fee rules for individual and HUF clients

Para 1.9 sets the fee rules. They apply to individual and HUF clients who are not accredited investors. For non-individual clients and accredited investors, fees are agreed bilaterally.

One inconsistency to watch: the one-year advance limit came from SEBI's April 2025 circular and is in para 1.9(f). The standard MITC text reproduced in Annexure B of the same master circular still says the advance limit is "presently one quarter". If your MITC still says one quarter, either collect at most a quarter in advance or update your MITC with your compliance adviser so that what you collect matches what the client signed. For more on pricing, see our fee structure guide.

Payment modes SEBI accepts

• Banking channels only. The MITC lists cheque, online bank transfer and UPI as examples, and says cash is not allowed. The investor charter tells clients to pay only through banking channels and keep receipts.
• A SEBI-validated UPI ID. Under the SEBI circular of 11 June 2025, investor-facing intermediaries, including RAs, must obtain a structured UPI ID with the "@valid" handle and make it available to clients. The username ends in ".ra" for a Research Analyst, and payments to it show a green "thumbs-up" icon. Clients may still use other modes, but you must offer it. Check with your bank for the current status of the rollout.
• CeFCoM, optional. BSE runs a Centralised Fee Collection Mechanism for RAs and IAs. It is optional, but your terms must guide clients about it (para 1.9(h) and Annexure B). See our CeFCoM explainer.

Choosing a payment gateway

SEBI does not approve particular gateways. What matters is that the money trail is clean and matches your records. Practical tests:

• Money settles into a bank account in your registered name, ideally the account you gave in your RAASB application. Do not collect through a personal account of a relative or staff member, or through a creator platform that pools funds.
• Each payment links to a client. The gateway should carry the client's identity and plan so you can match payment to KYC and consent.
• Recurring payments need consent. If you use eNACH or UPI Autopay, the mandate amount and frequency must match the agreed fee, and any amount collected in advance must stay within the one-year limit.
• Refunds are easy to issue and leave a record.
• Exports work for your accountant and your auditor.

SEBI's April 2026 order against two unregistered Telegram channels is a useful counter-example: fees were collected through creator-platform payment links, one account was opened using another person's PAN, and anyone who paid was added to a paid channel. A registered RA should be able to show the opposite at every step. See running a compliant Telegram channel.

GST invoices

Research services attract 18% GST, and registration is generally required once your turnover crosses ₹20 lakh in a year (₹10 lakh in special-category states). Because statutory charges sit outside the SEBI fee limit, show the fee and GST separately on the invoice. An invoice should carry your registered name, SEBI registration number, GSTIN (once registered), the client's name, the plan and its period, the fee, the tax and the payment reference. Our tax guide for RAs covers GST and TDS in more detail.

If you are a part-time RA, your invoices for your other business must carry a prominent disclaimer, in at least 10-point font, that those services are not under SEBI's purview and no complaint about them can be raised with SEBI (para 1.4(e)).

Write a refund policy you can follow

Your refund policy should be in your terms, on your website and consistent with SEBI's rules:

• How a client ends the subscription, and from what date the refund is calculated.
• The proportionate refund formula for the unexpired period, with no breakage fee.
• How and when you pay the refund: same banking channel, and a stated timeline.
• What happens if your registration is suspended or cancelled.

"No refunds" on a fee paid in advance by an individual client conflicts with para 1.9(g). Remove it if your policy says it.

Keep the records

For each subscription, keep the KYC, the signed terms and MITC, the payment record, the invoice, any refund and all interactions with the client. Records must be kept for five years, and longer if a dispute is open. The auditor will sample them, and they feed the client numbers in your half-yearly report to RAASB. See the RA compliance calendar.

Where AlphaQuark fits

AlphaQuark runs this sequence for SEBI-registered RAs: KYC and MITC e-sign before payment, collection of one-time and recurring subscription payments, and access to Telegram or WhatsApp that starts after payment and ends when the plan expires. See pricing.