Investment Research Report Writing: SEBI Requirements, Template and Disclosures

Investment Research Report Writing: SEBI Rules and a Practical Template

The research report is the core product of a SEBI-registered research analyst. Whether it is a full initiating-coverage note, a short update after results, a sector piece or the note that goes out with a model-portfolio rebalance, it carries your reasoning, your disclosures and your regulatory obligations. It is also the most honest sales document you will ever produce: it cannot promise returns or hide conflicts, yet a clear report does more to win and keep subscribers than any landing page.

This guide covers what the SEBI (Research Analysts) Regulations, 2014 require a report to contain, a practical structure, how to write for credibility, and how to distribute reports without breaking the rules.

What a research report must contain under SEBI rules

The requirements below come from the RA Regulations as consolidated on sebi.gov.in (last amended 10 October 2026). Use them as a checklist, and check the current text before you finalise your template.

1. Every recommendation must be backed by the report

Since the December 2024 amendments, Regulation 20(4) requires that the recommendations in a research report are corroborated by relevant data and analysis forming the basis of the research service. In practice: a call sent on Telegram or WhatsApp without an underlying report is not compliant. Facts must be based on reliable information (Regulation 20(1)).

2. Defined terms and ratings

• Define the terms you use in recommendations (for example "Buy", "Accumulate", "Exit") and use them consistently.
• If you use a rating system, define each rating, including the time horizon and the benchmark it is based on (Regulation 20(2)).
• If a report carries a rating or price target, and you have rated or set a target on that security for at least a year, include a graph of its daily closing price for the period covered or three years, whichever is shorter (Regulation 20(3)).

3. Conflict-of-interest and compensation disclosures

Regulation 19 requires disclosure of all material information about yourself, including your business activity, disciplinary history, the terms on which you offer research and details of associates. In each report, disclose:

• Whether you, your associates or relatives have any financial interest in the subject company, and its nature.
• Whether you, your associates or relatives own 1% or more of the subject company's securities at the end of the month before publication.
• Any other material conflict of interest at the time of publication.
• Whether you or your associates received any compensation from the subject company in the past twelve months, managed or co-managed a public offering for it, or received compensation for investment banking, merchant banking, brokerage or other products or services from it in that period.
• Whether you or your associates received any compensation or benefit from the company or a third party in connection with the report.
• Whether the analyst has served as an officer, director or employee of the subject company, and whether you have been engaged in market making in it.
• The extent to which you use AI tools in providing research services (Regulation 19(vii)). SEBI's January 2025 guidelines say this is disclosed with your terms and conditions and updated when needed. You remain solely responsible for research based on AI output.

4. Standard warnings

Research reports fall within the forms of communication covered by SEBI's advertisement code for IAs and RAs. Carry your SEBI-registered name, registration number and the standard warning: "Investment in securities market are subject to market risks. Read all the related documents carefully before investing." Add the disclaimer that SEBI registration and NISM certification do not guarantee performance or assure returns. Do not imply assured, minimum or target returns, or "percentage accuracy".

5. Model portfolio reports

A model portfolio is issued through a research report and has extra requirements under SEBI's January 2025 guidelines: a factsheet, the methodology and stock-selection universe, a true-to-label name, the investment horizon, a predefined review frequency, risk disclosures and a consistently used benchmark. See how to build a model portfolio for the full list.

6. Records and your own trading

• Keep each research report signed and dated, the recommendation, and the rationale for it, for at least five years. Records kept electronically that must be signed must be digitally signed (Regulation 25).
• Independent and part-time RAs and their associates must not trade in securities they recommend or follow within thirty days before and five days after publishing a report, or trade against their own recommendation (Regulation 16).

A practical report structure

SEBI does not prescribe a format. This order works for most single-stock reports.

1. Summary and recommendation

Lead with the recommendation, using your defined terms, the current price, your price framework and the time horizon. Then state the thesis in one or two sentences a busy reader could repeat. Not "we are positive on the stock" but the actual claim, for example: "The market prices this as a cyclical, but recurring revenue is now large enough to justify a different multiple."

2. The business

What the company does, where its revenue comes from, its competitive position and the key financial metrics a reader needs for context.

3. Thesis and variant view

Your edge is not the recommendation itself but why the market is wrong. Name the consensus view, then show specifically where you differ and why. List the three to five drivers behind the call, the catalysts, and when you expect them to play out.

4. Financials and valuation

Show historical performance, your estimates with assumptions stated, and the bridge from your numbers to a value range (DCF, P/E, EV/EBITDA or whatever suits the business). Present a target as a framework, for example "at 18x FY28 earnings, fair value is X", never as a guarantee. A reader who can follow the chain from driver to earnings to multiple will trust the output even if they would choose different inputs.

5. Risks

List what would break the thesis: company risks such as customer concentration or key-person dependency, industry risks such as competition or regulation, and macro risks. Describe the downside scenario. Stating the bear case in your own words, and then explaining why you still hold your view, is the most persuasive paragraph in any report.

6. Action and exit framework

Say what a subscriber should do, at what price range, over what horizon, and what would make you review or exit. A buy call with no exit criteria is incomplete.

7. Disclosures

A complete, consistent disclosure block at the end, covering everything in the SEBI section above. Build it into your template so it is never forgotten.

Types of report and when to use them

• Initiating coverage: the full analysis when you first recommend a stock.
• Update notes: after results, corporate actions or a change in view. Focus on what changed and whether the thesis still holds.
• Sector reports: trends, competitive dynamics and relative positioning across a sector.
• Rebalance notes: the most frequent report for model-portfolio RAs. State each addition, removal or weight change with its rationale.

Write for credibility

• Be specific. "Strong growth prospects" says nothing. Give the numbers behind the claim and their source.
• Separate fact from estimate. Label projections clearly and state the assumptions behind them.
• Write for retail readers. Explain technical terms briefly. Clear beats impressive.
• Do not lean on management guidance. Test it rather than repeat it.
• Revisit old calls in writing, including the ones that did not work. Never quietly edit a published thesis.

Distribute reports fairly and on permission

• No early access for some clients. Regulation 22(1) bars making a report available selectively to a particular client or class of clients before others entitled to receive it. Higher-priced plans can include more research, but not the same call earlier.
• Open the thesis, gate the detail. Educational summaries can be public. The full model, price framework and position guidance belong with paying subscribers.
• Send only to people who opted in. Unsolicited tips with return claims are exactly what SEBI's advertisement and finfluencer scrutiny targets.
• Performance claims need PaRRVA. If a report refers to how past calls performed, the figures for the period after 4 May 2026 must be PaRRVA-verified. See our PaRRVA explainer.
• Third-party research: if you distribute another provider's report, review it for misleading statements and disclose that provider's material conflicts or link to them (Regulation 22).

For delivery channels, see client communication for research analysts. For the wider compliance picture, see the 2026 RA master circular guide and the SEBI RA compliance calendar.

Publishing reports on AlphaQuark

On AlphaQuark, RAs upload research reports and choose which plans can see them, so each subscriber sees the reports their plan covers and every report is dated. Model-portfolio rebalances go out with their rationale, are stored as time-stamped advice records, and can be acted on through the client's own broker. See the SEBI RA software platform.