SEBI RA Reporting Guide: Annual and Half-Yearly Filings for Research Analysts

Annual and half-yearly reporting for SEBI Research Analysts

Many RAs search for a single "SEBI annual return". Under the current framework there isn't one form that does everything. Instead, a registered Research Analyst has a set of recurring filings and disclosures: a half-yearly periodic report to the Research Analyst Administration and Supervisory Body (RAASB, which is BSE), a half-yearly undertaking to SEBI, monthly complaint data on your own website, and annual items led by the compliance audit. They are set out in SEBI's Master Circular for Research Analysts dated 6 February 2026.

This guide covers what you report, when and to whom. The annual compliance audit has its own guide: SEBI compliance audit for research analysts.

Every recurring filing at a glance

The half-yearly periodic report to RAASB

Paragraph 29 of the master circular requires RAs to submit a periodic report for the half-years ending 30 September and 31 March, within 30 days of the end of each half-year. The report goes to RAASB in the format RAASB notifies in consultation with SEBI. Since the RAASB framework began, periodic reports go to RAASB rather than directly to SEBI.

Timelines can be extended. For example, the report for the half-year ended 31 March 2025 was allowed until 31 July 2025. Check RAASB's circulars each cycle instead of assuming last year's date.

The client count you report includes both fee-paying clients and non-fee-paying clients who receive research as a value-added service. The same count decides your deposit.

Numbers to have ready from your records

Use RAASB's current format for the exact fields. These are the figures your records should be able to produce at any time, because the regulations already require you to keep them:

• Number of clients, split into fee-paying and non-fee-paying, and the maximum on any day.
• Your client register: each client's PAN, the date and nature of the research service, the securities covered and the fee charged.
• Complaints received, resolved and pending, by source.
• Research reports and recommendations issued, with rationale.
• Certification status of you and everyone associated with research services.

The half-yearly SaaS undertaking to SEBI

SEBI has passed on a CERT-In advisory about Software as a Service solutions used by financial sector organisations. The concern is critical data leaving India's legal boundary. RAs must report compliance with the advisory half-yearly to SEBI with this undertaking: "Compliance of the SEBI circular for Advisory for Financial Sector Organizations regarding Software as a Service (SaaS) based solutions has been made." Before you sign it, check where your vendors store client data.

Monthly complaint data

By the 7th of every month, publish on your website and mobile app (if you have one) the complaints received and resolved in the previous month, in the format in Annexure E of the master circular. Months with no complaints still need a table showing zeros. The format and a template are in our monthly complaint data guide.

Annual items

• Deposit review by 30 April. Check the maximum number of clients on any day of the previous year against the slabs: ₹1 lakh up to 150 clients, ₹2 lakh for 151–300, ₹5 lakh for 301–1,000 and ₹10 lakh above 1,000. Top up the lien-marked deposit if you crossed a slab.
• Segregation certificate. An annual certificate confirming client-level segregation of research and distribution, obtained within six months of year end.
• Compliance audit. Completed within six months of year end and filed with RAASB/SEBI within one month of the audit report, with adverse findings filed by 31 October at the latest. Publish the status on your website and give the report to clients. Details in the compliance audit checklist.

Less frequent and event-driven items

• Five-yearly registration fee. RA registration does not expire, but you pay a fee every five years to keep it in force (₹1,000 for individuals and partnership firms, ₹5,000 for body corporates including LLPs), within three months before the paid period ends.
• NISM certification. Get a fresh certificate before the existing one expires. See NISM Series XV and renewal.
• Change in control. Take SEBI's prior approval before it happens.
• Information SEBI asks for. The regulations require you to furnish information and reports as SEBI specifies from time to time.

The reporting year, month by month

Our SEBI RA compliance calendar combines these with every other RA deadline.

Keep records so reporting is an export

Every figure above comes from records the regulations already require you to keep for at least five years: the client register, KYC, terms and consents, research reports with rationale, records of client interactions and complaints. If those are kept as you go, each report is a matter of pulling numbers, not rebuilding the half-year from chat history.

AlphaQuark keeps client onboarding, payments and every recommendation in one place with timestamps, so client counts, client registers and research records are ready when a filing is due. See the RA platform.