SEBI Master Circular for Research Analysts (2026): What Changed and What You Must Do

The SEBI Master Circular for Research Analysts, in plain English

On 6 February 2026 SEBI issued a Master Circular for Research Analysts (reference HO/38/12/11(1)2026-MIRSD-POD/I/4360/2026). It pulls the circulars of the last few years into one document addressed to every RA and to the Research Analyst Administration and Supervisory Body (RAASB), which is BSE. The circulars listed in its appendix stand rescinded to the extent they relate to RAs, so this is now the document to work from.

The master circular does not replace the SEBI (Research Analysts) Regulations, 2014. The regulations set the obligations; the circular sets out how SEBI wants them met. You need both. This page is our hub for the changes: what moved and when, what each rule says, and where to read the detail.

What changed between 2024 and 2026

Most of what feels new in the master circular arrived through separate circulars and amendments from mid-2024 onwards. The dates below are taken from the master circular's footnotes and from the regulations as amended up to 10 October 2026.

Two things to note. The master circular has already been amended once (the cost accountants change in March 2026). And the regulations were amended again in October 2026. So check the SEBI website for updates before relying on any single version.

The rules at a glance

Fees: the cap and the advance-fee limit

For individual and HUF clients, an RA may charge up to ₹1,51,000 per annum per family. The limit covers all research services of the RA, does not include statutory charges such as GST, and does not apply to non-individual clients, accredited investors or institutional investors, whose fees are agreed bilaterally.

Paragraph 1.9 of the master circular says that, if the client agrees, an RA may charge fees in advance for up to one year. If the service ends early, the client gets a proportionate refund for the unexpired period, and no breakage fee may be charged. Note one inconsistency: the standard MITC text reproduced in Annexure B still says the advance period is "presently one quarter". Until that text is updated, make sure the MITC you give clients matches what you actually charge, and check the current RAASB version. Cash is not an accepted mode of payment. CeFCoM, BSE's centralised fee collection mechanism, is optional, but your terms must tell clients about it.

Deposit scaled to client count

There is no capital adequacy requirement for an RA. Instead, you keep a deposit lien-marked in favour of RAASB, as units of a liquid or overnight mutual fund or as a deposit with a scheduled bank. The amount depends on the maximum number of clients on any day of the previous financial year, and is revised by 30 April of the following year. Fee-paying and non-fee-paying clients both count.

Client-level segregation

A client can take research services or distribution services within your group or family, not both. PAN is the control record, and the family of an individual client counts as one client. You keep an annual certificate from a member of ICAI, ICSI or ICMAI, or an auditor, confirming segregation; it is obtained within six months of the financial year end and forms part of the compliance audit. Stock broking is not treated as distribution for this purpose, and clients who are institutional investors can sign a standard waiver.

Terms, MITC and KYC before any fee

An RA must disclose the terms and conditions of its research services and take the client's consent before rendering any service or charging any fee. The minimum terms are in Annexure B of the circular and include the MITC. Consent can be signed in person or by any legally acceptable mode, including DigiLocker-enabled Aadhaar e-signature. For existing clients, consent was due at the next renewal or the next fee collection, whichever came first.

KYC applies to fee-paying clients, and you collect, store, upload and check KYC records with a KRA. The practical order is KYC, then terms and MITC consent, then payment. Our guides on KYC before payment and MITC walk through it.

Records, AI disclosure and model portfolios

• Records of interaction. Keep records of every interaction about your services with clients and prospective clients, from the first contact until the service ends: signed physical records, call recordings, emails from the registered email ID, SMS records or other verifiable records. Keep them for five years, or longer if a dispute is open. Where the interaction is by email or another channel with a digital footprint, a call recording is not needed.
• Research rationale. Every research service must be backed by a research report with the data and analysis behind it. A bare technical chart with a timestamp is not enough on its own.
• AI tools. If you use AI tools to serve clients, you are responsible for client data security and for the output, and you must disclose the extent of AI use when you disclose your terms.
• Model portfolios. Model portfolio recommendations are research services and must follow the guidelines in Annexure A. The annual audit covers them.

Advertising, social media and performance claims

The advertisement code applies to social media posts, messaging platforms and, where they promote your services, research reports. It bans assured or target returns, misleading testimonials, superlatives like "best" or "No. 1", and the SEBI logo. Past performance can be advertised only if verified by a PaRRVA. Separately, since January 2025 regulated entities cannot have any arrangement with unregistered persons who give securities advice or make return claims. Details in our social media guide.

Reporting, audit and certification

• Monthly: complaint data on your website and app by the 7th, in the format in Annexure E. See the complaint data format.
• Half-yearly: periodic report to RAASB within 30 days of 30 September and 31 March, plus the SaaS advisory undertaking to SEBI. See annual and half-yearly reporting.
• Annually: compliance audit within six months of year end, with the report filed with RAASB/SEBI by 31 October at the latest. See the compliance audit checklist.
• Every five years: the registration fee to keep your registration in force. Registration itself does not expire.
• Before your NISM certificate expires: a fresh certificate, usually through the NISM Series XV-B renewal exam.

For all of these on one page by month, use our SEBI RA compliance calendar.

Dual registration and compliance officers

An individual or partnership firm registered as an Investment Adviser may also be registered as an RA, subject to conditions in the circular. You then carry both rulebooks. Our RA vs RIA comparison covers the differences. A non-individual RA may appoint an independent ICAI, ICSI or ICMAI member as compliance officer if that person holds the specified NISM certifications.

How to put this into practice

1. Map each rule to a system or a document. Fee cap and advance limit to your billing rules. Terms and MITC to your onboarding flow. Segregation to a certificate on file. Deposit to a finance plan tied to client count.
2. Keep evidence as you go. The audit and any inspection ask you to show compliance: dated consents, KYC records, research rationale, complaint registers and copies of advertisements.
3. Check for updates. The circular has been amended once already. Read new RA circulars on the SEBI website as they come out.

AlphaQuark covers much of the client-facing part on one platform: KYC and MITC e-sign before payment, payments and invoices, dated records of every recommendation, and model portfolio delivery with rebalancing across clients' brokers. See the RA platform.