MITC for research analysts
MITC stands for Most Important Terms and Conditions. It is a short, standard set of terms that every SEBI-registered Research Analyst must disclose to clients as part of its terms and conditions. The MITC was standardised by the Industry Standards Forum in consultation with SEBI and RAASB, and required by SEBI's circular of 17 February 2025. Both the minimum terms and the MITC are now in Annexure B of SEBI's Master Circular for Research Analysts dated 6 February 2026.
Two rules matter more than any clause:
- Consent before service and before fees. The master circular says an RA shall ensure that neither any research service is rendered nor any fee is charged until consent is received from the client on the terms and conditions.
- Consent can be electronic. The client may sign in person or through any other legally acceptable mode, including DigiLocker-enabled Aadhaar-based e-signature.
Many RAs still call this document a "subscriber agreement" or "client agreement". The label does not matter. What matters is that it contains the minimum terms below, including the MITC, and that you have the client's consent before you take money.
The 13 minimum terms
Annexure B lists the terms every RA must disclose. Several have fixed wording that you copy as given.
| # | Clause | What it must say |
|---|---|---|
| 1 | Availing the research services | The client chose to subscribe at their own discretion; the RA will render services under the RA Regulations |
| 2 | Obligations on RA | Both parties are bound by the SEBI Act, rules and regulations |
| 3 | Client information and KYC | The client gives the details the RA's form needs; the RA collects, stores, uploads and checks KYC records with a KYC Registration Agency (KRA) |
| 4 | Standard terms of service | The client's prescribed declaration (market risk, no assurance of returns, no recourse for losses) and the RA's declarations: registration number and date, valid qualifications, no conflict with law, the ₹1.51 lakh fee limit, no assurance of returns. Individual RAs also declare that no other whole-time or executive activity affects their independence |
| 5 | Consideration and mode of payment | The client pays the agreed fee and statutory charges in the specified manner |
| 6 | Risk factors | Your statement of the standard risks of investing in securities |
| 7 | Conflict of interest | Your mandatory conflict-of-interest disclosures |
| 8 | Termination and refund | If your registration is suspended for more than 60 days or cancelled, you refund fees pro rata from that date to the end of the subscription |
| 9 | Grievance redressal and disputes | Name and email of your designated person; service grievances resolved within 7 business working days; disputes by arbitration or another SEBI mode |
| 10 | Additional clauses | Your own clauses may not contravene SEBI rules; changes need 15 days' notice |
| 11 | Mandatory notice | Ask clients to read SEBI's Do's and Don'ts for dealing with RAs |
| 12 | MITC | The standard Most Important Terms and Conditions, below |
| 13 | CeFCoM | Guidance on the optional Centralised Fee Collection Mechanism |
The 12 MITC points
Use the standard text from Annexure B. Here is what each point says, in short.
| Point | In plain words |
|---|---|
| i | The RA cannot trade on the client's behalf. Do not let the RA execute trades for you. |
| ii | Fees are capped for individual and HUF clients: currently ₹1,51,000 per year per family for all the RA's research services, excluding statutory charges. The cap does not apply to non-individual clients or accredited investors. |
| iii | Fees may be charged in advance if the client agrees, within the period SEBI allows. On early termination by either side, the client can claim a refund for the unexpired period. |
| iv | Pay by cheque, bank transfer, UPI and similar modes. No cash. CeFCoM run by BSE is optional. |
| v | The RA follows SEBI and RAASB rules on conflicts of interest and will tell the client promptly about any conflict. |
| vi | Assured, guaranteed or fixed-return schemes are prohibited and will not be offered. |
| vii | The RA cannot guarantee returns, profits, accuracy or risk-free investments. Opinions are based on data and assumptions as of the report date. |
| viii | Investments are subject to market risk, there is no assurance of returns and no recourse for losses. Reliance on the report is the client's own judgement. |
| ix | SEBI registration, RAASB enlistment and NISM certification do not guarantee performance or returns. |
| x | Grievances: first the RA (your escalation matrix), then SEBI SCORES, then SMART ODR. |
| xi | Keep your email and mobile number updated with the RA. |
| xii | The RA will never ask for logins or OTPs for your trading, demat or bank accounts. Never share them with anyone. |
One inconsistency to watch: point iii of the standard MITC text says the advance-fee period is "presently one quarter", while paragraph 1.9 of the same master circular allows advance fees for up to one year. Make sure the MITC you give clients matches what you actually charge, and check RAASB for the current version before moving clients to annual billing. See what fees an RA may charge.
What you add yourself
The standard text leaves blanks and placeholders for you to fill in:
- Your registration number and registration date in the RA declaration.
- Your risk statement (clause 6) and conflict-of-interest disclosures (clause 7).
- Your designated grievance person's name and email (clause 9) and your escalation matrix (MITC point x).
- The plan: what the subscriber gets, how often, through which channels, the fee, the period and how refunds are calculated.
- The extent of your use of AI tools, if any. Regulation 24(7) requires you to disclose this to clients.
Any extra clauses you add must not contradict SEBI's rules, and clients must get 15 days' notice before you change them. A clause that tries to exclude the client's right to a pro-rata refund, or binds them to something the regulations forbid, will not hold. The investor charter tells clients they are not bound by such clauses.
The right order: KYC, e-sign, then payment
| Step | What happens | Why it is in this order |
|---|---|---|
| 1. Collect details | Name, PAN, contact details, date of birth | Needed for KYC and for the family-level fee check |
| 2. KYC | Fetch or check the client's KYC with a KRA | KYC is required for fee-paying clients |
| 3. Show terms and MITC | The full terms, MITC, fee and plan details, investor charter | The client must see what they are agreeing to |
| 4. Consent by e-sign | Aadhaar-based e-sign through DigiLocker, or another legally acceptable mode | No service and no fee until consent is received |
| 5. Payment | Collect the fee by a non-cash mode and issue an invoice | Only now may a fee be charged |
| 6. Access | Start the service for the paid period | Service follows consent |
The common mistake is taking payment first through a payment link and sending the terms afterwards. That breaks the consent-before-fee rule, and it is one of the first things a compliance auditor checks. See KYC before payment for RAs and our guide to collecting subscription payments.
Existing clients and renewals
For existing clients, you must disclose the terms and take consent on or before the date their subscription renews, or the date the next fee falls due, whichever is earlier. If you change your terms, take fresh consent at the next renewal rather than relying on an old signature.
Institutional clients
Since SEBI's circular of 23 July 2025, consent by signature on the terms and MITC is not mandatory for institutional investors and qualified institutional buyers. You must still disclose the terms and MITC to them.
Keep the record
Keep the signed or e-signed terms with a timestamp, the version the client signed, and the link to the payment that followed. The regulations require records to be kept for at least five years, and longer if a dispute is open. When a client complains about a refund or a service, the signed MITC is the first document you will need. See handling SCORES complaints.
A quick check of your terms
- Does it contain all 13 minimum terms, with the standard wording where SEBI gives it?
- Is the MITC the current standard text, and does the advance-fee period match what you charge?
- Are your registration number, grievance contact and escalation matrix filled in?
- Do you disclose your use of AI tools?
- Can any client reach the payment page without first e-signing?
AlphaQuark runs this flow for RAs under their own brand: KYC with KRA lookup, MITC e-sign, then payment and invoice, with each step recorded against the client. See the RA platform.
Take consent before you take money
AlphaQuark runs KYC, MITC e-sign and payment in the right order for SEBI-registered Research Analysts, under your own brand.
See the RA platformFrequently Asked Questions
What is MITC for research analysts?
MITC means Most Important Terms and Conditions: a standard set of 12 points, standardised by the Industry Standards Forum with SEBI and RAASB, that RAs must disclose to clients as part of their terms. It is in Annexure B of SEBI's February 2026 master circular for RAs.
Can a research analyst take payment before the client signs the MITC?
No. The RA must not render any research service or charge any fee until the client has consented to the terms and conditions, which include the MITC.
Is Aadhaar e-sign valid for MITC consent?
Yes. Consent can be given in person or through any legally acceptable mode, including DigiLocker-enabled Aadhaar-based e-signature.
Do existing clients need to sign the MITC?
Yes. Disclose the terms and take consent on or before the subscription renewal date or the next fee due date, whichever is earlier.
Do institutional clients need to sign the MITC?
No. Since July 2025, signed consent is not mandatory for institutional investors and qualified institutional buyers, but you must still disclose the terms and MITC to them.
Can I add my own clauses to the RA terms?
Yes, as long as they do not contradict SEBI's rules. Any change to these voluntary clauses must be preceded by 15 days' notice to clients.