Running a compliant paid Telegram channel as a SEBI-registered Research Analyst

Running a paid Telegram channel as a SEBI-registered Research Analyst

Telegram is where many Indian investors already read market views, so it is a natural place for an RA to deliver research. SEBI does not ban it. But the same tool is used by unregistered tip sellers, and SEBI's enforcement orders show exactly what a non-compliant channel looks like. This guide sets out what a registered RA needs to do differently: disclosures, KYC and agreement before anyone gets access, records, and removing members when their subscription ends.

What SEBI's April 2026 Telegram order shows

In an order dated 30 April 2026, SEBI dealt with the Telegram channels "Intraday Jackpot" and "Professional Day Trading Institute". According to the order:

• A free channel was used as a funnel. It posted links to paid private channels, and paying through a link on a creator-payment platform got the subscriber added to the paid channel.
• The paid channels gave buy, sell and hold calls. SEBI held this to be investment advice and research analysis without registration, in breach of Section 12(1) of the SEBI Act.
• About ₹9.02 crore had been collected as fees. One of the payment accounts had been opened using another person's PAN.
• SEBI ordered three of the operators to refund the money within three months, barred them from the securities market for two years (or until the refund is complete, whichever is later), and imposed penalties of ₹10 lakh each on four people.

The lesson for a registered RA is not "avoid Telegram". It is that the free-channel-plus-payment-link pattern has no compliance built in: no KYC, no agreement, no records and claims of accuracy that cannot be verified. Your channel has to supply all of that.

Set up the channel correctly

The advertisement code in para 11 of the SEBI master circular for RAs explicitly covers "messaging platforms" and "social media platforms". Anything you post that promotes your service is an advertisement. So:

• Channel name and description show your name as registered with SEBI, your registration number and a link to your website. Where a message cannot carry your full details, the code allows a hyperlink to a website that does.
• Pin the standard warning: "Investment in securities market are subject to market risks. Read all the related documents carefully before investing."
• Pin the disclaimer: "Registration granted by SEBI, enlistment with BSE and certification from NISM in no way guarantee performance of the intermediary or provide any assurance of returns to investors."
• Pin grievance contacts: your compliance or grievance officer, and the SCORES and SMART ODR routes.
• Do not use the SEBI logo anywhere on the channel.

The free channel: educate, do not advertise results

Many RAs run a free channel to find subscribers. Keep it on the right side of the code:

• No claims of accuracy, "success rate" or target returns, and no profit screenshots. Past performance can only be shown using PaRRVA-verified metrics. See our PaRRVA explainer.
• Do not call the paid channel "free for 7 days" unless it really is free with no condition.
• If you mention a stock as an example, add "The securities quoted are for illustration only and are not recommendatory."
• Promotional posts need prior approval from the SEBI-recognised supervisory body under the advertisement code. Batch them so approval does not slow you down.

Free content that is genuinely educational, such as how to read a results release, is the safest and most useful thing to post.

Paid access: KYC and agreement before anyone joins

For a registered RA, a person should reach the paid channel only after these steps, in this order:

1. KYC of the fee-paying client (para 1.13).
2. Consent to your terms and conditions, including the MITC. Para 1.12 says no research service may be provided and no fee charged until the client has consented. Consent can be by Aadhaar-based e-sign. See what the agreement and MITC must contain.
3. Payment through a banking channel into your own account. Cash is not allowed. See collecting subscription payments.
4. A single-use invite link issued to that subscriber, so access cannot be forwarded.

Avoid the pattern in the April 2026 order, where a generic payment link added anyone who paid. That skips steps 1 and 2 completely.

Posting research in the paid channel

• Every call has a report behind it. Para 1.8 says research services must be corroborated by a research report with the data and analysis behind it, and you must keep that report. A one-line Telegram call is the delivery; the report is the record.
• Disclose conflicts, including your own holding in the security.
• Same research, same time, for everyone on the same plan. The investor charter says research must be distributed without discrimination.
• Disclose AI use. If AI tools help produce your research, say how far you rely on them (para 1.7).
• Keep everything for five years: messages, reports and advertisements. Para 13 of the master circular adds that use of chat and messenger platforms by your staff should be logged, and those logs kept as records.

Removing members when a subscription expires

This is the step most RAs do by hand, and it is the one that slips. Leaving expired members in a paid channel creates problems:

• People keep receiving research without a current agreement, which makes your client count, records and complaint handling unreliable.
• Paying subscribers notice that non-payers get the same calls, and renewals fall.
• If a subscriber ends early, SEBI requires a proportionate refund for the unexpired period, so access and billing must stay in step.

A workable routine:

1. Track each member's plan end date against their Telegram user ID, not just their name.
2. Send renewal reminders before expiry, through the channel and by email.
3. Remove expired members on the expiry date, and revoke their invite links.
4. If you allow a grace period, state it in your terms and apply it the same way to everyone.
5. Keep a log of who was added and removed, and when.

Done manually across hundreds of members, this is error-prone. AlphaQuark adds paying subscribers to Telegram or WhatsApp after KYC, MITC e-sign and payment, and removes them automatically when their plan expires. See the RA platform.

Complaints from channel members

Treat a complaint in a Telegram DM the same as an email. Log it, resolve it within your published timeline, and include it in the monthly complaint data you publish by the 7th. Our complaint data format guide has the template.

A quick checklist