Aadhaar e-Sign for RA & IA Client Agreements: How It WorksAadhaar e-sign lets clients sign your RA terms and conditions or IA advisory agreement online with an Aadhaar OTP. It is valid under the IT Act, 2000, and SEBI's RA and IA master circulars expressly allow DigiLocker-enabled Aadhaar e-signature for client consent.  Last updated: 21 October 2026 Aadhaar e-sign is a legally recognised way for a client to sign a research analyst's terms and conditions or an investment adviser's advisory agreement online. It works under the Information Technology Act, 2000, which treats e-authentication using Aadhaar e-KYC as a valid electronic signature, and SEBI's master circulars for RAs and IAs say client consent may be signed through DigiLocker-enabled Aadhaar-based e-signature. To keep each signed copy with the client file, use a client consent records system. This guide explains the legal basis, how an OTP-based e-sign actually works, who the eSign Service Providers are, and what you should store after signing. It is a general guide, not legal advice; check the current SEBI rules and get your own legal view on your agreement. Is Aadhaar e-sign legally valid in India?Yes, for most commercial documents. Three parts of the IT Act do the work. Section 3A: electronic signaturesA subscriber may authenticate an electronic record using an electronic signature or technique listed in the Second Schedule of the Act, provided it is considered reliable. The Second Schedule: Aadhaar e-KYCThe Second Schedule includes the "e-authentication technique using Aadhaar e-KYC services". This, together with the Electronic Signature or Electronic Authentication Technique and Procedure Rules, 2015, is the basis for the eSign service run under the Controller of Certifying Authorities (CCA). Section 5 and Section 10ASection 5 gives legal recognition to electronic signatures where a law requires a signature. Section 10A says a contract is not unenforceable only because it was formed electronically. The Act does not apply to the documents in its First Schedule, which include negotiable instruments other than cheques, powers of attorney, trusts, wills, and contracts for the sale or conveyance of immovable property. RA terms and IA advisory agreements are not on that list. What does SEBI say about e-signing RA and IA agreements?SEBI explicitly allows it. The Master Circular for Research Analysts (February 6, 2026) says consent of the client to the terms and conditions "may be signed by the client in person or through any other legally acceptable mode including DigiLocker enabled Aadhaar based e-signature facility". The Master Circular for Investment Advisers of the same date uses the same words for the investment advisory agreement. For RAs, SEBI's FAQs add that institutional investors and qualified institutional buyers need not sign consent on the terms and MITC, though you must still disclose them. For retail clients, consent is mandatory and the e-sign is your proof. How does Aadhaar OTP e-sign work, step by step?The CCA's eSign API specification describes three parties. The Application Service Provider (ASP) is the platform asking the user to sign. The eSign Service Provider (ESP) is a licensed Certifying Authority, or works with one, and is empanelled by the CCA. The e-KYC provider (UIDAI, for Aadhaar) authenticates the person. 1. The client reviews the documentYour onboarding page shows the terms or agreement and asks the client to sign. 2. A signing request goes to the ESPThe ASP sends a digitally signed request containing a hash of the document, not the whole document, to the ESP. 3. Aadhaar OTP authenticationThe ESP redirects the client to its authentication page. The client enters their Aadhaar number or Virtual ID and the OTP sent to their Aadhaar-linked mobile. 4. A one-time certificate is issuedAfter successful e-KYC, the ESP creates a new key pair, gets a short-validity e-KYC class Digital Signature Certificate from the CA, and signs the document hash. 5. The signature is attachedThe ESP sends the signature and certificate back to the ASP, which embeds them in the PDF. The client's name and a time stamp are part of the certificate. Because the certificate is created for one signing only and the private key stays in the ESP's hardware security module, the client does not need a USB token or a pre-issued Digital Signature Certificate. That is why Aadhaar e-sign suits retail onboarding. Who provides Aadhaar e-sign?Only Certifying Authorities licensed by the CCA can offer the eSign service, and the CCA publishes the empanelled eSign Service Providers on cca.gov.in. Most RAs and IAs do not connect to an ESP directly. They use a platform or an integration partner that is an ASP to one or more ESPs. Charges are usually per signature and vary by provider and volume, so ask for current pricing rather than relying on figures you see online. What about email OTP or click-to-accept consent?SEBI's wording is "any other legally acceptable mode", which leaves room for other methods. Section 10A of the IT Act supports contracts formed electronically, and an email OTP confirmation creates a digital trail. However, an email OTP is not the Aadhaar e-KYC technique in the Second Schedule, so it is weaker evidence of who signed. Many firms use Aadhaar e-sign as the default and keep email OTP for clients who cannot complete Aadhaar authentication. Agree your approach with your compliance officer or lawyer. What should you keep after a client e-signs?Regulation 25(1)(viii) of the RA Regulations requires RAs to keep the terms and conditions disclosed to clients and the client's consent. Regulation 25(2) says records must be kept for at least five years, and records that must be signed and are kept electronically must be digitally signed. An Aadhaar e-signed PDF meets that format by design. Do not store the client's full Aadhaar number. SEBI's KYC master circular prohibits intermediaries from storing Aadhaar numbers in their systems. If a dispute is raised, keep the related records until it is resolved, even beyond five years. Common e-sign mistakesSigning after paymentFor RAs, no service may be rendered and no fee charged until consent is received, so the e-sign step must come before payment. Losing the signed copySome integrations only keep the file at the provider for a limited time. Download and store each signed PDF in your own records. Re-using an old versionIf you update your MITC or terms, existing clients may need fresh disclosure and consent; keep each version and its consents. Collect and store e-signed agreements in one placeFinuro supports Aadhaar e-sign through Digio or Cashfree, email OTP e-sign, and a manual consent PDF upload for clients who sign on paper. Your MITC can be text or a PDF, the e-sign step sits inside a configurable onboarding sequence (KYC, MITC, risk assessment, payment), and you can bulk download a month of KYC and MITC e-sign documents for audit. See the client consent records page for details. Related Finuro features
Frequently asked questionsAnswers to common questions on this topic. Built for SEBI RAs and IAs Get client agreements e-signed onlineUse Aadhaar e-sign or email OTP inside your Finuro onboarding flow and keep every signed copy.  |
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