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MITC for RA Clients (+ Template)

MITC for research analysts is SEBI's standard 12-point summary of key terms, issued on February 17, 2025. Every RA must add it to their terms and conditions and take client consent before giving research or charging a fee. Use SEBI's prescribed text and fill in only your own details.

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Last updated: 21 October 2026

MITC (Most Important Terms and Conditions) for research analysts is a standard set of 12 points that SEBI published on February 17, 2025, and every SEBI-registered RA must include it in their terms and conditions and take the client's consent on it before providing research or charging a fee. The wording was standardised by the Industry Standards Forum with RAASB and SEBI, so you use SEBI's text and only fill in your own details. Collecting that consent with e-signed client consent records gives you proof for every client.

Below you will find what the rule requires, a sample MITC outline that follows SEBI's 12 points, the other minimum terms you need, and how to get it signed. This is a guide, not legal advice: always copy the MITC from SEBI's current prescribed text and check the latest circulars.

What is the MITC for research analysts?

Regulation 24(6) of the SEBI (Research Analysts) Regulations, 2014 requires an RA to disclose the terms and conditions of research services and take the client's consent. SEBI's circular of January 8, 2025 set the minimum mandatory terms and said they must include an MITC. The MITC itself came in SEBI circular SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/20 dated February 17, 2025, and it is now carried in Annexure B of the Master Circular for Research Analysts dated February 6, 2026.

The MITC is short on purpose. It puts the points a retail client most needs to know (what an RA can and cannot do, fees, refunds, risks and how to complain) on one page, in the same words across the industry.

Who needs MITC, and by when?

New clients

Include the MITC in your terms and conditions and take consent before any research service is rendered or any fee is charged.

Existing clients

SEBI required RAs to inform existing clients of the MITC by email or another mode that can be preserved by June 30, 2025.

Institutional investors and QIBs

SEBI's FAQs say consent on the terms and MITC is not mandatory for institutional investors or qualified institutional buyers, but you must still disclose them.

Non-fee-paying clients

Clients who get research as a value-added service with other paid services must also receive the terms and give consent, unless they are institutional investors or QIBs.

Sample MITC outline for research analysts

Sample outline only. The table below summarises the 12 points in SEBI's prescribed MITC so you can check your document covers each one. It is not the prescribed text. Copy the exact wording from Annexure B of the current Master Circular for Research Analysts on sebi.gov.in, and fill in only the details SEBI leaves for you.

Point	Topic	What SEBI's text covers	What you fill in
1	Nature of service	The terms are for research services; the RA cannot execute any trade for the client, and clients should not let the RA do so	Nothing
2	Fee limit	Fees are capped at the maximum set by SEBI/RAASB for individual and HUF clients, with notes on the current limit, statutory charges and the exemption for non-individual clients and accredited investors	Check the current limit is stated correctly
3	Advance fees and refunds	Advance fees only if the client agrees, within the period SEBI allows; proportionate refund for the unexpired period on early termination	See the note below the table
4	Payment modes	Cheque, online transfer, UPI and similar modes; no cash; optional payment through CeFCoM run by BSE as RAASB	Nothing
5	Conflict of interest	The RA follows SEBI and RAASB rules on conflicts and will try to tell the client promptly of any conflict	Nothing
6	Assured schemes banned	Assured, guaranteed or fixed-return schemes are prohibited and will not be offered	Nothing
7	No guarantee	The RA cannot guarantee profits, accuracy or risk-free investing; opinions rest on data and assumptions as of the report date	Nothing
8	Market risk	Investments based on recommendations carry market risk, there is no recourse for losses, and reliance is the client's own judgement	Nothing
9	Registration is not assurance	SEBI registration, RAASB enlistment and NISM certification do not guarantee the RA's performance	Nothing
10	Grievances	Step 1 contact the RA; step 2 SCORES at scores.sebi.gov.in; step 3 Online Dispute Resolution through SMART ODR at smartodr.in	Your grievance contact details and escalation matrix
11	Client contact details	Clients must keep their email and mobile number updated with the RA	Nothing
12	Credentials and OTPs	The RA will never ask for login details or OTPs for the client's trading, demat or bank accounts; clients should never share them	Nothing

Note on point 3: the MITC text published in February 2025 says the advance-fee period is "presently one quarter". The fee section of the February 2026 master circular (based on SEBI's April 2, 2025 circular) allows advance fees for up to one year if the client agrees. The MITC in Annexure B still shows the older wording. Check the current SEBI and RAASB position before you finalise this point, and do not rewrite SEBI's text on your own.

What else must your terms and conditions include?

The MITC is one item in a longer list. Annexure B of the RA master circular sets the minimum mandatory terms, and your full document should cover each of these.

Availing the service: the client chooses to subscribe at their own discretion
Obligations: both sides are bound by the SEBI Act, RA Regulations and related rules
Client information and KYC: the RA collects, stores, uploads and checks KYC with a KRA
Standard terms of service: the client's consent statement and the RA's declarations, including registration number and date
Consideration and payment mode: agreed fees and statutory charges
Risk factors: a statement of standard risks of investing in securities
Conflict of interest: the RA's mandatory disclosures
Termination and refunds: including pro-rata refund if registration is suspended for more than 60 days or cancelled
Grievance redressal and dispute resolution: the designated person's name and email
Additional clauses: must not conflict with SEBI rules, and changes need 15 days' notice
Mandatory notice: ask clients to read the Do's and Don'ts for dealing with RAs
The MITC itself
Guidance on the optional Centralised Fee Collection Mechanism (CeFCoM)

The master circular also asks RAs to disclose the extent of their use of AI tools when they disclose the terms and conditions. See our guide to AI tool rules for RAs.

How do you get MITC signed by clients?

SEBI allows consent on the terms and conditions to be signed in person or through any legally acceptable mode, including DigiLocker-enabled Aadhaar-based e-signature. In a digital onboarding flow the MITC step sits after KYC and before payment, because no fee may be charged until consent is received. Our guide to Aadhaar e-sign for client agreements explains how the signing works.

Show the full text

Display the MITC and the full terms on screen or as a PDF before the client signs, not just a link.

Capture consent

Use Aadhaar e-sign where possible, with a fallback such as email OTP or a signed paper copy.

Keep the signed version

Store the exact signed version; Regulation 25(1)(viii) requires you to keep the terms disclosed and the client's consent.

How long do you keep MITC consent records?

At least five years under Regulation 25(2) of the RA Regulations, and longer if a dispute is open or SEBI asks you to preserve records. Electronic records that must be signed should be digitally signed. Our RA record keeping guide lists the other records to keep alongside it.

MITC mistakes to avoid

Editing SEBI's wording

The MITC is standardised. Rewriting points to sound friendlier, or dropping some, defeats the purpose and may be flagged in your audit.

Burying it in fine print

The MITC should be easy to find within your terms, not hidden in a footer link.

Leaving the grievance section blank

Point 10 needs your actual contact details and escalation matrix.

Charging before consent

A payment link sent before the client signs breaks the consent-first rule.

Collect e-signed MITC consent with Finuro

On Finuro you can add your MITC as text or as a PDF, place it in a configurable onboarding sequence (KYC, MITC, risk assessment, payment) and have clients sign by Aadhaar e-sign through Digio or Cashfree, or by email OTP e-sign. A manual consent PDF option covers paper signers, and you can bulk download a month of KYC and MITC e-sign documents. Learn more on the client consent records page.

Related Finuro features

e-KYC and onboarding: KRA checks before the MITC step
Subscription billing: take payment only after consent
Compliance document management: keep each MITC version on file

Frequently asked questions

Answers to common questions on this topic.

Can I write my own MITC?

No. The MITC was standardised by the Industry Standards Forum with RAASB and SEBI, so you should use SEBI's prescribed text and fill in only the details it leaves for you, such as your grievance contacts.

Is the MITC the same for RAs and IAs?

No. SEBI issued separate MITCs for research analysts and investment advisers on February 17, 2025. IAs include their MITC in the investment advisory agreement.

Do institutional clients need to sign the MITC?

SEBI's FAQs say consent is not mandatory for institutional investors or QIBs, but you must still disclose the terms and conditions, including the MITC, to them.

Can clients sign the MITC online?

Yes. The RA master circular allows consent in person or through any legally acceptable mode, including DigiLocker-enabled Aadhaar-based e-signature.

What happens if I change my terms later?

Changes to your own voluntary clauses need 15 days' notice under the minimum terms in the master circular. Keep each version and the consents given on it.

Built for SEBI RAs and IAs

Get your MITC e-signed by every client

Upload your MITC to Finuro and collect Aadhaar or email OTP e-sign consent before payment.