Part-Time Research Analyst: Rules After the 2024 AmendmentA SEBI part-time research analyst is an individual or partnership firm that provides paid research services alongside another job or business that is unrelated to securities. The option was created by the December 2024 amendment and comes with a 75-client cap, an employer NOC where relevant, and strict segregation and disclosure rules.  Last updated: 21 October 2026 Yes, you can be a SEBI part-time research analyst. Since the SEBI (Research Analysts) (Third Amendment) Regulations, 2024 took effect on 16 December 2024, an individual or partnership firm that also has another job or business can register as a "part-time research analyst". You need the same qualification, NISM certification and deposit as a full-time RA. You can have no more than 75 clients at any time, and you must keep your research work clearly separate from your other activity. With a small client base, a CRM for SEBI research analysts makes it easier to keep that separation and the records SEBI expects. This guide explains who is eligible, which activities rule you out, what you must disclose, how conflicts of interest are handled, and how the application differs. It is based on the RA Regulations as amended up to 10 October 2026 and the SEBI Master Circular for Research Analysts dated 6 February 2026. Check the current SEBI rules before you apply. This article is general information, not legal advice. What is a part-time research analyst under SEBI rules?Regulation 2(1)(nd) defines a part-time research analyst as an individual or a partnership firm who, for consideration, provides research services and is also engaged in any other business activity or employment. "Other business activity or employment"Regulation 2(1)(nb) limits this to work that is unrelated to securities, does not involve handling or managing clients' money, and does not involve giving advice or recommendations on any product or asset for investment purposes. Only individuals and partnershipsThe definition covers individuals and partnership firms. Companies and LLPs cannot register as part-time RAs. Still a research analystThe definition of "research analyst" in Regulation 2(1)(u) expressly includes a part-time RA. Every rule that applies to RAs applies to you unless the regulations say otherwise. What changed with the 2024 amendment?Before December 2024 there was no separate category. Anyone with another business or job had to fit within the general RA framework. The Third Amendment, notified on 16 December 2024, created the category and its conditions. Later changes apply to part-time RAs too. Since 25 November 2025, a graduate degree in any subject (or a CFA Charter) plus NISM certification is enough. Who is eligible to register as a part-time RA?SEBI's master circular says a person whose activity, business or job is permitted by any financial sector regulator, or falls under a statutory self-regulatory body such as ICAI, ICSI or ICMAI, is eligible. It gives these examples. Chartered accountants, company secretaries and cost accountantsMembers of ICAI, ICSI or ICMAI providing their statutory services are eligible. Licensed insurance agentsAn insurance agent licensed by IRDAI is eligible. Salaried professors and teachersEligible, provided the employer gives a no objection certificate. If you change jobs, you must give the new employer's NOC to RAASB or SEBI to continue. Other professionalsArchitects, lawyers, doctors and similar professionals are eligible. Educators and education businessesEligible, as long as you do not give unregistered advice on securities or make claims of performance on securities, which are the two activities prohibited by Regulation 16A of the SEBI (Intermediaries) Regulations, 2008. Who cannot be a part-time research analyst?Advisers on other assetsThe master circular says a person who gives advice or recommendations on assets such as gold, real estate or cryptocurrency is not eligible. Jobs or businesses related to securitiesWork related to securities, or work that involves handling clients' money, does not count as "other business activity". You would need to look at full-time RA registration or another SEBI category. Companies and LLPsOnly individuals and partnership firms fit the definition. The CA exampleA CA who mentions securities as an asset class while doing tax planning, as incidental advice, does not need to register. A CA who gives security-specific recommendations that are not tailored to the individual investor, even as part of tax work, must register as a part-time RA. What conditions apply after registration?No separate deposit slab for part-time RAs is specified. The general deposit table applies, and with at most 75 clients you will fall in the ₹1 lakh slab. How do you manage conflicts of interest as a part-time RA?The other job or business is where SEBI expects conflicts to arise, so plan for them in writing. Separate client journeysOnboard research clients through a separate process with their own KYC, terms and conditions, MITC and consent. Do not mix research subscriptions into your practice or consultancy engagement letters. Separate billingInvoice research fees on their own. Put the SEBI disclaimer on invoices for your other services, as the master circular requires. Separate communicationSend research only through your RA channels with the "part-time research analyst" name and disclaimers. Do not slip stock views into client meetings for your other work. Written policiesYour internal conflict-of-interest and personal trading policies should name your other activity and explain how you keep it separate. For the disclosures each report needs, see the research report disclosures checklist. How does the part-time RA application differ?The process is the same as for a full-time RA: get qualified and certified, file Form A through BSE (acting as RAASB), arrange the deposit and pay SEBI's fees. The step-by-step guide to becoming a SEBI research analyst covers it in full. The part-time differences are:
SEBI's application fee (₹2,000) and registration fee (₹3,000) for individuals and partnership firms are the same as for full-time RAs. RAASB administrative fees are extra. What happens if you want more than 75 clients?The cap applies at every point in time, so you cannot go over it even briefly. Count every active client, and track renewals and expiries carefully so lapsed clients do not hide an overrun. Plan the move to full-timeIf you expect to grow past 75, you will need to stop the other activity and work as a full-time RA. The regulations do not set out a conversion procedure, so check the current process with RAASB before you reach the cap. Watch the deposit slabOnce you are full-time, the deposit is set by your highest client count on any day of the previous financial year. It goes up at 151 clients. Which obligations stay the same as for a full-time RA?Part-time does not mean lighter compliance. You still need KYC for fee-paying clients, terms and conditions with MITC and client consent before you give any service, records of client interactions kept for five years, the fee cap for individual and HUF clients, the investor charter and monthly complaint data on your website, half-yearly reports to RAASB and an annual compliance audit. Our monthly compliance checklist for research analysts sets these out as a routine. Distribution servicesAn individual RA cannot provide distribution services, and family members cannot provide distribution services to your research clients. Check how this applies to your other activity before you apply. Run a part-time practice without the paperwork piling upWith a day job or a professional practice, a part-time RA has little spare time for admin. Finuro's CRM for SEBI research analysts handles KYC and e-sign onboarding, recommendations with disclaimers, delivery logs, subscription billing with GST invoices, and business analytics that show your active client count, so you can keep an eye on the 75-client cap. Always check the current SEBI rules and RAASB notices. This article is not legal advice. Related Finuro features
Frequently asked questionsAnswers to common questions on this topic. Built for SEBI RAs and IAs Run your part-time RA practice on FinuroKeep research clients, consent, recommendations and billing separate from your other work, with records ready for your audit. |
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