Selling Single Calls or Reports: Pay-to-Unlock & SEBI Fee Rules

Last updated: 21 October 2026

Can a SEBI research analyst charge per call or per report? SEBI's research analyst rules do not ban pay-per-call pricing, and they do not create a separate category for it either. Each paid unlock is a research service for a fee, so the full fee rules apply to every buyer. The buyer becomes a fee-paying client, so you need their consent on your terms and conditions and MITC before charging and their KYC. Their purchases count towards the cap of ₹1,51,000 a year per family across all your research services, payment must go through permitted channels, and every sale must be recorded. Pay-to-unlock messages can run this way if your onboarding and records are set up first.

This guide explains how SEBI's fee, consent, KYC, distribution and advertising rules apply when you sell single calls or reports. It is based on the SEBI (Research Analysts) Regulations, 2014 as amended up to 10 October 2026 and the SEBI Master Circular for Research Analysts dated 6 February 2026. SEBI has not issued guidance written specifically for per-report pricing, so this is our reading of the general rules, not legal advice. Have your compliance officer review your setup and check the current SEBI and RAASB rules before you launch.

Regulation 15A of the RA Regulations lets a research analyst charge fees for research services in the manner SEBI specifies. The master circular then sets the conditions:

• fees may be charged subject to SEBI's ceiling and must be fair and reasonable;
• individual and HUF clients may be charged a maximum of ₹1,51,000 per annum per family;
• advance fees may cover at most one year;
• on early termination, the client gets a proportionate refund for the unexpired period, and RAs may not charge a breakage fee.

None of these provisions require fees to be charged as a subscription. Selling one research report, or unlocking one recommendation, is therefore a fee model the rules do not exclude. The constraints come from everything that attaches to a fee-paying client, covered below.

The cap applies per family of client, per year, across all your research services. Single-report purchases are added to whatever else that family pays you, including subscriptions, model portfolios and other paid unlocks. The limit excludes statutory charges such as GST. It does not apply to non-individual clients, accredited investors or institutional investors seeking proxy advice, whose fee terms are agreed bilaterally. RAASB revises the limit once every three years based on the Cost Inflation Index, after consulting SEBI.

An illustration with made-up prices:

Because the cap is per family, you also need a way to connect purchases by family members. The master circular treats the "family of client" as one client for this purpose. Track purchases by PAN and family, not just by phone number or Telegram handle. Our guide to RA fee limits and payment rules goes into the cap in more detail.

A one-off buyer is a client like any other. Before you take the fee:

The practical answer is to send one-off buyers through the same onboarding as subscribers, with KYC and MITC consent, before the first unlock, and to let later purchases reuse that consent. See our MITC guide for research analysts and KYC and KRA onboarding guide.

Regulation 22(1) says a research report must not be made available to a particular client or class of clients in advance of other clients who are entitled to receive it. This matters if the same call goes both to subscribers and to one-off buyers.

The refund rule covers the unexpired period of a service that ends early. A single report that has already been delivered has no unexpired period, so in most cases no proportionate refund arises. Your terms should still say plainly what happens if a report is not delivered, arrives incomplete or cannot be downloaded. The master circular's mandatory terms treat these as grievances you must resolve within the specified timeline. In the mandatory terms that is 7 business working days, or whatever timeline SEBI specifies. Prepaid bundles of unlocks are advance fees, so they cannot cover more than one year, and any unused balance should be refunded proportionately if the service ends early.

The master circular is not fully consistent here. Paragraph 1.9 allows an advance of up to one year, while the RA MITC text still says "presently it is one quarter". Check which applies before selling prepaid packs.

Promoting a single call is advertising, so SEBI's advertisement code for research analysts applies. In particular:

• do not call anything free unless it really is free, with no condition or obligation;
• do not promise or imply assured outcomes, accuracy percentages or risk-free results;
• do not use past performance claims unless they are permitted, such as metrics verified by a PaRRVA;
• include your registered name, registration number and the required disclaimers, or link to a website that has them.

A paid unlock is research and carries the same disclosures as a call sent to subscribers: the rationale, your registration details, conflicts of interest and holdings, the standard risk disclaimers, and the record of how you arrived at the call. Our research report disclosures checklist lists them. Selling a teaser openly and hiding the call behind a paywall does not remove these duties. The locked content still needs them, and the teaser itself is an advertisement.

In Finuro, pay-to-unlock (locked) messages are paid through Cashfree. You can require an onboarding sequence before purchase: KYC with CVL KRA and NDML KRA, MITC as text or PDF, Aadhaar e-sign through Digio or Cashfree, and payment. Recommendation messages carry your disclaimers, delivery by email, WhatsApp and Telegram is logged, and business analytics show clients and revenue. You stay responsible for the fee cap, pricing and promotions, and Finuro does not give legal or compliance advice. See how pay-to-unlock messages for research analysts work.

• e-KYC and onboarding: KYC and MITC consent before the first paid unlock
• Subscription billing: run subscriptions alongside single-call sales
• Communication records: delivery logs for every call sent
• Business analytics: clients, revenue and invoice downloads in one view