Fee and Payment Mistakes SEBI RAs Should Avoid

Last updated: 21 October 2026

The most common research analyst fee and payment mistakes are charging a fee before the client has consented to your terms, applying the ₹1,51,000 fee cap per person instead of per family, taking more in advance than the rules allow, refusing pro rata refunds, and accepting cash or payments into the wrong account. Each breaks a rule in the SEBI (Research Analysts) Regulations, 2014 or the RA master circular dated 6 February 2026. Subscription billing built for research analysts helps you set plans, invoices and refunds up correctly from the start.

This post covers eight mistakes, the rule behind each and how to avoid it. It is not legal advice. Fee rules have changed several times since December 2024, so check the current SEBI master circular and RAASB announcements before you set prices.

A prospect clicks a payment link from a Telegram post, pays, and receives the terms and MITC a day later, or never. The payment came first and the paperwork followed.

Regulation 24(6) requires an RA to disclose its terms and conditions and take the client's consent on them, and para 1.12(b) of the master circular says no research service may be rendered and no fee charged until that consent is received. The terms must include the Most Important Terms and Conditions (MITC), and consent can be given in person or by any legally acceptable mode, including DigiLocker-enabled Aadhaar e-signature.

To avoid it, make consent a step that has to be completed before checkout, not an email sent afterwards. Finuro's onboarding sequence can place KYC and MITC e-sign before the payment step for each product.

An RA sells an equity plan to a client and an options plan to the client's dependent spouse, and checks each against the cap separately. Together they may exceed it.

Para 1.9(b) caps fees for individual and HUF clients at ₹1,51,000 per annum per family, and the MITC says the cap applies to all research services of the RA. Statutory charges are excluded, RAASB revises the limit every three years based on the Cost Inflation Index, and the fee rules do not apply to non-individual clients or accredited investors. Regulation 2(1)(fc) defines family as the client and their dependent spouse, children and parents.

To avoid it, capture dependent family members at onboarding and total each family's fees across every plan before renewals and upgrades. Our guide to RA fee limits and payment rules covers the cap in detail.

Annual and multi-year plans paid upfront are attractive for cash flow, so they are easy to oversell.

Para 1.9(f) says an RA may charge fees in advance if the client agrees, but not for more than one year. The standard MITC text in Annexure B of the same master circular still says the advance must not exceed the period SEBI stipulates, "presently it is one quarter". Because clients read the MITC, a client could take your terms to mean three months.

To avoid it, never sell plans longer than a year upfront, and until SEBI or RAASB aligns the two texts, confirm the current position with RAASB or your compliance adviser before collecting more than a quarter in advance. Make sure the advance period in your own terms matches what you collect.

"No refunds after purchase" lines on checkout pages, or a cancellation fee for leaving early, are copied from other online businesses.

Para 1.9(g) says that if services end early under the agreed terms, the client must be refunded proportionate fees for the unexpired period, and the RA shall not charge any breakage fee. If SEBI suspends your registration for more than 60 days or cancels it, the MITC terms require a pro rata refund from the effective date to the end of the subscription period.

To avoid it, remove no-refund wording, state in your terms how you calculate the unexpired period (for example, in days), and apply it the same way every time. Billing that supports pause, extend and cancel, as Finuro's does, makes the end date of each subscription easy to show.

This looks like a client handing over cash, or paying a staff member's or relative's UPI ID because it was quicker.

The MITC says fees may be paid by modes such as cheque, online bank transfer or UPI, and that cash payment is not allowed. The investor charter tells clients to pay only through banking channels and keep signed receipts with payment details. Payment gateways (cards and net banking) are not named in the MITC, so confirm your gateway setup with your compliance adviser.

To avoid it, collect only into accounts in the RA's own name, issue a receipt or invoice for every payment, and never let staff collect fees personally. Our post on payment gateways for advisory businesses explains what gateways look for.

It is easy to keep sharing an ordinary UPI ID out of habit, or to leave BSE's fee collection mechanism out of your terms.

SEBI's circular of 11 June 2025 requires registered intermediaries, including RAs, to obtain a validated UPI ID with the ".ra" suffix and an "@valid" bank handle, and make it available to clients, although clients may still use other permitted modes. Para 1.9(h) says your terms must include the fee limits, the agreed fee and guidance on the optional Centralised Fee Collection Mechanism (CeFCoM) run by BSE as RAASB.

To avoid it, get your @valid UPI ID from your bank, show it on your payment pages, and add a CeFCoM paragraph to your terms. Check SEBI for any later changes to the UPI timelines.

"Only today: 50% off the annual plan" banners and countdown timers are common sales tools, and so are coupon codes shared in free channels.

The RA investor charter tells clients not to be attracted to limited-period discounts or other incentives and gifts offered by research analysts, and the advertisement code bars calling a service free unless it is free without condition. The SEBI (Intermediaries) (Second Amendment) Regulations, 2026, due to apply from around April 2027, require regulated entities to refrain from incentives, vouchers, coupons or subscription plans offered as inducements to avail services (Reg 16L(1)(g)), and ban dark patterns (Reg 16M).

To avoid it, keep pricing plain and stable, and review any coupon, trial or discount with your compliance adviser before the new code applies. Finuro billing supports coupons and trials, so decide deliberately whether you use them.

Payments sit in a bank statement, invoices sit in another tool and consent dates sit in email, so nobody can show the auditor how a fee matches a client and a service.

Regulation 25(1)(vi) requires a register of clients with PAN, the date and nature of the research service, the securities covered and the fee charged or received, and Regulation 25(2) requires records to be kept for at least five years. Your annual compliance auditor will test fees against them.

To avoid it, keep the invoice, payment reference, consent date and any refund working together for each client. Finuro issues GST invoices, and its business analytics include renewals, revenue and invoice downloads.

• Terms and MITC consented before any payment.
• Each family's total fees within ₹1,51,000 a year across all services.
• Advance period matching your terms, and the MITC position confirmed.
• Proportionate refunds, no breakage fee, no cash.
• @valid UPI ID displayed and CeFCoM guidance in your terms.
• Offers reviewed against the investor charter and the coming advertisement code.
• Invoice, payment reference and consent date kept for every fee.

Finuro's billing covers plans, recurring payments, manual subscriptions, pause, resume, extend and cancel, through Razorpay, Cashfree or HDFC, with GST invoices. You still set the prices and durations, so keeping each family within the cap is your call. See how subscription billing for research analysts fits these rules.

• e-KYC and onboarding: consent to terms before the first payment
• Client consent records: signed MITC and terms with dates
• Business analytics: clients, renewals, revenue and invoices
• Pay-to-unlock messages: single paid messages through Cashfree