Record Keeping & Call Recordings for RAsResearch analyst record keeping means keeping reports, recommendations, rationale, public appearances, KYC, a client register, communication records including call recordings, and signed terms for at least five years. From November 9, 2026, call recordings with institutional investors are no longer mandatory.  Last updated: 21 October 2026 Research analyst record keeping under SEBI means keeping eight types of records for at least five years: signed and dated research reports, every recommendation, its rationale, public appearances, KYC of fee-paying clients, a client register, records of communication including call recordings, and the terms and conditions with each client's consent. Most of these start at onboarding, so a proper e-KYC and client onboarding system is the first place your records come from. This guide sets out what Regulation 25 of the SEBI (Research Analysts) Regulations, 2014 and the RA master circular require, when call recordings are needed (including the change for institutional clients from November 9, 2026), and how to store records so you can produce them in an audit. It is a summary, not legal advice; check the current SEBI regulations and circulars. Which records must a SEBI research analyst keep?Regulation 25(1), as amended in December 2024, lists the records. The table below sets out each one with what it means day to day. The master circular adds that research services must be backed by a research report containing the data and analysis behind them, and that you must keep that report. SEBI's FAQs say that for technical recommendations you need an adequate documentary basis, supported by research, not just a chart with a time stamp. How long must RAs keep records?Regulation 25(2) says all records must be kept in physical or electronic form for a minimum of five years. Records that must be signed and are kept electronically must be digitally signed. The master circular adds two exceptions to the five-year rule for records of client interactions. DisputesIf a dispute has been raised, keep the records until the dispute is resolved, even if that takes more than five years. SEBI instructionsIf SEBI asks for specific records to be preserved, keep them until SEBI tells you otherwise. The interaction records start with the first interaction with the client and continue until the research service to that client ends, so the five years effectively run from the end of the relationship, not the start. Are call recordings mandatory for research analysts?Yes, for phone conversations about your services with retail clients. Paragraph 1.13 of the Master Circular for Research Analysts (February 6, 2026) requires RAs to keep records of interactions with all clients, including prospective clients before onboarding, where any conversation about their services has taken place. Accepted forms include:
SEBI's FAQs clarify that a call recording is not required where the interaction happens through a channel such as email that leaves a digital footprint. The rule exists so that client grievances about research services can be checked against what was actually said. Fee-paying and non-fee-paying clientsThe interaction records apply to both, including clients who receive research as a value-added service with other paid services. Prospective clientsSales calls count. A recording should exist from the first conversation about your services, before the person becomes a client. Institutional investors from November 9, 2026The SEBI (Research Analysts) (Amendment) Regulations, 2026 add a proviso to Regulation 25(1)(vii): keeping call recordings of communication with clients who are institutional investors is no longer mandatory. "Institutional investor" takes its meaning from the SEBI ICDR Regulations, 2018. The change takes effect on November 9, 2026. Other records of interactions with institutional clients, and all records for retail clients, still apply. What about WhatsApp and Telegram messages?Regulation 25(1)(vii) covers records of communication "including" emails and call recordings, and the master circular accepts "any other legally verifiable record". If you send recommendations or discuss services over WhatsApp, Telegram or SMS, keep exportable logs of those messages with date, time, sender and recipient. A log kept by the platform you deliver through is easier to produce in an audit than screenshots from a staff phone. Other records your audit will ask forBeyond Regulation 25(1), the master circular creates several more documents an RA should keep on file. See our annual compliance audit guide for how these come together each year. How should you store RA records?Keep them electronic and searchableSEBI accepts electronic records. Store them so you can pull up everything for one client by PAN or client ID in minutes. Sign what needs signingResearch reports and signed consents kept electronically must carry a digital signature. Separate the call recordingsKeep recordings with the number, date, time and client ID, in a store you control, not only with the telephony vendor. Lock down accessClient records contain personal data. Limit who can view or delete them and keep a log of changes. Plan for deletionBefore deleting anything after five years, check that no dispute or SEBI instruction applies to it. Why good records also protect your performance historyFor the period after a Past Risk and Return Verification Agency (PaRRVA) starts operating, RAs may only advertise or share past performance using risk and return metrics verified by a PaRRVA. Clean, time-stamped records of every recommendation, its entry, targets, stop-loss and outcome are the raw material for that verification. Our PaRRVA explainer covers how it works. Keep RA records in one place with FinuroFinuro keeps the records your onboarding creates: KRA checks with CVL KRA and NDML KRA, KYC documents, and MITC consent by Aadhaar e-sign or email OTP, with a bulk download of a month of KYC and MITC e-sign documents. Recommendations are stored with horizon, entry range, targets, stop-loss and status (target hit, SL hit, trailed SL hit, expired, not valid), and email, WhatsApp and Telegram deliveries have delivery logs. Research report PDFs, an audit trail of create, update and delete actions, and Excel export complete the picture, and recommendation performance analytics show success rate, P&L and accuracy from those records. Finuro does not include a dialer, so call recordings come from your telephony provider. Start with the e-KYC and onboarding page. Related Finuro features
Frequently asked questionsAnswers to common questions on this topic. Built for SEBI RAs and IAs Keep audit-ready RA recordsStore KYC, consent, recommendations and delivery logs together on Finuro.  |
Book a Demo
See how Finuro handles onboarding, recommendations, model portfolios, and billing for your advisory firm. Tell us a little about your practice and we'll walk you through the platform on a live call.