SEBI Master Circular for Research Analysts: SummaryThe SEBI master circular for research analysts, dated February 6, 2026, collects every SEBI circular that applies to RAs into one 107-page document. This summary explains what each part covers, the obligations and deadlines that matter most, and the circulars issued since that change it.  Last updated: 21 October 2026 The SEBI master circular for research analysts is a single document, currently the Master Circular for Research Analysts dated February 6, 2026 (reference HO/38/12/11(1)2026-MIRSD-POD/I/4360/2026), that consolidates all SEBI circulars applying to RAs and rescinds the older ones to the extent they relate to RAs. It is where the detail behind the SEBI (Research Analysts) Regulations, 2014 lives: fee limits, deposit slabs, MITC, the advertisement code, reporting formats and FAQs. Many of its duties come down to keeping good client records, which a CRM for SEBI research analysts can hold in one place. Below is a section-by-section summary, a table of the recurring deadlines and a list of later circulars that change it. This is a summary, not legal advice: read the full circular on sebi.gov.in and check for newer circulars before you rely on any point. What is the master circular for research analysts?SEBI issues master circulars so intermediaries can find every applicable circular in one place. The February 6, 2026 edition is addressed to all research analysts and to RAASB (BSE). Anything done under the rescinded circulars is treated as done under the matching part of the master circular. The appendix lists the circulars it replaces. It does not replace the regulations. The regulations create the duty, and the master circular says how to meet it. For the regulations themselves, see our plain-English guide to the SEBI research analyst regulations. How is the master circular organised?Part I: what are the core guidelines?Qualification (1.1)Existing RAs, principal officers and analysts do not need the revised qualification, but must hold NISM certification. Holders of NISM's PG programme in research analysis skip the entry exam but must renew within three years of registration. Deposit (1.2)Kept in liquid or overnight mutual fund units or a scheduled bank deposit, liened to RAASB, from ₹1 lakh (up to 150 clients) to ₹10 lakh (above 1,000 clients), revised by April 30 each year. Part-time RAs (1.4)Explains who qualifies, with examples (CAs, insurance agents, teachers with an NOC, doctors) and who does not (people advising on gold, real estate or crypto). Other invoices must carry a disclaimer that those services are outside SEBI's purview. AI tools (1.7)The RA is solely responsible for data security and AI-based research, and must disclose the extent of AI use when sharing terms and conditions. Research services (1.8)Every research service must be backed by a research report with data and analysis, and research given to clients of other paid services counts as "for consideration". What does it say about fees and client terms?Paragraph 1.9 sets the fee rules for individual and HUF clients who are not accredited investors. Fees must be fair and reasonable and may not exceed ₹1,51,000 per annum per family, excluding statutory charges; RAASB will revise the limit once every three years using the Cost Inflation Index. Non-individual clients, accredited investors and institutional clients of proxy advisers agree fees by contract. On early termination the client gets a proportionate refund and no breakage fee may be charged. There is one inconsistency to check. Paragraph 1.9(f) says an RA may charge fees in advance, if the client agrees, for up to one year. The MITC text in Annexure B, reproduced from the February 17, 2025 MITC circular, still says the advance period is "presently one quarter". Do not assume either reading: confirm the current position with RAASB before you set annual billing. Our RA fee limits and payment rules guide follows this point. Paragraph 1.12 requires the RA to disclose terms and conditions and take consent before any research service or fee. Consent can be signed in person or by any legally acceptable mode, including DigiLocker-enabled Aadhaar e-sign. Annexure B lists the minimum terms (13 clauses, including the 12-point MITC); see our MITC guide. What does it say about records, segregation, model portfolios and audit?Records of interaction (1.13)Keep records of conversations about your services with all clients and prospects, from first contact to end of service, as signed papers, call recordings, emails from registered IDs, SMS or other verifiable records, for five years. Segregation (1.10)A client takes either research or distribution within the RA's group or family, with PAN as the control record and an annual certificate from an ICAI, ICSI or ICMAI member or auditor. Model portfolios (1.11, Annexure A)A model portfolio is a basket with recommended weightages, issued through a research report with a factsheet, methodology, label, horizon, review frequency, risk disclosure and benchmark. See model portfolio rules. Audit (1.14, 31)Complete the annual compliance audit within six months of the financial year end, file it with RAASB within one month of the report and by October 31, and publish the audit status and any adverse findings on your website. Parts II to IV: supervision, complaints and technologyBSE is recognised as RAASB for five years from July 25, 2024. Applications for registration go to RAASB, which scrutinises them and recommends them to SEBI; registration, enforcement and penalties stay with SEBI. RAASB sets its own administrative fees, and the combined SEBI and RAASB fees are meant to be fee neutral compared with the old structure. On complaints, RAs must display grievance contact details in their office, bring the Investor Charter (Annexure D) to clients' notice on the website, at onboarding and by email, and publish complaint data on the website by the 7th of each month in the Annexure E format. For the investor route, see SCORES and ODR for research analysts. Part IV reproduces a CERT-In advisory asking firms using SaaS tools for governance, risk and compliance to keep critical data within India, with a half-yearly compliance undertaking. Part V: which miscellaneous rules matter most?Advertisement code (11)Ads must carry your registered name, registration number and the standard warning, avoid superlatives, testimonials and return claims, and need prior approval from RAASB. See the advertisement code guide. CeFCoM (12)BSE's optional Centralised Fee Collection Mechanism, which RAs should encourage clients to use. Conflicts of interest (16)General guidelines: written policies, fair treatment of clients, disclosure of conflicts and no misuse of client information. Association with unregistered persons (21)No association with people who give securities advice or make return claims without SEBI permission, except via a specified digital platform. PaRRVA (22-23)Past performance may only be advertised using PaRRVA-verified metrics. As an interim step, CA or CMA-certified past data may be shared one-to-one on a client's request, never on a website or public media. See PaRRVA explained. Other references (24-27)Cybersecurity (CSCRF), real-time price data norms, standardised UPI IDs for collecting fees, and digital accessibility under the Rights of Persons with Disabilities Act. Which deadlines does the master circular set?Our monthly compliance checklist turns these into a calendar. What has changed since February 6, 2026?A master circular is a snapshot. These later SEBI documents change or add to it, and there may be newer ones by the time you read this:
Using the master circular in your daily workRead the master circular once in full, then keep the deadline table and Annexure B close. Most of what it asks for is evidence: consent before service, KYC, client registers, call and email logs, complaint data and audit records. A research analyst CRM such as Finuro keeps that evidence together, with KRA checks, MITC e-sign, recommendation records and an audit trail. Finuro does not file reports with RAASB or give compliance advice, so always check the current circulars on sebi.gov.in. Related Finuro features
Frequently asked questionsAnswers to common questions on this topic. Built for SEBI RAs and IAs Keep the records the master circular asks forFinuro stores consent, KYC, recommendations and client communication for SEBI research analysts in one place.  |
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