Introduction
SEBI-registered Research Analysts (RAs) are required comply with a set of requirements in 2025, as part of regulatory efforts to ensure transparency, accountability, and investor protection in the Indian securities market. This article outlines the key deadlines and compliance obligations that every RA should be aware of for seamless operations.
1. Periodic and SaaS Compliance Reporting
A. Periodic Reporting
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- Frequency: Half-yearly
- Deadline: Within 30 days from the end of each half-year
- Submission Mode: BSE Portal
B. SaaS Compliance Reporting
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- Frequency: Half-yearly (March and September)
- Submission Mode: Via email
2. Fixed Deposit Requirement
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- Frequency: Annually
- Deadline: Within 30 days from the end of the Financial Year
- Submission Mode: Email and Physical submission of FDR
3. Contact Details Consistency on Social Media
- Nature: One-time compliance
- Requirement: Ensure that the contact number and email ID used on social media platforms match those registered with SEBI
- Submission: No formal submission required
4. Declaration on Use of Artificial Intelligence (AI) Tools
For Existing Clients:
- Nature: One-time compliance
- Deadline: 30th April 2025
- Action: Notify all existing clients about the use and extent of AI tools in advisory services
For New Clients (onboarded on or after 8th January 2025):
- Disclosure must be made at the time of onboarding
5. Functional Website Requirement
- Nature: One-time compliance
- Deadline: 30th June 2025
- Requirement: RAs without a functional website must create one and inform BSE
- Submission Mode: Email
6. Fee Structures and Terms & Conditions
Fee for Old Clients:
- Deadline: 30th June 2025
- Existing Individual/HUF client fees remain unchanged until current agreement expires or June 30, 2025
Fee for New Clients (onboarded after 8th January 2025):
- Charged as per new SEBI guidelines; other clients are governed by bilateral contracts
Terms and Conditions (T&C) & Most Important Terms and Conditions (MITC):
- Deadline: 30th June 2025
- Old Clients: Consent must be obtained via acceptable legal modes
- New Clients: Onboard only after signing of T&C/MITC
7. Segregation of Research and Distribution Services
- Compliance Start Date: 30th June 2025 (FY 25–26)
- Requirement: Maintain distinct client records for research and distribution services
8. Model Portfolio Reporting
- Compliance Start Date: 30th June 2025 (FY 25–26)
- Requirement: If offering model portfolios, issue them as research reports and follow SEBI’s model portfolio norms
9. KYC and Client Communication Recordkeeping
- Compliance Start Date: 30th June 2025 (FY 25–26)
- KYC must be done for all fee-paying clients by verifying details from the KRA portal
Maintain the following:
1. Signed & dated research reports
2. Research recommendations with rationale
3. Records of public appearances
4. Client registers (PAN, services, fees, etc.)
5. Communication logs (emails, calls, SMS)
6. Terms & conditions with client consent
10. Annual Compliance Audit for SEBI-Registered RAs
- Frequency: Yearly
- Deadline: Audit to be completed within 6 months from the end of financial year; Audit Report to be submitted to SEBI/RAASB within one month of audit completion
- Additional Compliance: In case of any non-compliance, RAs must submit details of corrective action taken by 31st October
- The Audit is required to be done by a competent qualified professional CS, CA, CMA
- Disclosure Requirement: The audit report, including any adverse observations, must be published on the RA’s website for client transparency
- Website Confirmation: Website must be functional and compliant with SEBI requirements; confirmation to be submitted to SEBI by 30th June 2025
- Effective Date: Applicable with immediate effect unless otherwise specified
Conclusion
If you are a SEBI-registered RA and require help with compliance execution, audits, or client documentation, don’t hesitate to reach out for tailored support.
Author can be reached at 9015933164 \ info.compliancebuzz@gmail.com.
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