SEBI Issues Master Circular for Research Analysts on 27th June 2025

Background: Securities and Exchange Board of India (“SEBI”/ “the Board”), from time to time, has been issuing various circulars/directions to Research Analysts (RAs). In order to enable users to have access to the applicable circulars/directions at one place, this Master Circular in respect of RAs is being issued.

SEBI has issued Master circular SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/95 dt 27th Jun 2025

This circular is issued in exercise of powers conferred under Section 11(1) of the Securities and Exchange Board of India Act, 1992 to protect the interests of investors in securities and to promote the development of, and to regulate the securities market.

Guidelines for Research Analysts:

Regulation: SEBI (Research Analysts) Regulations, 2014 (hereinafter referred to as “RA Regulations”)

Qualification: 

• Revised qualification requirements shall not be required to existing individual RAs, Principal officer of non-individual RAs or research entity, individuals employed as research analysts and partners of research analyst, if any, engaged in providing research services.
• Shall hold NISM certifications and comply with other conditions specified under Regulation 7(3) of the RA Regulations.

Regulation 7 of the RA Regulations

Qualification and certification requirement.

7.(1) An individual registered as research analyst under these regulations, individuals employed as research analyst and partners of a research analyst, if any, engaged in preparation and/or publication of research report or research analysis shall have the following minimum qualifications, at all times:

(i) A professional qualification or post – graduate degree or post graduate diploma in finance, accountancy, business management, commerce, economics, capital market, financial services or markets provided by:

(a) a university which is recognized by University Grants Commission or by any other commission/council/board/body established under an Act of Parliament in India for the purpose; or

(b) an institute/association affiliated with such university; or

(c) an institute/ association/university established by the central government or state government; or

(d) autonomous institute falling under administrative control of Government of India; or

(ii) professional qualification or post – graduate degree or post graduate diploma which is accredited by All Indian Council for Technical Education, National Assessment and Accreditation Council or National Board of Accreditation or any other council/board/body set up under an Act of Parliament in India for the purpose; or

(iii) a professional qualification by completing a Post Graduate Program in the Securities Market (Research Analysis) from NISM of a duration not less than one year; or

(iv) a graduate in any discipline with an experience of at least five years in activities relating to financial products or markets or securities or fund or asset or portfolio management.

(2) An individual registered as research analyst under these regulations, individuals employed as research analyst and partners of a research analyst, if any, shall have, at all times, a NISM certification for research analysts as specified by the Board or other certification recognized by the Board from time to time:

Provided that research analyst or research entity already engaged in issuance of research report or research analysis seeking registration under these regulations shall ensure that it or the individuals employed by it as research analyst and/or its partners obtain such certification within two years from the date of commencement of these regulations:

Provided further that fresh certification must be obtained before expiry of the validity of the existing certification to ensure continuity in compliance with certification requirements.

Deposit requirement:

• As per Regulation 8 of the RA Regulations, a research analyst shall maintain a deposit of such sum, as specified by the SEBI from time to time
• The deposit requirements shall be based on the maximum number of clients of RA on any day of the previous financial year, as under:

• The deposit shall be maintained with a scheduled bank
• The deposit amount may be revised for any change in applicable amount of deposit, based on the maximum number of clients
• The deposit requirements shall be reviewed by SEBI from time to time.
• The existing RAs shall ensure compliance with the deposit requirement latest by September 30, 2025

Registration both as Investment Adviser and Research analyst:

Regulation 9 of the RA Regulations, an individual or partnership firm registered as an investment adviser may be granted certificate of registration as a research analyst, subject to such terms and conditions as the SEBI may deem fit and appropriate.

It shall maintain arms-length relationship between its activity as IA and RA

Registration as part-time research analyst   

An individual or partnership firm who is also engaged in any other business activity/employment which is unrelated to securities and does

not involve handling/ managing of money/ funds of client/ person or providing advice/ recommendation to any client/person in respect of any products/ assets for investment purposes.

Designation as ‘principal officer

In case of non-individual research analyst being a partnership firm, one of the partners shall be designated as its principal officer

Appointment of an independent professional as Compliance Officer:

A non-individual research analyst may appoint an independent professional who is a member of ICAI or ICSI or ICMAI or member of any other professional body as may be specified by the SEBI

Use of Artificial Intelligence (‘AI’) tools in RA services

A research analyst or research entity who uses artificial intelligence tools, irrespective of the scale and scenario of adoption of such tools, for servicing its clients shall be solely responsible for the security, confidentiality, integrity of the client data, use of any other information or data for research services, research services based on output of Artificial Intelligence tools and compliance with any law for the time being in force

Research services provided by research analyst or research entity

Research services provided by RA or research entity shall be corroborated by research report containing the relevant data and analysis forming the basis for such research service. RA or research entity shall maintain record of such research report.

Fees chargeable to clients by RAs

• shall ensure that fee charged to client is fair and reasonable
• shall charge a maximum of ₹1,51,000 per annum per family
• The fee limit does not include statutory charges
• In case of non-individual clients, accredited investors, and in case of institutional investors seeking recommendation of proxy adviser, fee related

terms and conditions shall be governed through bilaterally negotiated contractual terms