The Securities and Exchange Board of India (SEBI) has issued a circular making call recordings of communications with institutional investor clients optional for research analysts and research entities from November 8, 2026. The circular updates the research analysts master circular following notified regulatory amendments, implementing the relaxation approved by SEBI’s board in September after public consultation and industry representations. The exemption is limited to call recordings for institutional clients, while the broader obligation to document client interactions remains. Records must cover service related conversations with all clients, including prospective clients before onboarding, from the first interaction through completion of research services. The requirement covers both fee paying clients and clients receiving research as an additional service alongside paid services at the entity or family or group level. Records must be retained for five years, longer where a dispute remains unresolved, or until further notice where SEBI requires preservation. The revised provisions also retain the clarification that call recording is unnecessary for interactions conducted through email or other means that leave a digital footprint. The Research Analysts Administration and Supervisory Body must amend its relevant rules and bylaws to implement the circular.

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