The Securities and Exchange Board of India (SEBI) has issued an updated master circular for research analysts, consolidating the operative requirements and guidance for SEBI-registered research analysts and proxy advisers into a single reference document. The master circular incorporates provisions from the circulars listed in its appendix and rescinds those earlier directions to the extent they relate to research analysts, while preserving prior actions, rights, liabilities, investigations and proceedings under the rescinded circulars. The consolidated framework restates key conduct and operational obligations, including qualification and NISM certification clarifications, responsibility and client disclosure requirements where artificial intelligence tools are used, and requirements for corroborating research services with documented research reports and maintaining client-interaction records for five years. It also brings together financial and investor-protection controls such as a client-count-based deposit to be maintained in liquid or overnight mutual fund units or as a scheduled-bank deposit and marked as lien in favour of the Research Analyst Administration and Supervisory Body (RAASB) (INR 100,000 up to 150 clients, INR 200,000 for 151–300, INR 500,000 for 301–1,000, and INR 1,000,000 for 1,001 and above), and fee rules for individual and Hindu Undivided Family clients including a maximum of INR 151,000 per annum per family, pro-rata refunds for unexpired periods on early termination and a prohibition on breakage fees. Further sections consolidate requirements on client-level segregation of research and distribution activities at group or family level, advertisement and branding restrictions including limits on performance claims tied to Past Risk and Return Verification Agency (PaRRVA) verification, the process for seeking SEBI’s prior approval for change in control, investor grievance handling and disclosures (SCORES and Online Dispute Resolution linkage, investor charter and monthly complaint-data publication), and periodic reporting and annual compliance audits under RAASB oversight, with BSE Limited referenced as the recognised RAASB. The circular reiterates recurring timelines including recalibrating the applicable deposit based on the prior financial year’s maximum client count by 30 April, half-yearly periodic reporting within 30 days of each half-year end, and completion of the annual compliance audit within six months of the financial year end with submission within one month of the audit report and no later than 31 October. It also provides that the individual and HUF fee cap is to be revised and announced by RAASB once every three years based on the Cost Inflation Index after consultation with SEBI.

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