The Securities and Exchange Board of India has issued an updated master circular for Research Analysts, consolidating applicable circulars and directions issued up to June 20, 2025 into a single reference document. The compilation supersedes the previous master circular and rescinds the earlier circulars listed in the appendix to the extent they relate to Research Analysts, while preserving prior actions, obligations, liabilities and ongoing proceedings under the rescinded directions. The circular restates key operational requirements across registration, conduct, investor protection and supervision, including client-count based deposits (INR 100,000 up to 150 clients rising to INR 1,000,000 for 1,001+ clients) to be maintained as a lien-marked bank deposit in favour of the Research Analyst Administration and Supervisory Body (RAASB). It also consolidates rules on retail fee charging (a cap of INR 151,000 per annum per family for individual and Hindu Undivided Family clients, excluding statutory charges, with proportionate refunds on premature termination and no breakage fee), client-level segregation of research and distribution activities using PAN as the control record (with limited waiver for institutional clients and accredited investors), AI-tool accountability and disclosure expectations, record-keeping (including retention of client and prospective-client interactions for five years), model portfolio reporting standards, advertising and brand-name restrictions, change-in-control approval processes, and periodic reporting, audit and website disclosure obligations. The master circular also brings together proxy adviser procedural guidelines, investor grievance handling via SCORES and the Online Dispute Resolution platform, monthly website disclosure of complaint statistics, and half-yearly reporting of compliance with the Software as a Service (SaaS) advisory. Several compliance timelines are reiterated, including meeting fee-related requirements for existing clients by June 30, 2025, adopting model portfolio guidelines by June 30, 2025 where applicable, and confirming website details to RAASB by June 30, 2025. Existing Research Analysts must meet the deposit requirement and the client-level segregation requirements by September 30, 2025, and certain partnership firms must migrate to a limited liability partnership or body corporate by September 30, 2025 if no partner meets the minimum qualification and certification requirements. Periodic reports are due within 30 days of each half-year end (with the March 31, 2025 half-year deadline extended to July 31, 2025), and annual compliance audits must be completed within six months of each financial year end and submitted within one month of the audit report, but not later than October 31.

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