From Authorised Person or Sub-Broker to SEBI Research Analyst
Client trust built through execution does not automatically license you to sell research. If recommendations are part of what you actually do, RA registration is probably required, not optional.
An Authorised Person or sub-broker earns brokerage-linked income for referring and servicing clients who trade through a registered broker. That status alone does not cover a second, distinct activity many APs end up doing informally: telling clients what to buy, sell, or hold. If that is a real part of the relationship, not an occasional aside, SEBI treats it as research activity requiring its own registration.
Where the line actually sits
The test is not how formal the advice sounds, it is whether you are giving clients specific views on securities, price targets, or recommendations, as an ongoing part of the relationship rather than a one-off comment. An AP who consistently sends trade ideas to a client list is functioning as a research provider in substance, whatever the arrangement is called informally.
What RA registration requires
The same baseline as any individual RA registration: the NISM Series-XV exam, a โน10,000 application fee, a โน1,500 NISM exam fee, a minimum net worth of โน1 lakh certified on letterhead, and 30 to 90 days of SEBI processing time. AP or sub-broker status is not a shortcut through any of this, it is a separate registration on top. Full detail in the registration guide.
Two income streams, kept separate
AP income is brokerage-linked and tied to execution. RA income is a fee paid directly by the client for research. Running both means keeping the two clearly disclosed and separated, so a client understands whether they are paying for execution-linked service or for independent research, not an undifferentiated blend of the two.
The business case for making it official
Beyond compliance, registration is also a credibility signal. A client-facing disclosure that you are a SEBI-registered Research Analyst, with the audit trail and disclosure obligations that come with it, reads differently than an informal tip from someone who happens to also handle your trades. See building a personal brand as a SEBI Research Analyst for how registered RAs turn that into a business.
FAQ
Can an Authorised Person give stock tips or recommendations to clients?
Not for a fee, and not as a business of giving research or recommendations. AP status covers referring clients to a broker for trade execution, earning brokerage-linked income. Publishing research or recommendations as a service requires separate SEBI Research Analyst registration.
Do I lose my AP or sub-broker status if I register as an RA?
Not automatically, but the two activities run on different rules and different income models, execution-linked brokerage versus fee-based research, and need to stay clearly separated and disclosed to clients rather than blended into one undifferentiated relationship.
What is the fastest way to know if I actually need RA registration?
If you are giving clients specific buy, sell, or hold views on securities, a price target, or a recommendation, and doing it as an ongoing service rather than a one-off remark, you are functioning as a research provider and the registration requirement almost certainly applies.