Client Agreement Consent: What a Research Analyst Should Keep on File
A signature on a PDF says the client agreed. It does not say when, to which version, or whether they had the terms open at all. An inspector can ask all three.
Short answer: get the client's consent to your terms before the first research note and the first fee. Keep a record of when they consented, to which version, and from where. When your terms change, get consent again before the next fee. Keep it all for five years with your other Regulation 25 records.
The rule
The RA Master Circular (para 1.12(b)) and the preamble to its Annexure B, the mandatory terms, put it in one line:
“neither any research service is rendered nor any fee is charged until consent is received from the client on the terms and conditions.”
Two more duties follow from it. When you change your terms, existing clients consent to the new version before their renewal or next fee (para 1.12(f)), and the agreement gives them notice of the change in advance (Annexure B, item 10). Read the client agreement guide for what the agreement itself has to contain.
What a consent record should hold
| Keep | Why it matters |
|---|---|
| When the client signed | Shows consent came before the first research note and the first fee. |
| Which version of the terms | When your terms change, you need to show which clients agreed to which text. |
| A fingerprint of the exact text | Lets you show the document on file is the one the client signed, not a later edit. |
| Where it was signed from | IP address and city tie the signature to a session, not just a name typed into a box. |
| How long the document was open | Shows the client had the terms in front of them. It does not show they understood them. |
A WhatsApp “OK” or a scanned signature covers the first row at best. The version row is the one that bites later: the day you change your fee or your refund terms, you need to know who agreed to the old text and who agreed to the new one.
How Aktai records it
Aktai gives you a certificate for each signed agreement: time, IP, city, document version, and how long the client read it. You can download it as a PDF for your file or your auditor. Read time is reported by the client's browser, and the certificate says so. It shows the client had the terms open, not that they understood them.
FAQ
Can a Research Analyst charge a fee before the client agrees to the terms?
No. The RA Master Circular says no research service is rendered and no fee is charged until consent is received from the client on the terms and conditions.
Do existing clients need to consent again when my terms change?
Yes. Existing clients consent to the changed terms before the renewal or the next fee, and the agreement provides for notice of changes in advance. Keep a record of which clients agreed to which version.
How long should I keep client consent records?
Keep them with your other Regulation 25 records, which a Research Analyst retains for five years.
General guidance for SEBI-registered Research Analysts in India, not legal advice. Check the current RA Master Circular for the exact wording, and have your agreement reviewed by a compliance professional.