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.

October 28, 2026 · 4 min read · By Aktai Team

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

KeepWhy it matters
When the client signedShows consent came before the first research note and the first fee.
Which version of the termsWhen your terms change, you need to show which clients agreed to which text.
A fingerprint of the exact textLets you show the document on file is the one the client signed, not a later edit.
Where it was signed fromIP address and city tie the signature to a session, not just a name typed into a box.
How long the document was openShows 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.

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Not financial advice. Aktai is software for SEBI-registered Research Analysts. It is not a financial adviser, broker, Investment Adviser, or Research Analyst, and is not registered with SEBI or any other financial regulator. It surfaces public filings and news and drafts factual notes for the registered analyst to review, edit, and sign. Aktai does not author research, make recommendations, or decide what any security is worth. The view, the recommendation, and the regulatory responsibility stay with the registered analyst who sends the note. Full disclaimer →