Client Onboarding for SEBI Research Analysts: 2026 Playbook
Most independent SEBI Research Analysts run client onboarding through a Google Form, a couple of WhatsApp messages, and a PDF agreement attached to an email. It works until a complaint arrives or a SEBI inspector asks for the signed agreement and risk profile of a client from 2024. A structured onboarding flow takes 30 minutes per client and produces records that survive scrutiny.
Note: General guidance only, not legal advice. Confirm KYC, eSign, and consent requirements against the current SEBI master circular and the SEBI Research Analyst Regulations 2014 before adopting this playbook.
Onboarding is the place where Research Analysts most often cut corners and where SEBI inspectors look first. The reason is structural: an RA who serves 20 clients has done onboarding 20 times, almost all of them informally. There is no calendar reminder for “collect KYC,” just a new client who wants a quick start. Six months later, the records do not exist.
A clean onboarding flow has six steps: contact and qualification, KYC, optional risk profile, agreement signing, channel consent, and watchlist setup. The total time is about 30 minutes per client if your tooling is set up. None of the steps require a developer or an enterprise platform.
The six-step flow
Initial contact and qualification
5 minMost leads arrive via WhatsApp, referral, or website form. Capture their PAN, contact, and what they are looking for. Decide if your service fits their use case (you do equity research, not portfolio management, not advisory).
KYC: PAN verification + KRA lookup
5 min if KRA hit, 15 if freshVerify PAN against the NSDL PAN API. Hit the KRA (CDSL, CVL, KARVY) for existing KYC. If the client has KYC with any other SEBI intermediary, this returns verified KYC in seconds. If not, collect Aadhaar, address proof, and a photo, and submit a fresh KYC.
Risk profile (optional but recommended)
5 minA short 8 to 12 question form covering investment horizon, prior experience, income, risk tolerance, dependants. Store the answers, the score, and the date. Used later to defend against suitability complaints.
Service agreement and fee schedule
10 minSend a draft PDF with services, fee structure, RA registration details, conflict disclosures, and termination clauses. Get it signed via Aadhaar eSign. Store the signed copy alongside the KYC.
Consent for research delivery channels
2 minCapture explicit, channel-by-channel consent: WhatsApp, email, Telegram. SEBI and the WhatsApp Business policy both require opt-in. Store the consent record with a timestamp.
Welcome and watchlist setup
5 minGet the client's portfolio holdings or watchlist, either via a CSV upload, a CDSL CAS PDF, or a structured form. Confirm the first research note will arrive within the first business day.
Documents to collect and store
The agreement clauses that matter
The RA-client agreement is the document SEBI looks at if a complaint reaches the regulator. Six clauses do the heavy lifting: the scope of services (research only, not advice, not portfolio management), the fee structure (flat or retainer, never performance-linked), the RA registration number with validity, the conflict-of-interest disclosure (do you or any associate hold the stocks you will recommend), the complaint redressal mechanism (your direct contact plus SEBI SCORES), and termination clauses with refund policy if any.
A clause RAs often forget: explicit consent for the delivery channel. SEBI's Investor Charter and the WhatsApp Business policy both require the client to opt in to each channel separately. A blanket “you may contact me” is not enough. Capture the channels they want, store the consent with a timestamp, and honour opt-outs immediately.
Common onboarding mistakes
Skipping KYC because the client is a friend or referral
SEBI does not care that you went to college together. A complaint from a friend client is still a complaint, and without KYC, you have no defence.
Charging a success fee or profit share
Regulation 22 prohibits performance-linked fees for RAs. Flat fees, retainers, and per-report fees are the only permitted structures. The agreement must reflect this.
Verbal agreement followed by “send me your number”
No signed agreement means no enforceable services contract. SEBI inspectors look for the signed PDF first; absence of one is treated as non-compliance with the Code of Conduct.
How Aktai handles client records
Aktai for Research Analysts (ra.aktai.app) stores the client list with onboarding dates, fee structure, delivery channels, and consent records. Client portfolios feed the filings dashboard so that the same record set powers both ongoing alerts and the annual SEBI return. The KYC documents and signed agreements still live in your CA-approved compliance folder; Aktai links to them but does not currently process them. Tier 1 of our 90-day roadmap brings PAN, KRA, and Aadhaar eSign into the same flow.
FAQ
Do SEBI Research Analysts need to do KYC of their clients?
Yes. Under the Research Analyst Regulations and SEBI master circulars, you must collect basic KYC: PAN, address proof, contact details, and a record of identity verification. KRA (KYC Registration Agency) lookup is the standard mechanism, returning verified KYC if the client is already registered with any other SEBI intermediary.
Is risk profiling mandatory for SEBI Research Analysts?
Risk profiling is mandatory for SEBI-registered Investment Advisers. For Research Analysts the position is softer: SEBI expects an RA to understand the client and make suitability-appropriate recommendations, but a formal risk profiling questionnaire is not explicitly mandated. Most professional RAs run one anyway, both as good practice and to defend against future suitability complaints.
What must the RA-client agreement contain?
The agreement should cover services to be provided, fee structure (flat, retainer, per-report, no success or performance-linked fees), payment terms, the RA registration number and validity, conflict-of-interest disclosure, complaint redressal mechanism including SCORES, termination clauses, and the standard disclaimer that research is not a guarantee of returns. The agreement is signed by both parties, ideally via Aadhaar eSign for evidentiary value.
Can the client agreement be signed on WhatsApp?
WhatsApp acknowledgement is weak evidence in a dispute. The agreement should be a PDF signed with Aadhaar eSign or a physical signature scanned and acknowledged. WhatsApp can be used to deliver the signed PDF and to confirm acceptance, but it should not be the sole evidence of consent.
How long do I keep onboarding records?
Five years minimum, matching the broader Regulation 25 standard. This covers the KYC documents, the signed agreement, the risk profile (if collected), and the consent record. Records should be retrievable in a SEBI inspection.