MITC, KYC and Reporting for SEBI Research Analysts (2026)
Three terms come up again and again in SEBI Research Analyst compliance, and they are easy to muddle: MITC, KYC, and reporting. They are not the same thing and they do not happen at the same time. One is what you share before you start, one is what you check at onboarding, and one runs for years afterwards. Here is each pillar, in order, with where it sits in the client relationship and how to keep the proof.
Not legal advice. A general explainer for SEBI-registered Research Analysts. Confirm current requirements against the SEBI circulars and the RAASB portal, and take professional advice for your own practice.
The three pillars, in order
Think of it as a timeline. The MITC comes first, before the client has paid you anything: it sets the terms. KYC comes at onboarding: it verifies who they are and captures consent. Reporting and record-keeping then runs for the whole relationship and five years past it. Get the order right and the obligations stop feeling like a tangle.
Most Important Terms and Conditions
A plain, standardised summary of what the client is signing up for: the scope of your research service, the fees and how they are charged, the risks, what you will and will not do, and the client’s rights and complaint routes. It has to be shared and explicitly accepted before you start, and you have to keep proof. The point of the MITC is that a client can understand the deal at a glance, without wading through a long agreement.
Full MITC guide →Know Your Customer
Verifying who the client is and capturing the records that prove it: PAN, a KRA or CKYC lookup, identity, and the client agreement and consent. Done as a digital flow (PAN check, KRA/CKYC, Aadhaar e-sign) it takes minutes per client rather than a folder of paperwork. KYC is also where most record-keeping gaps are created, so a repeatable flow that stores every artefact is worth more than it looks.
Digital KYC guide →Reporting and record-keeping
Everything you produce and send, kept in a retrievable, tamper-evident form: research reports, the rationale per recommendation, client communications across channels, and the periodic obligations like the complaints disclosure and the annual compliance audit. This is the pillar that runs longest and gets tested hardest, because it is what an auditor or an inspection actually asks to see.
Annual audit guide →The thread that ties all three together: proof
The common failure across all three pillars is not doing the thing, it is being unable to prove you did it. You shared the MITC, but can you show the client accepted it, and when? You did the KYC, but can you produce the documents two years later? You sent the research, but can you show what you said, to whom, in a form that has not been edited since? An auditor treats an obligation you cannot evidence as one you did not meet.
That is why the practical answer to all three is the same: run them as repeatable flows that store every artefact automatically, and keep the records in a form that is tamper-evident rather than editable. A signed acceptance with a versioned timestamp, a KYC pack stored against the client, and a hashed, timestamped trail of every note you sent. The compliance is real, but most of the pain is record-keeping, and record-keeping is a solved problem if you let software do it.
Where Aktai fits
Aktai is a research desk, and the pillar it owns is reporting. Every note you mark as sent is hashed, timestamped, locked, retained five years, and exportable as a CSV when the annual audit asks. It captures client-agreement acceptance with versioning, so the consent side has a record too. For full digital KYC e-sign you can pair an independent KYC aggregator alongside Aktai today. The point is that the longest and most-tested pillar, the one that decides how your audit goes, is the part Aktai makes automatic.
FAQ
What is the difference between MITC, KYC and reporting for a Research Analyst?
They sit at three points in the client relationship. MITC, the Most Important Terms and Conditions, is what you share and the client accepts before you begin: a plain summary of scope, fees, risks and rights. KYC is the identity and suitability check you complete at onboarding. Reporting and record-keeping is the ongoing obligation that runs for the life of the relationship and five years beyond: keeping your research, communications and consents in a retrievable, defensible form.
When do I have to share the MITC with a client?
Before the service begins. The MITC has to be shared and explicitly accepted by the client before you start providing research, and you have to keep proof of that acceptance. It is not a document you send afterwards or bury in a longer agreement; it is meant to be a clear, standalone summary the client sees and agrees to up front.
Is digital KYC allowed for SEBI Research Analysts?
Yes. A paperless flow built on PAN verification, a KRA or CKYC lookup, and Aadhaar-based e-sign is standard and accepted, and it is far faster than collecting physical documents. The important part is not the channel but the record: you need to retain the KYC artefacts and the client’s consent in a form you can produce on demand. Our digital-KYC guide covers the building blocks and the workflow.
What reporting and records does a Research Analyst have to keep?
Your research reports and the rationale behind each recommendation, your client communications across every channel, the KYC and consent records, the MITC acceptance, and your books of account, all retained for five years. On top of that you have periodic obligations such as the complaints disclosure and the annual compliance audit. The records have to be retrievable and tamper-evident, not just sitting somewhere.
How does Aktai cover MITC, KYC and reporting?
Aktai is strongest on the reporting and record-keeping pillar: every research note you send is SHA-256 hashed and stored with its timestamp, recipient and content, retained five years, and exportable as a CSV for the annual audit or an inspection. For the consent side, it captures agreement acceptance with versioning. For full digital KYC e-sign, an independent KYC aggregator pairs cleanly with Aktai today; the research output and the audit trail are the part Aktai automates.