MITC for Research Analysts: The Most Important Terms and Conditions (2026)
Long agreements get signed and never read. SEBI's answer for Research Analysts is the MITC: a short, standard summary of the points a client absolutely must understand before they pay you. Get it in front of every client, keep proof, and a lot of future disputes never happen. Here is what it covers and how to handle it.
Note: General information, not legal advice. Use the current MITC text and format published by SEBI or RAASB; confirm before you rely on a template.
What the MITC is for
The Most Important Terms and Conditions is a standardised, plain-language summary of the analyst-client relationship. SEBI introduced it so the headline points are not lost in a twenty-page agreement. It sits on top of your full client agreement and pulls the things a client most needs to understand into one short document they actually read.
What it has to cover
The MITC carries the points that protect both sides. At a minimum:
- You are a SEBI-registered Research Analyst, not an Investment Adviser, and you do not manage funds or give personalised advice.
- Your registration number and the name of the entity providing the service.
- No assured or guaranteed returns. Investments are subject to market risk.
- The fee you charge, the mode of payment, and that the fee for individual and HUF clients is within the SEBI cap.
- That research is a recommendation, not an instruction, and the client decides whether to act.
- Conflict-of-interest position and any financial interest in the securities covered.
- The grievance route: your contact, SCORES, and the ODR portal.
- That you do not seek client trading credentials or take custody of client funds or securities.
Use the standard text where SEBI or RAASB publishes it, rather than writing your own from scratch. Standardisation is the point.
When to share it, and with whom
Share the MITC at onboarding, before the client starts paying, and again whenever your terms change. Both new and existing clients are in scope. The fee cap of โน1,51,000 per family per year for individual and HUF clients applies to everyone, so the MITC's fee line should reflect that. Tie the MITC to your onboarding flow so it is never skipped.
Keep proof you shared it
The MITC only protects you if you can show the client received it. Send it through a channel that records delivery, and keep that record for five years with your other Regulation 25 records. When a client later claims they were never told you do not guarantee returns, a timestamped, tamper-evident record of the MITC ends the argument. Aktai keeps that kind of delivery record automatically for everything you send a client.
FAQ
What is the MITC for a Research Analyst?
MITC stands for Most Important Terms and Conditions. It is a SEBI-standardised summary of the key terms of the analyst-client relationship: that you are a Research Analyst and not an Investment Adviser, that you do not guarantee returns, the fee position, the complaint route, and the disclaimers. You share it with every client so the most important points are not buried in a long agreement.
When do I have to share the MITC?
At onboarding, before or at the point the client starts paying for your research, and again whenever the terms change. Keep a record that the client received it. New and existing clients are both in scope.
Is the MITC the same as the client agreement?
No. The MITC is a short, standardised summary of the most important points. The client agreement is the full contract. You need both. The MITC makes sure the headline terms are read; the agreement covers everything in detail.
How do I prove a client received the MITC?
Send it through a channel that logs delivery and keep the record for 5 years alongside your other Regulation 25 records. A timestamped send over email or WhatsApp, stored in a tamper-evident archive, settles any later dispute about whether the client was told.