The Research Analyst Client Agreement: What SEBI Requires (2026)
Most analyst-client disputes are won or lost on one question: what did you agree to in writing? A clear client agreement is your single best protection. It is also a SEBI expectation. Here is what the agreement must contain, the clauses that actually matter when something goes wrong, and the records to keep.
Note: General information, not legal advice. Have a qualified professional review your agreement against the current SEBI Regulations before you use it.
Why the agreement matters
A handshake and a UPI payment is not a client relationship a regulator recognises. The written agreement defines the service, sets the fee, records the risk disclosures, and gives you a clean answer when a client claims you promised something you did not. It works with the MITC, which summarises the headline points, and your KYC records, which establish who the client is.
The clauses that matter
Scope of service
Exactly what the client gets: research notes, the coverage, the channels, the cadence. Be specific so expectations are set.
Fees and payment
The fee, the mode, the billing cycle, and that individual and HUF fees are within the โน1,51,000 per family per year cap. Advance-fee limits apply.
Status and disclaimers
You are a SEBI-registered Research Analyst, not an Investment Adviser. No assured returns. Investments carry market risk. Research is a recommendation, not an instruction.
Conflict of interest
Any financial interest in covered securities, and how you manage conflicts.
Data and confidentiality
What client data you collect, how you protect it, and that you do not seek trading credentials or take custody of funds.
Grievance and dispute
Your complaint contact, the SCORES route, and the ODR portal for unresolved disputes.
Term, termination and refund
How long the agreement runs, how either side ends it, and what happens to fees on termination.
Sign it digitally, store it tamper-evident
Use a digital signature or Aadhaar eSign. It is faster for the client, and it gives you a timestamped record that cannot be quietly back-dated. The signature and date are the whole value of the document. A Word file with an editable modified date does not prove when the client agreed. Store the signed agreement with your Regulation 25 records for at least five years.
Keep the agreement and the research record together
An agreement on its own is half the picture. When a client disputes a call, you need both the agreement that set the terms and the timestamped record of what you actually sent them. Aktai handles the second half: every research note you send is hashed and stored for five years, so the agreement and the evidence of what you delivered live in the same auditable trail.
FAQ
Does a SEBI Research Analyst need a written client agreement?
Yes. You should have a written agreement with every fee-paying client that sets out the service, the fee, the risk disclosures, the conflict position and the grievance route. It sits alongside the MITC and your KYC records, and it is one of the first things an auditor or inspector asks to see.
What must the agreement contain?
The scope of research service, the fee and payment mode within the SEBI cap, the term and renewal, a clear statement that you are an RA and not an Investment Adviser, no-guaranteed-returns and market-risk disclosures, conflict-of-interest disclosure, data and confidentiality terms, the complaint and dispute process including SCORES and ODR, and termination and refund terms.
Can the agreement be signed digitally?
Yes. A digital signature or an Aadhaar eSign is valid and is the cleaner way to keep a tamper-evident, timestamped record. Store the signed agreement with your other Regulation 25 records for 5 years.
How long do I keep the agreement?
Keep the signed agreement, the MITC acknowledgement and the KYC records for at least 5 years, in a form where the date cannot be quietly changed. The record is only useful in a dispute if you can show when it was signed.