SEBI Compliance Checklist for Research Analysts 2026
SEBI's Research Analyst Regulations 2014 cover registration, disclosures, record-keeping, and prohibited conduct. A single missed item, a lapsed NISM cert or an informal WhatsApp note not archived, can trigger a show-cause notice. This checklist covers every recurring obligation a SEBI RA must meet in 2026.
Note: This checklist is for general guidance only. Regulations change. Always verify against the current SEBI Research Analyst Regulations and SEBI circulars. Consult a qualified compliance professional for advice specific to your practice.
SEBI registered 1,489 Research Analysts as of March 2025. Inspections and enforcement actions have increased steadily since 2022. The most common findings: missing Regulation 25 records, no disclaimer in research notes, and front-running. All three are avoidable with a structured checklist.
1. Registration and certification
2. Research report requirements
3. Client communication records (Regulation 25)
4. Prohibited practices
5. Annual compliance
How Aktai handles Regulation 25 automatically
Regulation 25 is the clause most RAs struggle with. It requires 5-year retention of all research communications, including informal notes. The problem: most RAs send notes via WhatsApp or email, then store nothing.
Aktai addresses this in three ways. First, every research note sent through Aktai is timestamped and stored in an audit log. Second, the full text of each delivery is retained for 5 years on Aktai's servers. Third, you can export a CSV of all sent notes at any time for your own records or for SEBI inspection.
The log captures the note text, the ticker it relates to, the delivery channel (WhatsApp, Telegram, email), the recipient client ID, and the delivery timestamp. This is exactly what a SEBI inspector looks for under Regulation 25.
Key dates to track in 2026
The three violations that trigger most SEBI RA actions
1. Missing Regulation 25 records
The most common finding in SEBI RA inspections. WhatsApp and Telegram tips sent without any archiving. The fix is to either use a platform that logs automatically or maintain a daily export of all sent messages.
2. No disclaimer in research notes
Every note, even a one-line stock view shared informally, is a research communication under SEBI rules. It needs your RA registration number and a disclaimer. A bulk WhatsApp broadcast without this is a violation.
3. Trading before publishing a recommendation
Regulation 16 prohibits an RA from trading in a security within the 30-day period before and after recommending it, with narrow exceptions. SEBI cross-checks RA trading data against published recommendation dates.
FAQ
Do I need to renew my NISM certification as a SEBI Research Analyst?
Yes. NISM Series XV (Research Analyst) certification is valid for 3 years. You must pass the renewal exam before expiry. SEBI can suspend or cancel your RA registration if your NISM certification lapses. Set a calendar reminder at least 6 months before your certificate expiry date.
What must be included in a research report under SEBI RA regulations?
Every research report must include: your SEBI RA registration number, a disclaimer stating it is not investment advice, disclosure of any conflict of interest (if you or your associates hold the stock), the basis and sources of your recommendation, and a risk disclosure. Omitting any of these makes the report non-compliant under the Research Analyst Regulations 2014.
Can a SEBI Research Analyst charge success fees or performance-linked fees?
No. SEBI prohibits performance-linked or success fees for Research Analysts. You cannot charge a fee tied to portfolio returns, profit sharing, or trading outcomes. Permitted structures are flat fees, retainer fees, and per-report fees only. Charging a success fee exposes you to regulatory action under Regulation 22 of the RA Regulations.
What records must a SEBI Research Analyst keep?
Under Regulation 25, you must maintain records of all research reports issued, all recommendations (including informal ones sent via WhatsApp, email, or Telegram), client agreements, fee receipts, and conflict-of-interest disclosures. The records must be maintained in a format that is retrievable for SEBI inspection.
How long must a SEBI Research Analyst keep research records?
SEBI Regulation 25 requires Research Analysts to retain all records for a minimum of 5 years. This includes research reports, client communications, fee receipts, and complaint records. Records must be kept in a manner that allows prompt retrieval if SEBI requests them during an inspection.