SEBI Inspection Readiness for Research Analysts (2026)
An inspection is not a test of your analysis. It is a test of your records. The analysts who sail through have one thing in common: the records already exist, dated and intact, so producing them is a download, not a scramble. Here is the document pack inspectors ask for, the gaps that turn up findings, and how to stay ready.
Note: General information, not legal advice. Inspection scope varies; confirm specifics against the SEBI Regulations and any notice you receive.
The document pack
Have these ready as a standing folder, not a fire drill:
- Registration certificate and NISM Series XV certification, current and valid.
- Client list with KYC, signed agreements and MITC acknowledgements.
- Research reports: dated, signed, with the rating defined and the rationale on record.
- Regulation 25 record-keeping, tamper-evident, retained 5 years.
- Complaint register and the periodic complaints disclosure.
- Fee records, within the โน1,51,000 per family cap for individual and HUF clients.
- The latest annual compliance audit report and proof it was filed with RAASB.
- Website disclosures: investor charter, grievance and SCORES links, registration display.
The gaps that become findings
Most findings are not about a bad call. They are about records that cannot be trusted or disclosures that went stale:
- Research notes in WhatsApp and editable files, with no proof of when a call was first made.
- An investor charter or complaints table that is months out of date.
- Reports that use a rating with no defined meaning, horizon or benchmark.
- A complaint register with holes in it.
- Fees that crept above the โน1,51,000 per family cap for individual or HUF clients.
- No registration-number display on the website or social handles.
Readiness is a habit, not an event
You cannot prepare for an inspection in a weekend if the underlying records were never kept properly. The fix is to keep them continuously. The single most valuable habit is a tamper-evident archive of what you sent each client and when, because that is the record an inspector probes hardest under Regulation 25, and it is the one that is hardest to reconstruct after the fact.
How Aktai shortens the research record
Every note you send through Aktai is SHA-256 hashed and stored for five years with its date, recipient and content, and you can export the full log as a CSV. When an inspector asks for your research records, that part is already done. The rest of the pack, KYC, agreements, the charter, the complaints table, still needs to be in order, but the heaviest piece is no longer a scramble.
FAQ
What records does a SEBI inspection ask for?
Your registration and NISM certification, the client KYC and agreement records, the MITC acknowledgements, the research reports with their dates and rationale, the Regulation 25 record-keeping, the complaint register, the fee records, the annual compliance audit report, and your website disclosures. In short, proof that you do what the rules require.
What are the most common inspection findings?
Records that are not tamper-evident, missing or stale website disclosures (investor charter, complaints table, registration display), research reports without a defined rating system or rationale, gaps in the complaint register, and fees that drifted above the cap. Most findings are about records, not analysis.
How far back do I need to keep records?
At least 5 years under Regulation 25 for research reports and related records. The key is that the records show their original date and have not been altered since, which an editable spreadsheet or document cannot demonstrate.
How can I be ready before the notice arrives?
Keep the records continuously, not retroactively. A research-note archive that hashes and timestamps every send means the heaviest part of an inspection is already done. Aktai keeps that archive automatically and exports it as a CSV, so you can produce the research record in minutes.