SEBI Model Portfolio for Research Analysts (2025-26)
The model portfolio is the most-asked-about RA product in 2026. Smallcase normalised the format for retail; SEBI's 2025 master circular put structure around it. The rules are clear: stated mandate, declared benchmark, quarterly performance reporting, no execution on the client's behalf, no performance-linked fee. Inside those guardrails, baskets are a high-leverage business for an RA.
Note: The framework is in active evolution. Verify against the SEBI master circular for Research Analysts as of your filing date, and consult compliance counsel before launching a model portfolio product.
A model portfolio is a research output, not a managed product. The distinction matters because it sits on one side of a bright regulatory line. Cross it (execute trades for the client, take custody, charge an AUM fee) and you are in PMS territory, with a different licence and a โน50 crore net-worth requirement. Stay on the RA side and you have a clean product: publish the basket, publish the performance, let subscribers replicate at their broker.
The eight constraints that define a compliant model portfolio
What goes into a quarterly performance report
The line between research and PMS
The single most important thing to get right is the execution boundary. As long as the client decides whether and when to replicate the portfolio, you remain an RA. The moment you place orders on the client's behalf, hold their securities, or charge a fee tied to their realised returns, you have crossed into portfolio management. The financial threshold for that is significant: PMS managers in India need a minimum net worth of โน5 crore (or โน50 crore in some categories), a separate registration, and a much heavier compliance burden.
A smallcase-style broker integration is the standard pattern that keeps you on the RA side. The basket is published; the broker offers a one-click replication tool; the client clicks; the broker places the orders into the client's account. The RA is a publisher, not an executor.
Fee structures that work
Per-basket monthly or annual subscriptions are the cleanest. โน999 to โน4,999 a year per basket is the common retail range; โน15,000 to โน50,000 for high-conviction or thematic baskets aimed at higher-net-worth subscribers. Bundle discounts (subscribe to 3 baskets for the price of 2) are allowed. Performance-linked fees are not. AUM-percentage fees are not, because the โassetsโ sit in the client's broker account, not yours, and pricing against them implies a custody relationship you do not have.
How Aktai supports a model-portfolio practice
Aktai's current B2B product covers the research-note side: filings dashboard, AI note drafts, audit trail. The model-portfolio surface, basket builder with target weights, broker-deep-link replication, quarterly performance reporting against a declared benchmark, sits in Tier 2 of our roadmap (3 to 6 months). When it ships, the existing audit trail extends to cover every rebalance and constituent change automatically, which is the single biggest compliance gap in the current smallcase-style workflows.
FAQ
What is a model portfolio under the SEBI RA framework?
A model portfolio is a basket of securities an RA publishes with target weights, rebalancing rules, and a stated objective. Clients who subscribe to a model portfolio replicate it (often through a broker integration) at their own discretion. SEBI's 2025 master circular treats this as a structured form of research and applies disclosure, benchmarking, and performance reporting requirements distinct from ad-hoc stock recommendations.
Do I need a separate SEBI registration to publish a model portfolio?
No, the existing RA registration covers model portfolios as long as you operate within the framework: the portfolio is a research output, you do not execute trades on behalf of the client, and you do not collect a portfolio-based or performance-linked fee. Crossing into discretionary execution would push you into the PMS regulation, which is a separate licence.
What benchmark must I use for a model portfolio?
The benchmark must be appropriate to the portfolio's mandate. A large-cap basket benchmarks against Nifty 50 or BSE Sensex; a mid-cap basket against Nifty Midcap 100; a sector basket against the corresponding sector index. The benchmark is declared at portfolio launch and cannot be silently changed. Any change requires re-disclosure to subscribers.
How often must I publish portfolio performance?
Performance must be published at least quarterly, with the calculation methodology disclosed (typically a time-weighted return or money-weighted return), benchmark comparison, and the period covered. Cherry-picking a favourable window is prohibited; you publish the same window every quarter and include all rebalances and entries.
Can I show backtested returns for a new model portfolio?
Backtest results carry strict disclosure requirements: clearly labelled as hypothetical, methodology disclosed, no implication that future performance will match. The framework discourages backtest-only marketing because of the well-known overfitting risk. Live track record builds slowly; the framework treats it as more credible than backtest.