SEBI RA Call Recordings: What Changes on 9 November 2026
One proviso, one new definition, and a lot of RAs reading it as a bigger change than it is.
Short answer: call recordings were already part of your Regulation 25 records. From 9 November 2026, recording calls with institutional investor clients is no longer mandatory. For retail clients and prospects, nothing changes: keep recording.
The amendment
SEBI amended the Research Analysts Regulations, 2014 on 10 October 2026 through the SEBI (Research Analysts) (Amendment) Regulations, 2026, notification SEBI/LAD-NRO/GN/2026/321. It comes into force on 9 November 2026. Regulation 25(1)(vii) now reads:
(vii) records of communication including emails, call recordings with all clients including prospective clients in such manner as may be specified:
Provided that the requirement to maintain call recordings of communications with clients which are institutional investors shall not be mandatory.
The same amendment inserts Regulation 2(1)(ia), which defines "institutional investor" by pointing to Regulation 2(1)(y) of the SEBI (Issue of Capital and Disclosure Requirements) Regulations, 2018.
Before and after
| What | Until 8 Nov 2026 | From 9 Nov 2026 |
|---|---|---|
| Wording of 25(1)(vii) | Listed "call recordings etc." | "etc." dropped. Emails and call recordings named |
| Institutional investor clients | Recordings kept like any other client | Recording not mandatory (new proviso) |
| Definition | Not defined in the RA Regulations | Reg 2(1)(ia) "institutional investor", meaning as in ICDR 2018 Reg 2(1)(y) |
| Retail clients and prospects | Recordings kept | No change. Recordings kept |
Who the exemption actually covers
Most independent RAs serve retail clients. For them the proviso changes nothing. It matters if you sell research to institutions, and even then only for the clients that meet the ICDR definition.
A client with a large portfolio, a family office run by one person, or an HNI who pays for your top plan is not an institutional investor because of the size of the cheque. Read the ICDR definition, decide client by client, and write down why. If an inspector asks why a client's calls were not recorded, "they are big" is not an answer.
Prospects count too
The clause says "all clients including prospective clients". The sales call where a lead asks what your last few calls returned, or whether you can pick stocks for them, is exactly the conversation you want on record. It is also the one most often taken on a personal phone and never saved.
What to put in place before 9 November
- Record every call with a client or prospect, including WhatsApp, Zoom and Meet calls. The clause says call recordings, not phone calls only
- File each recording against the client it belongs to, with the date and who was on the call
- Write a short note for every call: what was discussed and whether a recommendation came up
- Mark institutional investor clients in your client register, with the basis for each, before you stop recording them
- Keep recordings where you keep your other Regulation 25 records, not on a personal phone
- Check that associates who take client calls follow the same process
Note: the clause keeps records "in such manner as may be specified". Format and storage details come from SEBI circulars, not from the regulation itself. Check the current circulars for retention and format.
Where recordings live in Aktai
Aktai keeps an interaction log per client: inbound WhatsApp and Telegram replies, website enquiries, and the calls and meetings you add, with the call recording attached. You upload the recording or paste a link to it, so each call sits next to the client, the notes and the research it relates to. See the features page for the rest of the record-keeping tools.
Questions RAs ask
Did SEBI just start requiring Research Analysts to record calls?
No. Call recordings were already part of the records under Regulation 25(1)(vii). The 10 October 2026 amendment tidies the wording and adds one exception: recording calls with institutional investor clients is no longer mandatory from 9 November 2026.
Do I need to record calls with prospects who never become clients?
Yes. The clause covers "all clients including prospective clients". A sales call with a lead is a communication with a prospective client, so keep the recording.
Can I stop recording institutional clients now?
Not before 9 November 2026, when the amendment comes into force. After that, recording them is optional. Keep a note on file of why each such client counts as an institutional investor.
Is a large individual client an institutional investor?
Not because of the size of the account. The amendment adds a definition at Regulation 2(1)(ia) that takes its meaning from Regulation 2(1)(y) of the ICDR Regulations, 2018. Read that definition before you treat any client as exempt. If in doubt, record.
Does keeping call recordings cover all of Regulation 25?
No. Recordings are one item in a longer list of records that also covers every recommendation and its basis, other client communications, KYC and conflict-of-interest disclosures. A full recording archive with no notes behind your calls still leaves a gap.
General guidance for SEBI-registered Research Analysts in India, not legal advice. Aktai is software; you, the registered RA, remain responsible for your records. Check the notification and current SEBI circulars before relying on any point here.