SEBI RA Client Communication: Scripts That Stay Regulation 25-Safe (2026)
Most SEBI Research Analysts write client messages by feel: a quick WhatsApp update, a price-target revision, an onboarding note. The delivery channel gets attention, the wording usually does not. But Regulation 25 and the advertisement code impose real requirements on what the message itself has to say, not just where it is stored.
Wording is a compliance surface, not just a courtesy
A SEBI inspection does not just check whether your client messages are logged. It checks what they say. A perfectly tamper-evident record of a message that never disclosed a position, never referenced the client agreement, or never mentioned SCORES is still a finding. Three requirements come up most often in enforcement actions and inspection reports:
- Position disclosure on every recommendation. Not just the first one to a client, every single note.
- Registration and grievance channel, stated proactively. Clients should not have to ask for your INH number or how to file a complaint.
- A traceable link back to the signed client agreement. Especially for fee changes, renewals, and grievance responses.
Two examples
Here is what that looks like in practice. Two scripts from the full pack, with the reasoning behind the wording:
New client onboarding (WhatsApp)
Hi [Client Name], welcome to [Firm Name]. You are now onboarded as a research client under my SEBI RA registration [INH000XXXXXX]. I will share research recommendations and updates on this number. Every message here is logged as required under SEBI Regulation 25. You can reach me at [phone] or [email] for questions, and file a complaint via SCORES (scores.sebi.gov.in) or the SMARTODR portal if needed.
Why it matters: States the registration number up front, points to the grievance channel SEBI requires you to disclose, and confirms the client agreement exists, three things inspectors check for first.
Research note delivery (WhatsApp)
[Stock Name] ([NSE/BSE code]): [Buy/Sell/Hold], Target: [Rs.X], Stop-loss: [Rs.X], Horizon: [X months]. Rationale: [1-2 lines]. Disclosure: I/my associates [do/do not] hold a position in this stock. This is not personalised advice; please assess your own risk tolerance.
Why it matters: The disclosure line is not optional. SEBI requires every recommendation to disclose whether the analyst or associates hold a position in the security being recommended.
Free download
RA Client WhatsApp & Email Script Pack
- All 8 scripts: onboarding, MITC consent, research delivery, price-target updates, conflict-of-interest disclosure, declining off-platform requests, fee renewal, and grievance acknowledgment
- Each script comes with the specific SEBI requirement it satisfies
- Copy, fill the placeholders, send through your logged channel
Wording solves the content problem, not the record-keeping problem
Getting the wording right is necessary but not sufficient. SEBI still requires every client communication to be retained for 5 years in a form that proves it was not altered after the fact. A perfectly worded message sent from a personal WhatsApp number with no logging mechanism satisfies the content requirement and fails the record-keeping one. See why spreadsheets and personal chat history do not hold up when an inspection actually asks for the record.
Declining requests is part of the script set too
Clients will occasionally ask for something outside what you can compliantly provide: a tip over a phone call with no record, a note forwarded to a friend who has not signed the client agreement, a recommendation for a stock outside your published coverage. How you decline matters as much as how you deliver research, since agreeing "just this once" is exactly the gap an inspection finds later. The full pack includes a script for this specific situation.
FAQ
Does SEBI require specific wording for RA client messages?
SEBI does not prescribe an exact template, but Regulation 25 and the advertisement code impose requirements the wording must satisfy: a recommendation must disclose whether the analyst or associates hold a position, every message must be attributable to your registration, and grievance-channel information must be disclosed proactively rather than only on request. A script that misses any of these can be compliant in delivery but non-compliant in content.
Is sending research over personal WhatsApp allowed?
WhatsApp itself is a permitted channel, but the message still has to be retained for 5 years in a tamper-evident form under Regulation 25. Personal WhatsApp with no logging mechanism does not satisfy that requirement regardless of what the message says, since the record can be deleted or the phone replaced with nothing to show an inspector.
What happens if I forget the disclosure line on a recommendation?
A missing conflict-of-interest or position disclosure is one of the more common findings in SEBI RA inspections. It does not need to be a long paragraph, a single line stating whether the analyst or associates hold a position in the security is enough, but it needs to be present on every recommendation, not just the first one to a client.
Can I reuse the same onboarding script for every client?
Yes, the structure should be the same for every client since it exists to disclose the same required information: your registration number, the logging of communications, and the grievance channel. Only the bracketed placeholders (client name, your firm name, registration number) change.