You Just Got SEBI RA Registration: The First 90 Days (2026 Checklist)
Your registration consultant's job ends when the certificate arrives. Yours does not. The next 90 days set up the compliance and client-facing infrastructure that either holds up under your first SEBI inspection or does not. Here is the checklist, in the order it actually needs to happen.
Note: This is an informational checklist, not legal or compliance advice. SEBI regulations and rollout timelines (including CeFCoM) change. Always verify current requirements at sebi.gov.in and consult a qualified professional before you rely on any deadline here.
Why the first 90 days matter more than the exam did
Getting registered is a qualification test: NISM, documents, a fee, a wait. Running a registered practice is a different problem. The obligations that start the moment your certificate is issued (disclosures, record-keeping, a compliant client agreement) are exactly the ones registration consultants stop covering, because their engagement ends at the certificate. Nobody hands you a sequence for what comes next.
This is that sequence, broken into three 30-day windows. Each item links to the deeper guide or the free tool that covers it, so this page stays a map rather than another wall of text to read before you can act.
Days 1 to 30
Get the gates open
These are the pieces SEBI expects in place before you take a fee from your first client. None of them are optional, and doing them out of order is the most common early mistake.
Website and practice disclosures
Your registration number, the standard disclaimer, investor charter, SCORES and grievance details, and conflict-of-interest disclosure need to be live on whatever public presence you use, before you accept a fee.
Confirm your deposit
SEBI's deposit requirement scales with how many clients you plan to serve. Work out the slab you fall into now, before your client count forces a last-minute top-up.
CeFCoM enrollment
SEBI's Centralised Fee Collection Mechanism routes client payments through a validated platform. Set up your billing path early rather than retrofitting it once fees are already flowing informally.
Build your client agreement template
You need a compliant agreement ready before your first signature, not drafted under pressure the week a client says yes. Know what SEBI requires the agreement to contain before you write it.
Days 31 to 60
Make the client-facing pieces routine
By now you are likely onboarding, or about to onboard, your first paying clients. These are the per-client processes that need to work smoothly rather than be invented from scratch each time.
MITC, per client, every time
The Most Important Terms and Conditions must go out to every client before you begin research, with proof it was shared. Doing this by hand does not scale past a handful of clients, so template it now.
Wire MITC, KYC and reporting together
MITC, KYC at onboarding, and the ongoing reporting and records you keep afterward are three separate obligations that touch the same client relationship. Treat them as one onboarding flow, not three disconnected tasks.
Turn on record-keeping before your first note goes out
Regulation 25 requires every research report and client communication to be retained in tamper-evident form for 5 years. There is no way to backfill a compliant record after the fact, so this needs to be running before, not after, your first client interaction.
Check your fees against the cap
SEBI caps what an individual RA can charge per client and restricts how much can be collected in advance. Price your first engagements against the actual cap, not a guess.
Days 61 to 90
Build the operating rhythm
The last stretch is about turning one-off setup into a recurring calendar, so nothing in year one becomes a surprise show-cause notice.
Put every recurring deadline on one calendar
The annual compliance audit, the annual return, deposit upkeep, and certification renewal all recur on a schedule. Track them together rather than rediscovering each one as it becomes due.
Note your NISM certificate expiry now
Your NISM Series XV certificate is valid for 3 years from the date you passed. Renewal is not a 90-day task, but the reminder for it needs to be set now, while the exact date is fresh, not rediscovered in year two.
Sanity-check your economics
Ninety days in, you have real numbers: client count, fees collected, and time spent on compliance versus research. Compare that against what the practice actually costs to run.
Read the full compliance checklist once, end to end
By month three you have touched most individual obligations piecemeal. Read the consolidated checklist once as a single pass to catch anything the 90-day sequence did not force you to look at.
For newly-registered RAs
Aktai for Research Analysts: the record-keeping and MITC pieces, running from day one
Aktai for Analysts automates Regulation 25 record-keeping for every research note and client communication, with tamper-evident logging and CSV export ready for a SEBI inspection. Built for the exact obligations this checklist covers, so you set it up once instead of rebuilding it under pressure later.
See Aktai for AnalystsFAQ
What is the first thing I should do after getting my SEBI RA certificate?
Put your website and practice disclosures in place before you take a single fee. SEBI requires registration details, the standard disclaimer, investor charter, and grievance information to be visible before you operate as a Research Analyst, not after. Everything else on this checklist (CeFCoM enrollment, MITC, client agreement, record-keeping) can be sequenced across the following weeks, but disclosures come first because they gate you accepting your first client.
Do I need to enrol in CeFCoM before I can accept client fees?
CeFCoM, SEBI's Centralised Fee Collection Mechanism, is designed to route client payments to Research Analysts through a validated platform. Rollout timelines and enforcement dates have been updated by SEBI over time, so check the current status on sebi.gov.in or with your RAASB rather than assuming a fixed deadline. Treat CeFCoM enrollment as an early task regardless: setting up billing infrastructure after you already have paying clients is harder than setting it up before.
Do I need a separate MITC for every client?
Yes. The Most Important Terms and Conditions document must be shared with each client before you begin providing research, and you need proof it was shared and acknowledged. It is not a one-time document you publish once; it is a per-client artifact. Generating it by hand for every new client is the most common early time sink, which is why a template or generator is worth setting up in week one, not month three.
What counts as record-keeping under Regulation 25, and when do I need it running?
Regulation 25 requires every research report, recommendation, and client communication to be retained in tamper-evident form for a minimum of 5 years. The obligation starts with your first research report, not at some later compliance milestone. Set up your record-keeping system before you send your first note to a client, because there is no way to retroactively create a compliant record of something you already sent informally.
When does my NISM certificate need renewal, and should I think about it in the first 90 days?
The NISM Series XV certificate is valid for 3 years from the date you passed. Renewal itself is not a 90-day task, but noting the expiry date and the CPE (Continuing Professional Education) renewal window on your compliance calendar is. RAs who lapse their certificate mid-practice usually do so because nobody set a reminder at the start, not because the renewal process is hard.
Can I sign my first client before finishing every item on this checklist?
No. Website disclosures, a compliant client agreement, and a working MITC process need to exist before your first paid engagement, not after it. Record-keeping needs to be running from your first research report. CeFCoM enrollment, deposit confirmation, and your compliance calendar can be finished in parallel during the same window, but the core client-facing pieces are prerequisites, not follow-ups.