The SEBI Investment Adviser Guide (2026)
Short answer
Who the IA regime covers
Anyone who gives investment advice for a fee, to a client, about securities or other SEBI-regulated products, needs registration as an Investment Adviser. Registered advisers carry an INA-series number. The test is personalised advice: telling a specific client what to buy, hold or sell given their situation. Publishing research to a list of subscribers is Research Analyst territory instead, covered in the SEBI Research Analyst guide.
Registration needs the qualifications, NISM Series X-A and X-B certification and the financial requirement set out in how to register as a SEBI Investment Adviser. Mutual fund distribution has to stay segregated from advice; the IA vs MFD guide covers where that line sits.
The client lifecycle SEBI imposes
Most of the IA rulebook is a sequence that has to hold for every client, in order. Miss a step and the advice that follows is a breach, however good it was.
| Step | What it means | When |
|---|---|---|
| Onboard | KYC, PAN, the client’s financial details | Before any advice |
| Risk profile | A dated profile the client consents to | Before advice, re-assessed at least yearly |
| Suitability | A finding per recommendation against the current profile | Every piece of advice |
| Agreement | Signed advisory agreement plus the IA MITC | Before advice, again on every new version |
| Fees | One mode per family, within the SEBI limit | Every fee plan and invoice |
| Disclose | Conflicts of interest and holdings | Standing, and with advice where relevant |
| Record | Advice linked to the suitability basis it relied on | Kept at least five years |
| Audit | Annual compliance audit | Every financial year |
Risk profiling and suitability
The risk profile records the client’s age, objectives, horizon, income, assets, liabilities and tolerance for loss, with a score and a date, and the client consents to it. Suitability is the separate judgement that a specific recommendation fits that profile. One profile, many suitability findings. Both go stale: re-assess at least once a year and whenever the client’s circumstances change.
A form on file is not the same as compliance. What matters is that no advice leaves without a current profile and a suitable finding behind it. Suitability without a gate explains how to make that hold on a busy day.
The advisory agreement
The agreement, with the SEBI-standardised Most Important Terms and Conditions for Investment Advisers, is signed before advice starts. It sets out the scope, the fee and its limit, advance fees and refunds, conflicts, confidentiality and grievance redressal. Every time you change it, each client has to accept the new version. The agreement checklist generator lists the terms with your details filled in.
Fee limits
For individual and HUF clients, choose one mode per family: up to 2.5% of assets under advice a year, or up to ₹1,51,000 fixed a year. The fixed limit is per family, so plans for a husband, a wife and their HUF count together. Fees go through banking channels only, and can be collected up to one year in advance if the client agrees. Check a family’s plans with the fee-limit calculator, and read AUA vs fixed for how to choose.
Advertising
IA advertisements carry the adviser’s name, INA number, BASL membership and the standard risk disclaimer. They cannot promise returns, use superlatives without a verifiable basis, quote client testimonials, or blur advice with distribution. Past performance needs independent verification before it goes anywhere near an ad.
Records, grievances and the annual audit
Keep the trail for at least five years: KYC, the dated risk profile, suitability findings, the signed agreement version, fees, and every piece of advice linked to the basis it relied on. Client grievances go first to you, then to SEBI SCORES, then to the Online Dispute Resolution portal. After each financial year, an annual compliance audit checks all of it.
The audit is far easier when the record was built as you went rather than reconstructed from email. The IA compliance guide walks through what an inspector asks for first.
Running the practice on software
Spreadsheets hold the records but cannot stop a send. Software built for the IA regime should block advice when a step is missing, check fees per family and keep the trail tamper-evident. The buyer’s guide and the options compared cover what to check before you buy.
Frequently asked questions
What is a SEBI Investment Adviser?
A person or firm registered with SEBI under the Investment Advisers Regulations 2013 to give personalised investment advice for a fee. An IA owes the client a fiduciary duty, must risk-profile the client and assess suitability before advising, and identifies itself with an INA-series registration number.
How is an Investment Adviser different from a Research Analyst?
A Research Analyst publishes research and recommendations to subscribers; an Investment Adviser advises a named client on what suits them. The IA carries the heavier obligations: per-client suitability, a signed advisory agreement before advice, and fee limits per family.
What are the SEBI Investment Adviser fee limits?
For individual and HUF clients, one fee mode per family: up to 2.5% of assets under advice a year, or up to ₹1,51,000 fixed a year. Accredited investors and non-individual clients agree fees bilaterally. Fees can be collected up to one year in advance if the client agrees.
How long must an Investment Adviser keep records?
At least five years. That covers KYC, the risk profile and its date, suitability findings, the signed agreement, fee records and a log of the advice given with the basis it relied on.
Does an Investment Adviser need a compliance audit every year?
Yes. An IA has to get an annual audit of its compliance with the regulations done after each financial year, and act on what it finds. Check the current timing and auditor eligibility against the SEBI Investment Advisers Regulations.
Related reading
General information, not legal or compliance advice. SEBI rules change: check the current SEBI Investment Advisers Regulations, the Master Circular for Investment Advisers and recent circulars, and confirm your own position with your compliance officer.