SEBI circular SEBI/HO/MIRSD/ MIRSD-PoD/P/CIR/2025/105 · 23 Jul 2025
Official title
Frequently Asked Questions (FAQs) related to regulatory provisions for Research Analysts
Summary
Check the official recordSEBI has issued clarifications via Frequently Asked Questions (FAQs) regarding the regulatory framework for Research Analysts (RAs) and research entities. The update mandates that persons associated with research services obtain NISM certification within one year. It provides regulatory relief for institutional investors and Qualified Institutional Buyers (QIBs) by making the signing of terms and conditions, including the Most Important Terms and Conditions (MITC), non-mandatory, provided disclosures are still made. Furthermore, the circular clarifies the scope of client-level segregation between research and distribution activities, allowing exemptions for institutional clients and QIBs upon receipt of a standard waiver. These measures aim to ensure regulatory clarity and ease of compliance for registered RAs and research entities.
What you must do
Key dates
Who is affected
Exceptions
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CIRCULAR
SEBI/HO/MIRSD/ MIRSD-PoD/P/CIR/2025/105
July 23, 2025
To,
All registered Research Analysts BSE Ltd. (Research Analyst Administration and Supervisory Body- RAASB)
Sir / Madam,
Sub: Frequently Asked Questions (FAQs) related to regulatory provisions for Research Analysts
Securities and Exchange Board of India (SEBI) has notified SEBI (Research Analysts) (Third Amendment) Regulations, 2024 on December 16, 2024. Pursuant to these amendments, SEBI has issued a circular dated January 08, 2025 on guidelines for research analysts.
SEBI is in receipt of representations from Research Analysts (RAs) requesting to provide clarifications on certain regulatory provisions.
In this regard, in order to provide clarity and guidance for compliance by RAs with the regulatory provisions, the details/clarifications are provided as part of the Frequently Asked Questions (FAQs) at Annexure A. These FAQs are issued after public consultation and incorporating various suggestions received during such consultation (wherever found appropriate). For full particulars of laws governing the Research Analysts (RAs), please refer to the Acts/ Regulations/ Guidelines/ Circulars, etc. appearing under the Legal Framework Section of SEBI website. For an interpretation of a specific provision of the Regulations, informal guidance may be sought as specified under SEBI (Informal Guidance) Scheme 2003.
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i. Persons associated with research services shall obtain the relevant certification from NISM as specified by SEBI within one year from the date of this circular.
ii. Consent by signature on the terms and conditions including most important terms and conditions (MITC) shall not be mandatory for the clients who are institutional investors or qualified institutional buyers. However, RAs/research entities are required to disclose the terms and conditions of research services including MITC to these clients.
This circular is issued in exercise of powers conferred under section 11(1) of the Securities and Exchange Board of India Act, 1992 read with Regulation 33 of Securities and Exchange Board of India (Research Analysts) Regulations, 2014 to protect the interests of investors in securities market and to promote the development of, and to regulate the securities market.
This circular is available on the SEBI website at www.sebi.gov.in under the category "Legal →Circulars".
Yours faithfully,
Aradhana Verma General Manager Tel. No. 022-26449633 aradhanad@sebi.gov.in
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Annexure A
FREQUENTLY ASKED QUESTIONS (FAQs)
1. How are research analysts regulated in India? The SEBI (Research Analysts) Regulations, 2014 (“RA Regulations”) came into effect from December 01, 2014. The RA Regulations specify conditions for registration, certification, limitations on trading by research analysts, limitations on compensations of research analyst, various disclosures to be made during public appearance and during making recommendations through public media, code of conduct, records to be maintained, manner of conducting inspection, etc. The RA Regulations (as amended from time to time) are available on the SEBI website www.sebi.gov.in.
2. Whether the individuals employed as research analyst with a research entity are required to obtain registration certificate under RA Regulations? No. Individuals employed as research analyst with a research entity are not required to obtain registration certificate from SEBI. The research entity, which employs individuals as research analysts, is required to obtain registration certificate under the RA Regulations. The individuals employed as research analyst by research entity are required to comply with qualification and certification requirements as specified in the regulations. The trading limitations prescribed under the regulations are applicable to them.
3. Whether the personnel involved in publication activities like marketing and editing are covered under the definition of Research Analyst under RA Regulations? The personnel engaged in clerical activities/marketing activities, back office assistance, support services, etc., in relation to publication and/or distribution of research report are not covered under the definition of research analysts.
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These personnel are also not considered as persons associated with research services if –
(i) these personnel while performing these activities do not have client contact, or
(ii) these activities have no connection with the research services provided as a RA.
4. What are the communications excluded from the definition of research report? "Research report” does not include the following communications: -
i. comments on general trends in the securities market; ii. discussions on the broad-based indices; iii. commentaries on economic, political or market conditions; iv. periodic reports or other communications prepared for unit holders of Mutual Fund or Alternative Investment Fund or clients of Portfolio Managers and Investment Advisers; v. internal communications that are not given to current or prospective clients; vi. communications that constitute offer documents or prospectus that are circulated as per regulations made by SEBI; vii. statistical summaries of financial data of the companies; viii. technical analyses relating to the demand and supply in a sector or the index; ix. any other communication which SEBI may specify from time to time.
5. Whether technical analysis as a methodology is exempted from the purview of the RA Regulations? Research services provided under RA Regulations are specific to the securities under purview of SEBI and are agnostic to the methodology used to provide research services. Providing research services (including buy/sell/hold recommendation) on a security or securities based on any methodology
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(including the technical analysis) is not exempted from the purview of the RA Regulations. However, technical analyses relating to the demand and supply for a particular sector or index is exempted from the purview of RA Regulations.
6. What are the communications excluded under periodic reports referred to in answer to FAQ No. 4 above? Periodic reports such as sending financial account statements, annual reports and any other communication as required under the specific regulations prepared for unit holders of Mutual Fund or Alternative Investment Fund or clients of Portfolio Managers and Investment Advisers are excluded from the definition of research report under RA Regulations.
7. Does RA Regulations cover only equity and equity linked securities? No. RA Regulations cover all securities as defined under clause (h) of section 2 of the Securities Contracts (Regulation) Act, 1956.
8. Who is required to make an application to get registration under RA Regulations? No person shall act as a research analyst or research entity or hold itself out as a research analyst unless he has obtained a certificate of registration from SEBI on and from the commencement of RA Regulations unless an exemption specifically applies to such a person.
An applicant who intends to engage in providing research services such as issuance of research report or research analysis is required to make an application for registration under RA Regulations.
9. Which intermediaries are covered under the definition of ‘Research Entity’ who are mandated to obtain registration under RA Regulations? SEBI registered Stock Brokers, Merchant Bankers and other intermediaries except those who are exempted from making application for registration under RA Regulations are required to make application for grant of registration under
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