SEBI Master Circular 2026 for Research Analysts – Fees | Dual Registration | Renewals

The Securities and Exchange Board of India (SEBI) has issued the 2026 Master Circular for Research Analysts (RAs), consolidating all applicable regulations, guidelines, and circulars into a single, comprehensive regulatory framework.

The Master Circular rescinds earlier circulars to simplify compliance, while preserving the validity of actions taken under the earlier framework.

1. Consolidation and Rescission of Earlier Circulars

SEBI has clarified that:

• All previous circulars and instructions applicable to Research Analysts stand rescinded
• Prior actions, approvals, and enforcement proceedings under earlier circulars remain valid, ensuring continuity and legal certainty

2. Eligibility and Certification Requirements

The Master Circular clearly defines eligibility criteria for Research Analysts, including:

• Mandatory NISM certification requirements
• Renewal obligations for existing registered Research Analysts
• Continued compliance with qualification and experience norms

These provisions aim to ensure competence and professionalism in research and advisory services.

3. Client-Linked Security Deposit Requirement

Research Analysts are required to:

• Maintain a client-linked security deposit, linked to the number or scale of clients
• Ensure the deposit is maintained on an ongoing basis as prescribed

This measure strengthens investor protection and enhances accountability.

4. Dual Registration and Part-Time Research Analysts

SEBI has introduced greater flexibility by allowing:

• Dual registration as both Investment Adviser (IA) and Research Analyst (RA), subject to compliance with applicable regulations
• Part-time Research Analysts, enabling wider participation while maintaining regulatory oversight

5. Responsible Use of Artificial Intelligence and Data Security

The Master Circular strengthens governance around:

• Responsible and ethical use of Artificial Intelligence (AI) in research and recommendations
• Data security and confidentiality of client information
• Internal controls to prevent misuse of technology and data

6. Supervision by BSE and Investor Grievance Handling

Key supervisory and investor protection measures include:

• Supervisory oversight by BSE for Research Analysts
• Strengthened investor grievance redressal mechanisms
• Clear timelines and procedures for handling complaints

7. Proxy Advisor Norms

The Master Circular also incorporates updated norms applicable to proxy advisors, ensuring:

• Transparency in research and voting recommendations
• Proper disclosures of conflicts of interest
• Accountability to investors and stakeholders

8. Key Takeaway

The 2026 Master Circular:

• Serves as a single reference point for Research Analyst compliance
• Enhances flexibility without diluting investor protection
• Strengthens governance, technology use, and supervision
• Simplifies regulatory navigation for RAs

Click Here To Read The Full Circular