SEBI Updates for IAs & RAs — July–August 2025

What’s new

1) Research Analyst (RA) FAQs — What actually changed on the ground (July 23, 2025)

SEBI issued an 18-page FAQ circular to resolve practical questions post-January 2025 Guidelines. Key operational clarifications include (illustrative, not exhaustive):

  • Certification timeline for associated persons: Persons associated with research services must hold the relevant NISM certification within a specified window (one year from the FAQ circular for those not already certified).
  • MITC for institutional clients: For QIBs/institutional clients, signature on MITC may not be mandatory, but disclosure/availability of MITC remains the RA’s responsibility.
  • Record-keeping: Reinforces 5-year retention for research reports, client communications (calls/emails/SMS), and public appearances where research views are expressed.

Read the official FAQ circular here (and refer to Annexure-A for detailed Q&As): “Frequently Asked Questions (FAQs) related to regulatory provisions for Research Analysts” (Jul 23, 2025). Securities and Exchange Board of India

2) Amendment Regulations — Codifying the 2025 regime

  • RA Amendment Regulations, 2025 (Aug 6, 2025): Updates the Research Analysts Regulations, 2014 to align with the new 2025 framework (including definitions, obligations like MITC, and supervisory constructs). Official page: “Securities and Exchange Board of India (Research Analysts) (Amendment) Regulations, 2025.” Securities and Exchange Board of India
  • IA Amendment Regulations, 2025 (Aug 7, 2025): Updates the Investment Advisers Regulations, 2013 to reflect fee-cap mechanism, operational obligations, and other 2025 changes. Official page: “Securities and Exchange Board of India (Investment Advisers) (Amendment) Regulations, 2025.” Securities and Exchange Board of India
  • Regulations index (consolidated): SEBI’s live regulations page now reflects the “last amended” dates for both RA and IA Regulations (Aug 6 and Aug 7, 2025, respectively), confirming incorporation. Securities and Exchange Board of India

3) Deposit Requirement — New option via Liquid/Overnight MFs (Aug 12, 2025)

SEBI now permits the required deposit (mandated for IAs/RAs under the 2025 framework) to be maintained via units of Liquid Mutual Funds or Overnight Mutual Funds under lien to the supervisory body — in addition to the bank FD option. Circular: “Use of liquid mutual funds and overnight mutual funds for compliance with deposit requirement by Investment Advisers and Research Analysts” (Aug 12, 2025). Securities and Exchange Board of India

Quick table: Deposit options (as of Aug 12, 2025)

OptionPermitted?Lien in favour of
Bank Fixed DepositYesIAASB/RAASB (as applicable)
Liquid MF unitsYesIAASB/RAASB
Overnight MF unitsYesIAASB/RAASB

Source: SEBI Circular dated Aug 12, 2025. Securities and Exchange Board of India

4) EoDB (Ease-of-Doing-Business) — Fresh proposals open for comments (Aug 7, 2025)

SEBI opened a public-comments window titled “Proposals for Ease of Doing Business for Investment Advisers and Research Analysts”. This lives on SEBI’s Reports/Consultation listing and the Public Comments portal, and includes ideas like streamlining documentation, clarifying fee modalities in special cases, and simplifying ongoing filings (exact proposals as per the page at the time you access it).

Action point: If your practice sees edge-cases (e.g., second-opinion engagements, transition from RA to IA or vice-versa within a group, or AI-tool disclosures), it’s worth submitting concise comments backing practical solutions.

5) Cross-cutting: RPWD Act compliance for all regulated entities (Jul 31, 2025)

SEBI mandated compliance with the Rights of Persons with Disabilities Act, 2016 and associated rules by all regulated entities. For IAs/RAs, this touches website/app accessibility, forms, disclosures, and support channels (e.g., accessible PDFs, alt-text, captioning, and disability-friendly grievance pathways). Circular: “Rights of Persons with Disabilities Act, 2016… mandatory compliance by all Regulated Entities” (Jul 31, 2025). Securities and Exchange Board of India

6) Implementation Planner — What IAs/RAs should do now

A) 30-Day “Do-Now” Checklist

TaskWhySource
Review RA FAQs and update SOPs (certification, MITC handling for institutions, records)Align operations with clarified expectationsSecurities and Exchange Board of India
Update internal policies to reflect Amendment Regs 2025Codified law now in forceSecurities and Exchange Board of India+1
Decide deposit instrument (FD vs Liquid/Overnight MF) and execute lien formalitiesBenefit from liquidity while remaining compliantSecurities and Exchange Board of India
Conduct RPWD accessibility audit of website/formsCross-cutting legal duty; reduces legal/reputational riskSecurities and Exchange Board of India
If relevant, submit comments on EoDB proposalsInfluence practical refinements that save compliance cost/timeSecurities and Exchange Board of India+1

B) Documentation & Evidence to Maintain

7) Context & Backbone documents (for reference)

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