SEBI Research Analyst Compliance Checklist

A reference checklist covering both sides of RA compliance — becoming a SEBI-registered Research Analyst, and staying compliant after registration.

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This checklist is built from the actual SEBI (Research Analysts) Regulations, 2014 and the SEBI/BSE circulars that RA OS itself tracks and files against for real, currently-registered Research Analysts — the same regulation citations and due-date logic that runs this platform's own live Compliance Tracker. It is meant as a genuinely useful reference for anyone evaluating whether to become a SEBI RA, or an existing RA checking their own ongoing obligations — not a marketing page.

Before You Register — What SEBI Requires to Become an RA

Source: SEBI (Research Analysts) Regulations, 2014 and the cited circulars — transcribed from the same regulation-by-regulation checklist RA OS's own Annual Compliance Audit template uses.

Regulation 3
Certificate of registration is mandatory

Application for grant of certificate. (1) No person shall act as a Research Analyst or hold itself out as an Research Analyst unless he has obtained a certificate of registration from the Board under these regulations.

Regulation 6
Eligibility criteria for grant of registration

Consideration of application and eligibility criteria. Regulation 6 states all the matters, which are relevant for the purpose of grant of certificate of registration.

Regulation 7 & SEBI circular Ref no. SEBI/HO/MIRSD/MIRSD-PoD-1/P/CIR/2025/004 dated January 08, 2025, point 2(i)
Qualification requirement

An individual Research Analyst or a principal officer of a non-individual research analyst registered as a Research Analyst under these regulations and persons associated with research services shall have minimum qualification and certification requirements as mentioned in Regulation 7(1) and 7(2). For the RAs existing as on 16 December 2024: it is clarified that the revised qualification requirements shall not be required for existing individual RAs, Principal officer of non-individual RAs or research entity, individuals employed as research analysts and partners of research analyst, if any, engaged in providing research services [Para 2.i. of SEBI/HO/MIRSD/MIRSD-PoD1/P/CIR/2025/004].

SEBI circular Ref no. SEBI/HO/MIRSD/MIRSD-PoD1/P/CIR/2025/004 dated January 08, 2024, point 2(i) & BSE Circular Ref. No. 20250313-10 dated March 13, 2025
NISM certification requirement — NISM-Series-XV, renewed via NISM-Series-XV-B

An individual registered as research analyst under the RA Regulations, 2014, a principal officer of a non-individual research analyst, individuals employed as research analysts, persons associated with research services, and in case of the research analyst being a partnership firm, the partners thereof if any, who are engaged in providing research services: (i) shall obtain certification(s) from NISM by passing the "NISM-Series-XV: Research Analyst Certification Examination", as mentioned in the NISM communiqué No. NISM/Certification/Series-XV: Research Analyst/2015/01 dated February 16, 2015. (ii) shall, in order to ensure continuity in compliance with the certification requirements, before expiry of the validity of the existing certification as specified in clause (i), obtain certification from NISM by passing the NISM-Series-XV-B: Research Analyst Certification (Renewal) Examination as mentioned in the NISM communiqué No. NISM/Certification/NISM-Series-XV-B: Research Analyst Certification (Renewal) Examination/2024/01 dated January 06, 2025.

Regulation 8 & SEBI circular Ref no. SEBI/HO/MIRSD/MIRSD-PoD1/P/CIR/2025/004 dated January 08, 2025, point 2(ii)
Capital requirement — currently in force: deposit by client-count slab Current

Applies based on the number of clients you have — the minimum deposit required rises in slabs as your client count grows:

Number of clientsMinimum deposit required
Up to 150 clients₹1 Lakh
151 to 300 clients₹2 Lakhs
301 to 1,000 clients₹5 Lakhs
1,001 clients and above₹10 Lakhs
Superseded — old net-worth requirement, applied only till 15th December 2024 (historical reference only) Superseded

Net worth requirement till 15th December 2024 as below: (1) A research analyst who is individual or partnership firm shall have net tangible assets of value not less than one lakh rupees. (2) A research analyst who is body corporate or limited liability partnership firm shall have a networth of not less than twenty five lakh rupees.

This net-worth requirement is no longer an active/current requirement — it was superseded by the deposit-by-client-count-slab requirement above (Regulation 8 read with SEBI/HO/MIRSD/MIRSD-PoD1/P/CIR/2025/004), which is what a prospective or currently-registered RA needs to satisfy today. Shown here only as historical context.

After You're Registered — Ongoing Compliance

Two checklists RA OS itself generates and tracks for a live, registered RA org: a recurring filing calendar with real due dates, and the document bundle needed for the Annual Compliance Audit.

Time-bound annual filing calendar

The recurring compliance deadlines RA OS's own Compliance Tracker auto-generates for every financial year (FY = April to March).

ObligationDue dateRegulation / circular citation
Monthly complaints/SCORES data — publish on website Mandatory7th of the following month, every monthMaster Circular SEBI/HO/MIRSD/MIRSD-PoD-1/P/CIR/2024/49, Cl. 5.3
BSE Periodic Reporting — H1 (Apr–Sep)31 OctoberBSE RAASB Annexure I — 8 schedules (General, Complaints, Clients & Fees, Website, Social, Bank, NISM, UPI)
BSE Periodic Reporting — H2 (Oct–Mar)30 AprilBSE RAASB Annexure I — 8 schedules
Half-yearly SaaS compliance undertaking — H1 (Apr–Sep)31 OctoberSEBI/HO/MIRSD2/DOR/CIR/P/2020/221 (03-Nov-2020) — CERT-In advisory for SaaS
Half-yearly SaaS compliance undertaking — H2 (Oct–Mar)30 AprilSEBI/HO/MIRSD2/DOR/CIR/P/2020/221 (03-Nov-2020) — CERT-In advisory for SaaS
Annual Compliance Audit Report (ACR)30 SeptemberReg 25(3) RA Regulations + Cl. 2(xiv) CIR/2025/004 — within 6 months of FY-end. Audit by an ICAI/ICSI member; report must contain line-wise compliance status of every provision.
Action Taken Report (ATR) on adverse audit findings31 OctoberCl. 2(xiv)(c)(ii) CIR/2025/004 — within 1 month of the audit, not later than 31 October
Client-level segregation — annual auditor certificate30 SeptemberCl. 2(x)(h) CIR/2025/004 — CA/auditor certificate within 6 months of FY-end
Deposit adequacy review against client-count slab31 MarchReg 8 — ≤150 clients: ₹1L · 151–300: ₹2L · 301–1000: ₹5L · 1001+: ₹10L
Records, KYC & Investor Charter maintenance review31 MarchReg 25 + Cl. 2(xiii) + Master Circular 5.1 — recommendation/client/public-appearance registers, KYC, 5-year retention
NISM-Series-XV-B (Renewal) examBefore your own certificate's validity expiresTracked per-RA against your own NISM-XV certificate's validity window (illustrative example this codebase tracks: a certificate valid 17-Oct-2023 to 12-Oct-2026 — renew before expiry to stay eligible; your own dates will differ)
Inform SEBI/BSE in writing of any material change to your submitted information MandatoryAs and when it happens — not on a fixed dateRegulation 13(ii) — address, name, ownership, or any other material change vs. what was originally submitted to SEBI must be reported; distinct from simply keeping a record of it for your own audit file

Annual audit document checklist

The evidence bundle a registered RA keeps ready every year for the Annual Compliance Audit (Reg 25(3)) — the same 34-item kit RA OS's own Compliance Tracker walks an RA through.

Always N/A for an individual RA with no employees and no separate principal officer:

Disclaimer

This list is not exhaustive/comprehensive. It highlights the major, recurring obligations RA OS itself tracks — SCORES/complaints disclosure, FIU registration, and KRA/POS registration are all genuinely mandatory for a registered RA, not optional items to skip. A registered RA also has a standing duty under Regulation 13(ii) to inform SEBI/BSE in writing of any material change to previously-submitted information (address, name, ownership, or anything materially different from what was declared at registration) — this is separate from simply keeping a record of material changes for your own audit file. This checklist is for general informational and reference purposes only — it is not legal, regulatory, or investment advice, and does not replace consulting SEBI, BSE/RAASB, or your own compliance professional (CA/CS) directly. It reflects RA OS's own understanding of the SEBI (Research Analysts) Regulations, 2014 and the circulars cited above, as of the date shown on this page, and is subject to SEBI's own future updates — always verify the current requirement on SEBI's or BSE's own website before relying on it for a registration or filing decision.


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