I have been receiving lot of queries on my blog on Research Analyst regulations. In this post I cover such top 30 queries related to all stages of being a Research Analyst and my personal views on the same based on my experience (updated as on August 25, 2023).
STAGE ONE: BEFORE YOU MAKE AN APPLICATION
#1 – I am an MBA in Finance from a state recognised university. Do I fulfill the qualification and certification requirements?
A: Yes, you fulfill the qualification requirements as per the RA regulations. However, you also need to take up NISM – Research Analyst exam to fulfill the certification requirements. Also, SEBI may ask for experience details, on case to case basis.
To know more about qualification requirements, click here.
#2 – I have a partnership firm and planning to register the same with SEBI. Do all the partners have to fulfill the qualification and certification requirements?
A: No, only those partners who will be involved in research and analysis need to fulfill the qualification and certification criteria.
#3 – What is the meaning of capital adequacy or the net worth criteria?
A: For individuals and partnerships – the net tangible assets should be not less than Rupees 1 Lakh.
“Net tangible assets” means the total assets less intangible assets (like trademarks, goodwill) less liabilities.
For individuals, the items to be included in the net worth certificate can be assets like laptop, house, vehicle, bank balance, FDs and other investments. Liabilities will be home loan, car loan, etc.
For companies and LLPs – the networth should be not less than Rupees 25 lakhs.
“Networth” means the aggregate value of paid up share capital plus free reserves (excluding reserves created out of revaluation) less aggregate value of accumulated losses.
Before you apply to SEBI, please check if you / your partnership firm / your company fulfill the net worth criteria.
The networth certificate has to be provided by Chartered accountant. The certificate should state her membership number, seal and signature.
#4 – If I am providing training and conducting seminars on how to select stocks and mutual funds and also covering fundamental and technical analysis, do I have to get registered as a Research Analyst?
A: If you are providing general training and not specific to any stock / mutual fund / derivative, you are not covered under RA.
Read more: When Research Analyst regulations do not apply to you.
#5 – Can a research analyst be a stock broker as well?
A: As an individual, a research analyst cannot provide stock broking services as SEBI sees this as a conflict of interest. If you are a corporate, you can have two separate departments for providing services. Best is to check with the SEBI officers.
#6 – I am a stock broker. Do I need to get registered with SEBI as a Research Analyst?
A: If you are also providing research recommendations or writing research reports, you need to get registered with SEBI as a Research Analyst.
#7 – Is Income Tax returns (ITR) for three years mandatory? What if I have just started earning and have two years ITR?
A: Yes, ITR for three years is mandatory. If you have just starting earning or if your company is newly incorporated, you may attach a note, along with the application, mentioning the reason why you do not have ITR for three years.
#8 – I am an NRI and would like to provide research services in India. Do I need to get registered as a Research Analyst with SEBI?
A: If a person is located outside India and want to issue research reports or provide research services, he / she needs to have an agreement with a research analyst or research entity registered with SEBI.
#9 – Is CIBIL score mandatory in case of application as a RA?
A: No, CIBIL score is not a mandatory requirement for applications as a RA. However, SEBI officer may request you to submit the same as an additional requirement.
#10 – I am going to give information on my website regarding stocks. The information is on price movements and from the annual reports which is publicly available. However, it will be presented in a manner which will help investors decide on whether to buy that stock or not. Should I get registered as a RA?
A: If you are providing statistical summaries of the financial data of companies and the data is publicly available, then you need not get registered as a RA.
#12 – I run a blog which has analysis and recommendations on listed stocks. However, the information is free to access. Do I need to get registered as a RA?
A: In our view, you need not get registered with SEBI if the access to your recommendations is absolutely free and you do not receive compensation directly / indirectly / through any brokers / through referrals.
#13 – I am a B.Com graduate and I have been investing in markets in my personal capacity and for family for the past 7 years. Do fulfil the qualification requirements for SEBI RA?
A: No. If you are only a graduate, you need to have atleast 5 years working experience in research analysis and should have experience certificates from the employer if you want to get registered with SEBI. SEBI does not consider personal experience in stock markets.
#14 – Can I be employed in a company as well be Research analyst?
A: SEBI, has in most cases, asked the applicant to choose between employment and RA registration. If you are working in a firm providing research services, SEBI will ask you to resign from the job. However, if you are working in a company not related to securities market, then at your request SEBI may allow you to continue with your job with NOC from the employer to do so.
STAGE TWO: APPLICATION PROCESS
#15 – When do we need to pay the application fees and the registration fees to SEBI?
A: The application fee is paid at the time of making an application to SEBI. Once SEBI approves the application, SEBI sends a communication to pay the registration fees. The application fee is not refundable.
#16 – Can my application be rejected by SEBI?
A: Yes, SEBI can reject your application for various reasons. Click here to know more.
If you application is rejected, the application fees paid by you will not be refunded by SEBI.
#17 – Can I withdraw my application?
A: Yes, you can withdraw the application before SEBI approves it.
#18 – Can I apply again if my application is withdrawn or rejected?
A: Yes, you can apply again once you make good the default for which the application was closed / withdrawn.
STAGE THREE : AFTER THE APPLICATION / RENEWAL
#19 – Is RA registration one time or is it to be renewed at regular intervals? Do I need to re-appear for the NISM exams too at regular intervals?
A: The registration as Research Analyst is permanent subject to payment of renewal fees every five years. To know more, click here.
Yes, you need to appear for NISM certification exam every 3 years and have a valid certificate at all times.
#20 – If I have a proprietorship firm which is involved in research services, will the certificate come under my name or proprietorship firm’s name?
A: The certificate is always in the name of the applicant. So, you need to mention the name of your proprietorship firm if you want to have it on the certificate. The certificate will be in the name of the partnership firm / company / LLP (in case of non-individual applicants).
#21 – Once I pay the application fees and SEBI rejects my application, will my fees be refundable?
A: No, application fee is not refundable.
#22 – Can I surrender my registration?
A: Yes, if you are no longer in the business of research analysis, you should surrender the registration. The application has to be made online.
#23 – Are there any restrictions on the personal trading of analysts?
A: Yes, there are restrictions on the personal trading of individual research analyst or the research analysts registered with partnership firm / company / LLP registered with SEBI.
The same is covered in Regulation 16 of the RA regulations.
#24 – My partnership is registered as a Research Analyst with SEBI. Do I need to appoint a compliance officer?
A: No. It is mandatory to appoint a compliance officer only in case of companies and LLPs.
#25 – I am already registered as an Investment Adviser with SEBI. I am also providing research services to my clients. Do I need to get registered as a Research Analyst as well?
A: Under Research Analyst regulations, there is an exemption mentioned under Regulation 3.
Our interpretation is – if you are registered as an Investment Adviser and planning to provide research reports, you need not get registered with SEBI again. However, you need to comply with Chapter III of the Research Analyst regulations as well.
We suggest to get in touch with SEBI for further confirmation.
#26 – If I have registered as an Individual Research Analyst with SEBI and now want to incorporate a private company providing the same services, do I need to apply to SEBI again?
A: Yes, you need to get your company registered with SEBI and hence need to follow the application process for registration of your company. In the process, SEBI may ask you to surrender your individual RA license.
#27 – I am registered as a Research analyst and write research reports. Are there any disclosures to be given in the report?
A: Yes, you need to give certain disclosure in the research reports. To know more, click here.
#28 – What are the compliance requirements after I get registered as a Research Analyst?
A: The mandatory compliance requirement as per RA regulations is to get an annual compliance audit done from a Company Secretary (CS) or a Chartered Accountant (CA) in practice. To know more, click here.
#29 – Do I have to make any submissions to SEBI once I get registered?
A: Currently, there are no submissions to be made to SEBI. Even the compliance audit report need not be submitted to SEBI.
#30 – Can I provide research on derivatives or only on stocks?
A: You can provide research on securities as defined in clause (h) of section 2 of the Securities Contracts (Regulation) Act, 1956. Securities include stocks, mutual funds, bonds, debentures, derivatives, government securities.
Disclaimer : The answers mentioned above are my views and are based on my experience. They are only guiding points. Please take advice from SEBI for your specific case.
For any queries or on enquiries on application services or compliance services you can send an email to kruti@cskruti.com
Hello mam, can sebi registered RA can conduct online classes on technical analysis?
Hi Pratik, in my view, SEBI is restricting the said activity for RA. However, I suggest confirming the same with SEBI’s MIRSD (department) at Mumbai office.
Ok mam. Thanks for reply.
SEBI is not allowing RA to take classes.
My wife is CA and she has also knowledge of market. And she is not going to apply for RA licence. Can she take online classes on technical analysis without registration with proper disclosure and without any comments on guaranteed returns?
Hi Pratik, in my view, if your wife is going to be involved only in providing education and training without giving out any analysis or views or recommendation on any of the stocks or securities, then she can do so with any SEBI registration. For further clarification /confirmation, I request you to get in touch with SEBI officers.
Does in a RA (LLP in nature) the designated partner / Research analyst can be appointed itself as the Compliance officer ??? Also can the entity get partnered with any stock broker and earn commissions on client referrals??? pls answer if possible.
In our view, the RA should not be the compliance officer. For your second query, I suggest getting in touch with SEBI’s MIRSD department.
Great information! I have a question which is if a company has a IA registration then what will be the procedure for RA registration for that company? If you could guide me on this it would be great.
The application process for RA registration is online. With proper segregation of services, you can apply for RA registration. If you have any specific questions, you can email to kruti@cskruti.com.
hello mam
I am a graduate(B,tech) and working in public sector bank for 9 years. Will this experience makes me eligible for SEBI RA? as the condition on sebi websites says: a graduate in any discipline with an experience of at least five years in activities relating to financial products or markets or securities or fund or asset or portfolio management.
Please guide
Thanks
Hi Piyush, if you have atleast 5 years of exeprience in dealing with the financial products or stocks, then your experince can be considered by SEBI.
Madam can you be little bit more precise?
Banking experience will count or not ?
If you were involved in researching in financial products and explaining it to your customers, then in my view, SEBI will consider your exprience. For further clarification, suggest to get in touch with MIRSD department of SEBI.
Hi
Iam an Active ARN Holder
Interested to complete RA & RA to be registered as PVt firm. Will SEBI Guidelines allow ARN holders to register as RA Pvt firm. Pls clarify whether it is conflict of interest or not.
Hi, you can register the company as RA. The company can have ARN.
However, if you are the represenatative of the company to provide RA services, then you will have to surrender your ARN.
Hi, Are we not allowed to put our name on a research paper if we do not have a post graduation degree
Hi, in my view, you cannot be appointed as a Research Analyst if you do not fulfill the qualification and certification requirements. If you are a graduate with minimum 5 years of experience in research / advisory / fund management then you fulfill the qualification requirements.
Mam, I have worked in Bank Back Office, Bank Retail Sales handling Casa and Demat&Trading Account, and as a Relationship manager in Stock Broking companies like Motilal Oswal and anand rathi in Sales department. Does all this work experience will be counted in Research Analyst experience criteria.
Hi Sandeep, as per RA regulations – you need atleast 5 years of experience in activities relating to financial products or markets or securities or fund or asset or portfolio management. If you have exeprience in dealing with the financial products or stocks, then your experince can be considered.
Thanks Mam
Are they now accepting masters degree from Foreign Universities?
In my experience, SEBI is still not accepting degrees from foreign universities. However, best is to confirm with SEBI’s office near you.
Hello Mam,
KYC of clients is compulsory for RA?
Hi, although the RA regulations do not specify about KYC of the clients, in my view, the Prevention of Money Laundering Act (PMLA) is application to RAs and KYC is a requirement under the PMLA. Hence it is suggested to do KYC of clients.
Just need to understand this as the CKYC portal under the institution type do not have research analyst as a option to select, so wondering without being able to register with ckyc how one will be able to perform the same. Also on calling ckyc helpline they asked to check the same with the regulator.
Hi, CKYC registry is just a registry for KYC documents of investors which are uploaded by SEBI or RBI or IRDA or PFRDA regulated intermediaries. CKYC Registry does not facilitate conducting KYC of clients. KYC process has to be carried on by the intermediaries themselves. Hope this solves your concern.
As RA can i offer small case services
I would request you to refer to this – https://cskruti.com/can-a-research-analyst-provide-model-portfolio-services/
Hope this helps.
Hey. I am employed as a fundamental analyst with a full broker service firm and completed my RA certificate from NISM. I am asked to get a DSC done but I don’t have a PG. will I still be allowed to sign reports?
Hi Anubhav, is your boroker firm registered with SEBI as a RA? if yes, then they have to follow RA compliance. If you have minimum 5 years of experience in activities related to securities or financial products, then you fulfill the qualification requirements of being a research analyst along with NISM certification and can sign the reports.
Hi Kruti,
I am trying to upload a RA application, but at the last stage it’s gets logged out. Do you know what can be done for this
Hi Rajni, it could be a technical error. I suggest you get in touch with portal help team – portalhelp@sebi.gov.in
Hope this helps.
Hello Mam, Always great information shared by you.
I have one question – That I am a NSE, NCFM AND NISM CERTIFIED TRADER AND ALSO PROVIDING LEARNING ON MARKET LIKE TECHNICAL ANALYSIS AND OPTIONS IN MY APPLICATION
ALSO ADDING STUDENTS IN A GROUP FOR LIVE TRADE IDEAS, HOWEVER ALL INFORMATIONS ONLY DELIVERED ABOUT KNOWLEDGE.
NOW MY QUERY IS WHENEVER I WILL APPLY FOR SEBI RA, CAN SEBI CHECK WHETHER AM PROVIDING LEARNING AND IS ITS WRONG.
Hi Sudhansu, I am not sure of SEBI’s internal process.
I m working as market analyst in the firm in which my role is providing trainning / conduct seminars / also i have cleared NISM MFD exam now planning for reaserach ananlyst exam and get registered for stks advise and all is it correct ?
if no then can i plan to take MFD ARN number on other name ?
plz guide
Hi, if you want to be a research analyst, SEBI may not allow you to continue with your employment as well as to be an MFD at the same time.
Hello Mam,
I have applied for RA certification. SEBI has now asked me to provide certificate under Shop and Establishment Act. Is this normal? I plan to provide RA services online operating out of my self-owned residence and have mentioned this in my application.
Thanks
Sunaina
Hi Sunaina, Shops and Est. Certificate is required if you are applying as a proprietorship firm. If not, then it is not mandatory to submit the said certificate. You can explain the officer accordingly. All the best!
Hello Kruti, Can a SEBI individual RA incorporate an OPC.
Hi Prajwal, yes an individual can incorporate an OPC (assuming to get registered with SEBI as non-individual RA). However, the individual has to surrender his license if he is going to be the representative.
Thank you mam.
Hello Kruti, can a SEBI registered Research Analyst work for IT company as a engineer at the same time running a financial advisory company on his own.
Hi Prajwal, in my view SEBI will not allow. If the SEBI officer processes the application, he / she may need NOC from the employer.
Thank you, Kruti mam.
Hi Kruti, Can a SEBI Individual RA incorporate a OPC, or should he convert Individual RA to non – Individual RA.
My question is will OPC comes under non – Individual RA?
Hi Prajwal, yes OPC is considered as non-individual / corporate RA.
Hi ma’m. I have done b.tech and have been working in a bank for last 7 years..can i apply for r.a. registration??
Hi Rohit. In my view you cannot as you do not fulfill the qualification requirements, assuming that your work in a bank did not involve any research activity.
Hello kruti Mam ,
I appreciate your guidance i come across on your website its truly helpful .
I just got registration as Research Analyst , as an individual. Mam, I have prepared subscription form with disclaimer , considers its sufficient as per regulation, But I wish to.know your opinion does it requires any other documentations that need to take care for audit purpose in future is any KYC registration is mandatory like I.A. for R.A.? as I.A. Includes Brokerage firms opens accounts and keeps funds for clients need to do KYC like Banks.
If possible please send me what need to keep as docs for audit purpose.
Thanks in advance.
DHARMESH BHATT
Hi Dharmesh, I would request you to go through my blog, https://cskruti.com/5-things-to-do-after-getting-sebi-research-analyst-license/
In case you have further questions, you can write to me at kruti@cskruti.com
Mam, i have done m.com in recognized University,and also cleared my NISM research analyst certification, unfortunately i don’t have 5 yrs experience in financial sectors ,bcz currently I am 22 yr old , can i know is am eligible for SEBI research analyst registration.
Hi Sanjay, M.Com plus NISM RA certification will help you fulfill the current qualification and certification requirements for RA registration.
I am a SEBI registered RIA ( individual). My qualifications are Bcom, LLB and NISM XA , XB, registered since 2016 and i do have about 150 clients. i was exempted from the PG with grandfathering clause in individual capacity. Now i am planning to get register as corporate Research Analyst , i have cleared Nism exam for this. Do i need to surrender my indiviual IA licence if i am applying as Research analyst in corporate name ?
Yes, if you are going to be the research analyst representative of your company.
Hi, how can one transfer his individual RA license to a Pvt Ltd company?? Is there any provision for that or does one have to apply for a new one from the company. If so, then what happens to the ndividual license.
TIA
Hi Aman, there is not provision to transfer the license. You have to make a fresh application as a private limited. SEBI will ask you to surrender your individual license if the private limited company application is getting approved.
Hi Mam,
I have done my MBA with HR and Marketing, can I apply for RA, pls answer me.
Hi Nitesh, if the MBA is accredited by All Indian Council for Technical Education, National Assessment and Accreditation Council or National Board of Accreditation or any other council/board/body set up under an Act of Parliament in India for the purpose then you fulfill Regulation 7.1.ii of the RA regulations. However, best is to confirm with SEBI’s regional / local office near you.
Hi Kruti,
You mentioned that SEBI can make exceptions for certain international qualifications.
Does the FRM qualify?
Hi Ayesha, I would suggest you confirm it with SEBI’s regional office near you.
Mam, I have 2 queries first one is how much fees Research Analyst can charge and second one is does all directors required to fulfill Regulation 7 of RA Regulations or it is sufficient any one director fulfills it.
Hi Shashikant, currently, there is no cap on the fee charged by a RA. Atleast one director or employee need to fulfill the qualification and certification requirements of Reg. 7. Hope this helps.
Hi Kruti,
Please can you confirm that there is no further changes to the above position on the amount of fees that an RA (Research Analyst) can charge for his/her research reports/recommendations etc ? Are there any other specifics that the RA should be aware of ?
Hi Nilabh, yes currently there are no restrictions on the amount of fee an RA can charge for the research services.
Can a CA in practice apply for SEBi registered analyst? Can he do practice along with analyst services?
Hi Rahul, in my view SEBI will not process the application if you are a practicing CA. Also aren’t there any restrictions on doing other business activities if you are a practicing CA?
Hi mam,
If I merely share my portfolio on my website and do not give buy or sell recommendations. It will be upto the member of my website whether to copy my transaction. Then do I need to get registration as Research Analyst ?
Hi Mayank, asking them to login to your website and charging them for the same? If yes, then you will need RA registration in my view.
Thankyou so much for the information ma’am. I had a small doubt, can a research analyst perform functions which are not mentioned in the rules?
Hi Manav, can you pls give examples of other functions?
Hii
Suppose I am sub-broker of a broker
And still I want to register my self as reserach analyst so I can give recomandation to my client to buy or sell stock
Is It Possible?? Because as a subroker I can provide all dmat and trading related facilities to my client..
Hi, no, it is not possible.
Will a Post Graduate Diploma in Financial Management from IGNOU along with NISM-XV certificate fulfil the eligibility for SEBI registration ?
Assuming you are asking for RA registration, in my view you will fulfill the qualification and certification criteria.
Yes Ma’am, for Research Analyst registration. Thankyou.
Mam i am a professional graduate in finance with some experience as research analyst in company and nism RA certificate, nse Technical analysis, fundamental analysis and currency derivatives certificate and NCFM certified market professional level 1 . Do i qualify for RA registration.
Hi Atharva, can you pls let me know the exact name of the degree as well as the name of the university or institute. You can email at kruti@cskruti.com
Is it possible to be mutual fund distributor as well as Sebi Registered RA and provide both the respective services?
SEBI will, most likely, not allow to have both licenses at the same time.
mam i have mailed some query,please reply me.
Thanks a lot for your prompt reply. Yes, the course is UGC accredited. So in that case hopefully it will be covered in the second clause related to eligibility given in SEBI Research Analyst Regulations?
As I said, it is upto the SEBI officer to accept the same. Best is to get in touch with SEBI.
Hi, Can you please let me know whether LL.M. qualification (without any experience) will count for the purpose of being a research analyst?
Hi Obhiejit, is your course accredited by AICTE or UGC? If yes then depending on your place of business, some local SEBI offices accept such qualification. Best is to confirm with SEBI’s local / regional office near you.
Hi Kruti,
Can a Research Analyst be a MF distributor as well? or is there a restriction such as the case with investment advisors?
Hi Abhay, if the research analyst is providing recommendations on mutual funds, then it will not be allowed by SEBI.
Hello My name is vaibhav shah My qualification is B.com M.com (only passed class) I have 9 year experience in Technical analysis in stock market.. Now I want to share my experience by seminar and I want to start giving training on technical analysis so is it compulsory for SEBI registered and if yes which exam I want pass from NISM. also one more thing if I want generate call buy or sell on technical analysis base then is it compulsory for SEBI registered and for that which exam is compulsory .
Thanks
Waiting for reply
Hi Vaibhav. If you want to give training or conduct seminar on technical analysis, you need not get registered with SEBI; provided you do not give any recommendations to your clients in your training. If you want to give calls / recommendation, you need to get registered with SEBI as a research analyst. To fulfill the certification criteria, you need to give NISM Series XV exam for Research Analyst.
Thanks for the very informative post……But have a couple of queries….So if I am a graduate and have 10 plus years of experience in a corporate environment (IT related) and then 5 years experience as a full time trader, i still dont qualify??? if i want to put my experience as a trader to good use and advise others (friends or family or anyone who cares or run a blog) , then even with the NISM RA certification, I dont qualify for SEBI??
Hi Prashant,
As per SEBI requirements, one should have atleast 5 years working experience. To support the experience, one needs to provide a work experience certificate from the employer.
However, would suggest you get in touch with SEBI and check if they allow your case with some declaration, etc.
Hi Madam I hold an MSc in Physics with over 15 years experience in IT field. If I pass NISM certification courses, will I get qualified to register with SEBI as RA or RIA?
Hi Hari, there are different qualification requirements for RIA and RA.
Here are the requirements for RIAs – https://cskruti.com/demystifying-enhanced-qualification-requirements-for-investment-advisers/
You can check the requirements for RA here – https://cskruti.com/qualification-requirements-sebi-ia-and-ra/
Thank you so much for the reply madam.
I have a 2 year Post Graduate Degree accredited by AICTE. I read both your article.
Based on the article you wrote and SEBI circulars, I seem eligible for RA with any post graduate degree
Please correct me if I am wrong.
Yes, you fulfill the requirements of Regulation 7.1.ii of RA regulations.