SEBI Redefines Entry Norms: Simplifying the Path for IAs and RAs

Regulation rarely moves backward. It evolves.

When SEBI introduced the framework for Investment Advisers (IAs) and Research Analysts (RAs), the objective was clear — formalise advisory services, introduce provisions to deal with conflict of interest, enhance investor protection, and institutionalise accountability.

Over time, however, the market matured.
Technology reduced operational risk.
New-age advisory models emerged.

The entry framework, while robust, required recalibration to reflect this evolution.

In November 2025, SEBI decided to ease the entry norms for IAs and RAs. The regulator signalled a balancing act — improve accessibility without diluting compliance discipline.

The high requirement hurdle changed to calibrated regulatory reform — balancing ease of entry with accountability. Suddenly, the conversation shifted.

For individual professionals, the question was no longer “Do I fulfill the requirements?” but rather “How do I position myself correctly under the SEBI framework?”

For fintech founders ready with the business model and tech platforms, the question was no longer “Is registration too difficult?” but rather “How do I structure this correctly from day one?”

In this blog, we break down what has changed — and what applicants must still get right.

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1. Relaxed educational qualification criteria

Now, a graduate in any field can also be eligible to apply for IA / RA. Professional qualification or post graduation is no longer a mandatory requirement. Also, experience requirements have been done away with. 

You can now become an IA / RA with any of the following:

• A graduate degree or equivalent education qualification in any discipline from an Indian or foreign university recognized by the government 
• CFA charter holder from the CFA Institute

The requirement of relevant NISM certifications still remains. 

You can also complete a Post-graduate program in Securities market or post graduate program in financial planning from NISM (in case of IAs) or any other program of NISM. The advantage is, you do not need to complete relevant NISM certifications separately at the time of application. 

If you were previously held back by restrictive qualification requirements, this is your chance to step in with more flexibility.

2. Renewal of NISM certifications

If you have been planning to register as IA / RA, you must have completed the NISM certifications. A reminder to check your NISM validity!

The good news is, if your NISM certifications are due for renewal, you need not appear for the examinations again. Rather, NISM has introduced renewal certifications for :

• Investment Advisers – NISM X-C certification

• Research Analyst – NISM XV-B certification

3. Removal of capital adequacy / net worth requirements

A big relief to individuals as well as non-individuals – SEBI has removed the net worth requirements. 

Now, the applicants no longer need to have a specific net worth and submit the net worth certificate from the CA. 

Net worth requirement has been replaced by deposit requirement. Post approval of application, the deposit has to be created in the form of fixed deposit or liquid mutual funds based on the number of clients proposed to be serviced.

Since the capital adequacy requirements have been removed, you are no longer required to submit copy of income tax returns as well. 

4. Removal of credit report / score card from CIBIL

SEBI is no longer asking the investment adviser applicants to submit their CIBIL score. This criterion has been done away with and just fit and proper status of the applicant declaration would suffice. 

5. Transition from individual to non-individual RIA

If you are deciding whether you should go for an individual or non-individual RIA, you should consider this.

You can continue to be an individual RIA only till the time you have 300 clients or annual fees does not exceed Rs. 3 crores, whichever is earlier.

The moment you cross these thresholds or are going to cross the thresholds, you have to apply for conversion to a non-individual investment adviser. 

6. Relaxations in infrastructure requirements

SEBI realised that advisory and research services rely on expertise and not physical infrastructure. Infrastructure details are no longer required — a simple declaration is sufficient.

Also, applicants only need to declare the addresses and not submit address proofs. 

The aim is to reduce documentation and ensure faster processing.

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While entry barriers for Investment Advisers and Research Analysts have been rationalised, the core obligations remain firmly intact: fiduciary responsibility, disclosure standards, conflict management, audit compliance, and reporting discipline.

In our experience, most applicants do not struggle with eligibility. They struggle with interpretation, documentation precision and anticipating supervisory scrutiny post-registration.

Are you sure if you want to go for RIA or RA license?

A well-prepared application does more than secure registration — it lays the foundation for a defensible, scalable advisory practice.

If you are considering IA or RA registration under the revised norms, the right approach is not just to file — but to file correctly, comprehensively, and with long-term regulatory sustainability in mind.

We work closely with applicants to ensure their registration is not just approved — but is future-ready. 

Still have queries or need assistance with the application? You can write to kruti@cskruti.com.