Research analysts no longer need to record calls with institutional clients from 8 November 2026
TaxByKK · Compliance News · taxbykk.com23 Oct 2026
In short
SEBI has relaxed the record-keeping rule for research analysts (RAs) and research entities: keeping call recordings of conversations with institutional investor clients is no longer mandatory. The change follows an amendment to Regulation 25(1)(vii) of the SEBI (Research Analysts) Regulations, 2014 and takes effect on 8 November 2026.
- Authority
- SEBI, MIRSD
- Circular
- HO/38/11/(9)2026-MIRSD-POD/I/24272/2026 dated 23 October 2026
- Type
- Circular
- Effective from
- 8 November 2026
- Law
- SEBI Act, 1992, section 11(1); SEBI (Research Analysts) Regulations, 2014, regulation 25(1)(vii)
- Amends
- Master Circular for Research Analysts (6 February 2026), Chapter I para 1.13 and Chapter VII Annexure I para 33
What changed
| Item | Before | Now |
|---|---|---|
| Call recordings of interactions with institutional investor clients | Mandatory | Not mandatory |
| Records with other clients, including prospective clients | Physical record, call recording, email, SMS or other verifiable record | No change |
| How long records are kept | Five years (longer if a dispute is raised) | No change |
SEBI made the change after representations from market participants, as part of its ease-of-doing-business work. The Research Analysts Administration and Supervisory Body (RAASB) will amend its bye-laws to match.
Who it applies to
- SEBI-registered research analysts and research entities
- Brokers and other entities that house research desks
- Compliance officers and CS professionals advising RAs
What to do
- From 8 November 2026 you may stop recording calls with clients that are institutional investors; keep doing it for all other clients.
- Keep some other verifiable record of institutional interactions (email, signed note or SMS), as the regulation still requires records of interactions.
- Update the RA compliance manual and the record-retention policy.
- Keep all records for five years, or until a dispute is resolved.
Reference
SEBI circular HO/38/11/(9)2026-MIRSD-POD/I/24272/2026, 23 October 2026, Review of regulatory requirement for maintenance of call records of institutional clients by Research Analysts or Research Entities.
Read the official PDF: SEBI circularWritten by TaxByKK from the official notification. Check the official text before you act on it.
Frequently asked questions
Do research analysts still need to record calls with clients?
Yes, for all clients except institutional investors, for whom call recordings are no longer mandatory from 8 November 2026.
How long must a research analyst keep client records?
Five years, or until a dispute is resolved if one is raised, or longer if SEBI asks.
Which regulation was amended?
Regulation 25(1)(vii) of the SEBI (Research Analysts) Regulations, 2014.