Research analysts no longer need to record calls with institutional clients from 8 November 2026

Authority SEBIDate 23 Oct 2026Type CircularSubject Capital Markets

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

ItemBeforeNow
Call recordings of interactions with institutional investor clientsMandatoryNot mandatory
Records with other clients, including prospective clientsPhysical record, call recording, email, SMS or other verifiable recordNo change
How long records are keptFive 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

  1. From 8 November 2026 you may stop recording calls with clients that are institutional investors; keep doing it for all other clients.
  2. Keep some other verifiable record of institutional interactions (email, signed note or SMS), as the regulation still requires records of interactions.
  3. Update the RA compliance manual and the record-retention policy.
  4. 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.

SEBIResearch AnalystRecord keepingEase of doing business
Read the official PDF: SEBI circular

Written 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.