Key change: SEBI has issued Circular No. HO/38/11/(9)2026-MIRSD-POD/I/24272/2026 (23 October 2026): from 8 November 2026, research analysts and research entities are no longer required to maintain call recordings of interactions with clients who are institutional investors — though every other interaction record stays compulsory for all clients.
What happened
On 23 October 2026, the Securities and Exchange Board of India issued a circular titled "Review of regulatory requirement for maintenance of call records of institutional clients by Research Analysts or Research Entities" (No. HO/38/11/(9)2026-MIRSD-POD/I/24272/2026), addressed to all registered Research Analysts and the Research Analysts Administration and Supervisory Body (RAASB). It is signed by Divya Hamirbasia, Deputy General Manager, and issued under Section 11(1) of the SEBI Act, 1992 read with Regulation 25(1)(vii) of the SEBI (Research Analysts) Regulations, 2014.
The circular's operative line, inserted as a proviso in the Master Circular's record-keeping paragraph and the related FAQ: "Provided that the requirement to maintain call recordings of interactions with clients which are institutional investors shall not be mandatory." The provisions take effect from 8 November 2026.
This is the operational endpoint of a process SEBI ran through 2026: a consultation paper on 18 May 2026 proposing the relaxation, Board approval of the proposal, and a notified amendment to Regulation 25(1)(vii) of the RA Regulations — which the circular now implements through the Master Circular for Research Analysts.
Why SEBI did this: The circular says the move follows representations from market participants and is part of SEBI's ease-of-doing-business drive. The logic, laid out in the consultation: institutional investors are sophisticated entities with the expertise and resources to evaluate research inputs independently, and research analysts provide research and recommendations — not client-specific investment advice, asset management or transaction execution — so a risk-proportionate, lighter record-keeping standard is appropriate for them.
What exactly changes — and what does not
The fine print RAs should not miss
- All clients means all clients. Interaction records must be kept for every client including prospective clients (prior to onboarding) wherever a conversation about the RA's services took place — in the form of a physical record signed by the client, call recordings, email from the registered email ID, SMS records, or any other legally verifiable record.
- Fee-paying AND non-fee-paying. The circular's FAQ clarifies the record-keeping obligation covers both — non-fee-paying clients being those receiving research as a value-added service alongside other paid services (from the research entity or a family/group entity).
- Email needs no call recording. "For abundant clarity": where the interaction happens through a channel like email that already leaves a digital footprint, no call recording is required at all.
- From first hello to final report. Records must begin with the first interaction and continue till completion of research services to the client.
- The purpose is grievance-readiness. SEBI states the records exist to document interactions "to cater to potential client grievances related to research services" — RAs "shall ensure compliance" for all clients.
Who is affected and what to do next
Registered Research Analysts and research entities dealing with institutional investors get the compliance relief — no more mandatory call-recording infrastructure for those relationships. RAASB has a direct to-do list from the circular: amend its bye-laws and rules to implement the circular, and bring the provisions to the notice of all registered RAs plus disseminate them on its website.
- Segment your record-keeping by client type before 8 November 2026 — institutional-investor interactions move to the lighter standard; retail interactions keep full call-recording discipline.
- Do not dismantle recording for retail. The relaxation is confined to institutional-investor clients; retail call-recording obligations continue unchanged.
- Document the "digital footprint" channels. Email-from-registered-ID and similar trails already satisfy the framework — make sure yours are captured as the legally verifiable record.
- Check the 5-year retention clock. Records run five years from the interaction, longer if a dispute is raised or SEBI asks for preservation.
Related reading: we covered the May 2026 consultation paper that proposed this relaxation — this circular is its final implementation.
FAQs
Q: From when do research analysts stop recording calls with institutional clients?
8 November 2026 — SEBI Circular No. HO/38/11/(9)2026-MIRSD-POD/I/24272/2026 (dated 23 October 2026) states its provisions come into effect from that date. From then, maintaining call recordings of interactions with institutional-investor clients is not mandatory.
Q: Does this remove all record-keeping for institutional clients?
No. Only the call-recording requirement is relaxed. RAs must still maintain interaction records — signed physical records, registered-email, SMS, or other legally verifiable records — for all clients including prospective clients, institutional or otherwise.
Q: What about retail clients?
Unchanged — RAs must continue maintaining all records including call recordings for retail client interactions.
Q: How long must records be kept?
Five years as the base rule; till resolution of the dispute where one is raised; and till further intimation from SEBI where SEBI wants specific records preserved.
Q: What must RAASB do?
Make necessary amendments to its bye-laws and rules to implement the circular, and bring the provisions to the notice of all registered research analysts while disseminating them on its website.
Sources
- SEBI Circular No. HO/38/11/(9)2026-MIRSD-POD/I/24272/2026 (23 Oct 2026) — "Review of regulatory requirement for maintenance of call records of institutional clients by Research Analysts or Research Entities" (official circular, sebi.gov.in; effective 8 Nov 2026)
- SEBI (Research Analysts) Regulations, 2014 — Regulation 25(1)(vii) (amended basis for the relaxation)
- SEBI consultation paper (18 May 2026) proposing the relaxation — our coverage: corplawupdates.in
Verified against the official SEBI circular dated 23 October 2026 (read in full from sebi.gov.in). Last verified: 23 October 2026.
