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Fee Chargeable to Clients – The ₹1,51,000 Per Annum Per Family Cap

A detailed analysis of the ₹1,51,000 per annum per family fee cap for Research Analysts, including applicability, exclusions, and compliance requirements.

25 Jul 20264 min read

SEBI has standardized the fee structure for Research Analysts (RAs) by introducing a maximum fee cap of ₹1,51,000 per annum per family for individual and HUF clients. This article provides a comprehensive technical analysis of the fee cap, its applicability, and compliance requirements.

Regulatory Basis

The fee cap is specified in the circular dated January 08, 2025 (SEBI/HO/MIRSD/MIRSD-PoD-1/P/CIR/2025/004) on "Guidelines for Research Analysts". The circular states:

"RAs shall charge a maximum of ₹1,51,000 per annum per family in case of their clients who are individuals and Hindu Undivided Family(HUF)."

Key Features of the Fee Cap

1. Applicability

Client TypeFee Cap Applicable?
Individual ClientsYes
HUF ClientsYes
Non-Individual ClientsNo
Accredited InvestorsNo

2. "Per Family" Definition

The fee cap applies "per family," meaning the total fees charged to all members of a family cannot exceed ₹1,51,000 per annum.

3. Exclusion of Statutory Charges

The fee limit does not include statutory charges. This means GST and other statutory charges can be charged in addition to the ₹1,51,000 cap.

4. Applicability to Research Services Only

The ceiling applies solely to research services. Other services (e.g., non-RA services) are not subject to the cap.

Fee Cap Revision Mechanism

The fee limit shall be revised and announced by RAASB once in three years based on the Cost Inflation Index (CII) after due consultation with SEBI.

Comparison: RA vs IA Fee Cap

ParameterRAIA
Fee Cap₹1,51,000 per annum per family₹1,51,000 per annum per family
RevisionEvery three years based on CIIEvery three years based on CII
ApplicabilityIndividual and HUF clients onlyIndividual and HUF clients only

Disclosure Requirements

RAs must disclose the fee cap in:

  1. Terms and Conditions: The fee cap must be disclosed in the terms and conditions of research services.
  2. MITC: The Most Important Terms and Conditions (MITC) must include the fee cap.
  3. Client Communication: The fee cap must be communicated to clients at the time of onboarding.

Common Compliance Gaps

1. Charging Above the Cap

Some RAs charge fees exceeding ₹1,51,000 per family per annum, violating the cap.

Solution: Ensure total fees charged to a family do not exceed the cap.

2. Misclassifying Clients

Some RAs incorrectly classify non-individual clients as individuals to avoid the cap.

Solution: Properly classify clients based on their legal status.

3. Not Disclosing the Cap

Some RAs fail to disclose the fee cap in terms and conditions and MITC.

Solution: Include the fee cap in all client communications.

4. Including Statutory Charges in the Cap

Some RAs include GST and other statutory charges within the ₹1,51,000 cap.

Solution: Charge statutory charges in addition to the cap.

Conclusion and How Anuj Desai & Associates Can Help

The fee cap is a critical compliance requirement for RAs. Violation of the cap can result in regulatory action.

Anuj Desai & Associates offers specialized services to help RAs comply with the fee cap:

  • Review of fee structures for compliance.
  • Guidance on fee cap disclosure.
  • Assistance with MITC preparation.
  • Compliance audit and advisory.

Contact us today to ensure your fee structure complies with the ₹1,51,000 cap. Our team will review your fee arrangements and provide a tailored compliance roadmap.


Disclaimer: This article is for informational purposes only and does not constitute legal advice. Readers are advised to consult qualified professionals for legal and compliance matters. Anuj Desai & Associates is a SEBI compliance consulting firm based in India.


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