Registration Is a Structuring Decision Long Before It's a Filing
Every Investment Adviser registration application we've supported has one thing in common: the applications that sail through SEBI/IAASB review are the ones where structuring decisions — individual vs. non-individual, fee model, compliance officer arrangement — were settled before the application was drafted, not worked out reactively in response to a query from the regulator.
Step 1: Decide Individual vs Non-Individual Registration
This is the first and most consequential decision. An individual registration is simpler to set up but caps out at 300 clients or ₹3 crore in annual fees — cross that threshold and you're required to transition to non-individual registration within a defined window. If you're planning to scale a practice with a team, a non-individual (LLP or company) structure from day one avoids a forced mid-life restructuring later. We cover this decision in detail in our companion article on individual vs non-individual IA registration.
Step 2: Confirm Qualification & NISM Certification
SEBI requires specific educational qualifications and NISM certification (typically NISM-Series-X-A and X-B, or the relevant combination for your registration type) for the applicant — and for a non-individual applicant, for the designated Principal Officer specifically. This needs to be locked in before the application is drafted, not treated as a parallel-track item, since an incomplete certification record is one of the most common reasons applications stall at the scrutiny stage.
Step 3: Arrange the Deposit
Every IA must maintain a deposit — ranging from ₹1 lakh up to ₹10 lakh depending on client count slabs — held as units of a liquid/overnight mutual fund or a bank deposit, lien-marked in favour of IAASB. This needs to be arranged and evidenced as part of the application, not treated as a post-registration formality.
Step 4: Prepare the Application Documentation
This typically includes:
- Entity/individual details and ownership structure
- Qualification and certification evidence for the applicant and (where applicable) Principal Officer
- Net worth and financial soundness documentation
- The proposed Compliance Officer's details and certification
- Fit and proper person declarations for all relevant individuals
Step 5: File With IAASB and Respond to Queries
Applications are processed through BSE, acting as the Investment Adviser Administration and Supervisory Body (IAASB). It's common — not a red flag — for IAASB to raise clarificatory queries on a first submission; the applications that get delayed are typically the ones where responses to these queries are incomplete or inconsistent with what was originally filed, which is why having a single, coherent structuring narrative from the outset matters so much.
Step 6: Set Up Post-Registration Compliance Infrastructure
Registration is the beginning of the compliance obligation, not the end of the project. Before actively taking on clients, you need: the client agreement and MITC template ready, a documented risk-profiling process, your fee structure finalised and disclosed correctly, and your record-keeping system in place from day one — since SEBI expects records from the first client interaction, not from whenever you get around to setting up a system.
Where Applications Most Commonly Get Stuck
In our experience supporting registration applications, the recurring friction points are: an unclear or inconsistent Principal Officer designation for non-individual applicants, deposit documentation that doesn't match the client-count slab actually being declared, and qualification/certification gaps discovered only after the application is already filed. Every one of these is avoidable with proper pre-filing review.
How We Support IA Registration
We handle the full registration process for individuals, partnership firms, and companies seeking IA registration — structuring the entity, coordinating documentation, and managing IAASB correspondence through to grant of certificate — so you're not learning the process by trial and error on your own application.
Looking to register as an Investment Adviser, or unsure whether your current structure is the right one? Get in touch with Anuj Desai & Associates for end-to-end registration support.
This article is for general informational purposes and does not constitute regulatory advice specific to any applicant's circumstances.