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IA Deposit Requirements Explained — The Client-Count Slabs and How to Stay Compliant

How the SEBI Investment Adviser deposit requirement actually works — the client-count slabs, permitted deposit forms, and the annual revision deadline advisers often miss.

17 Jul 20263 min read

A Compliance Obligation That Changes as Your Practice Grows

Unlike a one-time registration fee, the IA deposit requirement is a continuing, client-count-linked obligation — meaning it needs active monitoring and periodic revision as your practice scales, not a single deposit made once at registration and forgotten about.

The Deposit Slabs

| No. of Clients (max. on any day, previous FY) | Deposit Required | Up to 150 | ₹1 lakh | 151 to 300 | ₹2 lakh | 301 to 1,000 | ₹5 lakh | 1,001 and above | ₹10 lakh

The deposit amount is determined by the maximum number of clients held on any single day during the previous financial year — not an average, and not the client count at any arbitrary point you choose to check.

What Form the Deposit Must Take

The deposit must be maintained as either units of a liquid or overnight mutual fund scheme, or a bank deposit with a scheduled bank — in both cases, lien-marked in favour of IAASB. A deposit held in any other form, or not properly lien-marked, doesn't satisfy the requirement even if the underlying funds are genuinely set aside.

The Annual Revision Deadline Advisers Often Miss

The deposit amount must be revised to reflect any change in client-count slab by April 30 of the subsequent financial year. This is a genuinely easy deadline to miss precisely because it falls outside the more prominent compliance-audit and reporting deadlines advisers tend to track more closely — worth building into your standing annual compliance calendar specifically, not left to be remembered informally.

What Happens If You Cross a Slab Mid-Year and Don't Revise

Growing past a client-count slab boundary mid-financial-year doesn't require an immediate deposit top-up — the revision obligation is tied to the April 30 deadline following the financial year in which the higher client count was reached. But this timing nuance is itself a common source of confusion, and getting the calculation wrong — either under-depositing or assuming a revision is due earlier than it actually is — creates its own compliance friction.

Why This Deserves Dedicated Tracking, Not Ad Hoc Attention

Because the deposit slab is directly tied to client count — a number that changes continuously as a practice grows — it's genuinely easy for this obligation to fall through the cracks between more attention-grabbing compliance deadlines like the annual audit or SCORES resolution timelines. A practice that tracks client count for business purposes should be cross-referencing that same data against deposit slab thresholds as a standing quarterly check, not an annual afterthought.

Managing Your Deposit Compliance as Part of Ongoing Advisory

We track deposit slab thresholds as part of our ongoing compliance support for Investment Advisers — flagging revision requirements well ahead of the April 30 deadline, and confirming the deposit is held in a properly lien-marked, compliant form.

Not sure if your current deposit matches your actual client count, or need this built into your standing compliance calendar? Speak with Anuj Desai & Associates.

This article is for general informational purposes and does not constitute regulatory advice specific to any adviser's circumstances.

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