SEBI issued the Master Circular for Research Analysts on February 6, 2026. This master circular consolidates all applicable circulars in the subject matter at one place, providing comprehensive guidance for RAs. This article provides a comprehensive technical analysis of the master circular.
Regulatory Basis
Master Circular: HO/38/12/11(1)2026-MIRSD-POD/I/4360/2026
SEBI issued the Master Circular for Research Analysts on February 6, 2026.
Purpose
The master circular consolidates all applicable circulars for RAs to provide a single reference document.
What the Master Circular Contains
Contents
The master circular covers the following areas:
I. GUIDELINES FOR RESEARCH ANALYSTS
- Guidelines for Research Analysts
- Procedural Guidelines for Proxy Advisors
II. ADMINISTRATION AND SUPERVISION OF RESEARCH ANALYSTS
- Framework for administration and supervision
- Recognition of BSE Limited as RAASB
III. INVESTOR COMPLAINTS
- Grievance Resolution
- Redressal through SCORES and ODR
- Investor Charter
IV. TECHNOLOGY RELATED
- SaaS advisory
V. MISCELLANEOUS
- Prior approval for change in control
- Advertisement code and usage of brand name
- CeFCoM
- Unauthenticated news
- Outsourcing guidelines
- Regulatory Sandbox
- Conflict of interest guidelines
- Data access and usage
- AML standards and CFT
- KYC Requirements
- Association with certain persons
- PaRRVA
- Cybersecurity and Cyber Resilience Framework
- Norms for sharing of real-time price data
- UPI IDs for payment collection
- Rights of Persons with Disabilities Act compliance
- FAQs
VI. REPORTING REQUIREMENTS
- Periodic reporting
- SaaS compliance undertaking
- Annual audit report submission
VII. ANNEXURES
- Model portfolio guidelines
- Minimum mandatory terms and conditions
- Detailed framework for RAASB
- Investor Charter
- Complaint Data format
- SaaS advisory
- Declaration cum undertaking for change in control
- Principles for outsourcing
- FAQs
- Periodic Reporting Format for PAs
VIII. APPENDIX
- List of Circulars/Notifications/Communications
Rescission of Circulars
What is Rescinded
All directions/instructions contained in the circulars listed in the appendix are rescinded to the extent they relate to RAs.
Savings
Notwithstanding such rescission:
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Anything done or any action taken under rescinded circulars shall be deemed to have been done under the master circular.
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Any application made to the Board under rescinded circulars and pending shall be deemed to have been made under the master circular.
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The previous operation of rescinded circulars, any right, privilege, obligation, or liability, any penalty incurred, or any investigation, legal proceeding, or remedy shall not be affected.
Key Updates and Changes
New Topics Added
The master circular includes topics not covered in earlier circulars:
- Digital accessibility
- PaRRVA
- FAQs
- Outsourcing principles
Reference Documents
The master circular references other SEBI master circulars and guidelines:
- AML master circular
- KYC master circular
- CSCRF circulars
Practical Implications
For RAs
RAs should use the master circular as the primary reference document.
For New RAs
New RAs should refer to the master circular for comprehensive guidance.
For Compliance
The master circular provides a consolidated view of all compliance requirements.
Common Compliance Gaps
1. Not Using the Master Circular
Some RAs do not use the master circular as the primary reference.
Solution: Use the master circular for consolidated guidance.
2. Relying on Rescinded Circulars
Some RAs rely on rescinded circulars.
Solution: Refer to the master circular.
3. Missing Updated Requirements
Some RAs miss updated requirements.
Solution: Review the master circular for all requirements.
Conclusion and How Anuj Desai & Associates Can Help
The master circular provides consolidated guidance for RAs.
Anuj Desai & Associates offers specialized services to help RAs navigate the master circular:
- Compliance review
- Regulatory guidance
- Compliance audit and advisory
Contact us today to ensure your compliance with the master circular. Our team will guide you through the process.
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.