A Registration Category Built for Exactly Your Situation
If you're a Chartered Accountant, Company Secretary, insurance agent, lawyer, doctor, architect, or educator whose primary practice occasionally touches on security-specific recommendations, SEBI has a specific registration category for you: the part-time Investment Adviser. Understanding exactly who qualifies, and what obligations attach, is essential before either registering unnecessarily or — more commonly — failing to register when you should.
Who Is Eligible for Part-Time IA Registration
SEBI's framework specifically contemplates part-time registration for individuals/partnership firms also engaged in another business or employment unrelated to securities, which doesn't involve handling client money or advising on non-securities investment products. Named examples include ICAI/ICSI/ICMAI members providing statutory professional services, IRDAI-licensed insurance agents, other professionals (architects, lawyers, doctors), and educators.
The Same Qualification Bar as Full-Time IAs — No Shortcut
A common misconception: part-time status doesn't lower the qualification or NISM certification bar. Part-time IAs must meet exactly the same requirements under Regulation 7 as full-time advisers — the "part-time" designation describes the applicant's overall professional engagement, not a lighter compliance standard.
The Mandatory Arms-Length Undertaking
Part-time IAs must provide a specific undertaking maintaining an arms-length relationship between their IA activity and their other business — with clear segregation at every stage of client engagement. This isn't a formality; it needs to be genuinely reflected in how client interactions, documentation, and fee structures are organised.
The Disclaimer Requirement on Non-IA Communications
Every invoice or communication relating to your non-IA service must carry a prominent disclaimer (minimum 10-font size) stating that activity is outside SEBI's purview and no SEBI complaint recourse exists for it. This is specifically designed to prevent clients from confusing your primary professional service with your separately regulated IA activity.
Managing Conflicts of Interest Between the Two Roles
Part-time IAs must disclose the nature of their other activities to clients and actively manage conflicts of interest between the two roles — for instance, where a recommendation in your primary capacity could be perceived as influenced by, or influencing, your IA-capacity advice.
What Triggers the Need for Part-Time Registration in the First Place
This is the question we get asked most often, and it deserves its own detailed treatment — see our companion article on exactly when a Chartered Accountant crosses from permissible incidental commentary into territory requiring part-time IA registration, using the Master Circular's own worked illustrations.
Getting Your Part-Time Registration Structured Correctly
We support professionals — particularly CAs and CS practitioners — through the complete part-time IA registration process: eligibility assessment, application, arms-length policy documentation, and building the disclaimer and segregation practices into your existing client-facing materials.
Think your practice might need part-time IA registration, or want a second opinion on whether you're already required to hold it? Get in touch with Anuj Desai & Associates for a clear-eyed assessment.
This article is for general informational purposes and does not constitute regulatory advice specific to any professional's circumstances.