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SEBI / Portfolio Managers

Part-Time PMS-Adjacent Advisory for CAs — Where the Line Sits With IA/RA Registration

A comprehensive guide to where the line sits between part-time PMS-adjacent advisory for CAs and IA/RA registration requirements.

25 Jul 20263 min read

Chartered Accountants often provide advisory services that may be adjacent to portfolio management. This article explains where the line sits with IA/RA registration requirements.

The Regulatory Framework

Part-Time IA/RA Registration

SEBI has introduced guidelines for part-time Research Analysts (RAs) and part-time Investment Advisors (IAs). Working professionals can now start advisory work legally, and CA & CS professionals can earn additional income.

Eligibility for Part-Time Registration

The applicant shall be considered eligible for registration as part-time IA/RA, if they are engaged in activity/business/employment permitted by any financial sector regulator or an activity under the purview of statutory self-regulatory organisations such as Institute of Chartered Accountants of India (ICAI).

Where the Line Sits

Investment Adviser (IA) Registration Required

You need IA registration if you are:

  • Providing investment advice for consideration
  • Recommending specific securities
  • Offering portfolio advice
  • Providing financial planning services

Research Analyst (RA) Registration Required

You need RA registration if you are:

  • Issuing research reports
  • Making buy/sell/hold recommendations
  • Providing price targets or stop loss targets
  • Recommending model portfolios

Portfolio Manager (PMS) Registration Required

You need PMS registration if you are:

  • Managing someone's money or portfolio
  • Exercising discretion in investment decisions
  • Making investment decisions on behalf of clients

Where CA Advisory Crosses the Line

What CAs Can Do Without Registration

  1. Tax Advisory: Provide tax planning and advisory services
  2. Accounting Services: Provide portfolio accounting services
  3. General Financial Advice: Provide general financial advice (not specific securities)
  4. Estate Planning: Provide estate and succession planning advice

What CAs Cannot Do Without Registration

  1. Specific Securities Advice: Recommend specific securities without IA/RA registration
  2. Portfolio Management: Manage client portfolios without PMS registration
  3. Discretionary Decisions: Make discretionary investment decisions
  4. Research Reports: Issue research reports without RA registration

Part-Time IA/RA Registration for CAs

Benefits

  1. Legal Compliance: Work legally within regulatory framework
  2. Additional Income: Earn additional income from advisory services
  3. Client Cap: Part-time RAs have a cap of 75 clients
  4. Flexibility: Can combine with existing practice

Requirements

  1. Same Qualifications: Same requirements as full-time advisors
  2. Client Cap: Cap of 75 clients for part-time RAs
  3. NOC: Working professionals must obtain employer NOC
  4. Dual Registration: Can register as both IA and RA

Key Distinctions

Advice vs Management

ActivityRegistration Required
Providing advice on securitiesIA/RA registration
Managing client portfolioPMS registration
Making discretionary decisionsPMS registration
Issuing research reportsRA registration
Tax advisoryNo registration required

What CAs Can and Cannot Do

Can Do:

  • Tax planning
  • Accounting services
  • Estate planning
  • General financial advice (not specific securities)

Cannot Do:

  • Manage client portfolios
  • Make discretionary investment decisions
  • Issue research reports
  • Recommend specific securities (without IA/RA registration)

Expert Legal Guidance

Anuj Desai & Associates provides expert legal advisory services on IA/RA registration for CAs. Our securities law experts help professionals understand where the line sits, obtain appropriate registration, and ensure regulatory compliance. Contact us for guidance on IA/RA registration and other regulatory matters.


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