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SEBI / Research Analysts

Part-Time RA – The Disclaimer Every CA/Professional Must Put on Non-RA Invoices (2026)

A detailed guide explaining the mandatory disclaimer requirements applicable to Part-Time Research Analysts when issuing invoices for their other professional services and how professionals should maintain regulatory segregation.

25 Jul 20267 min read

Introduction

The introduction of the Part-Time Research Analyst framework under SEBI (Research Analysts) Regulations, 2014 has allowed several professionals to provide securities research services while continuing their existing professional activities.

Professionals such as:

  • Chartered Accountants
  • Company Secretaries
  • Cost Accountants
  • Consultants
  • Other eligible professionals

may continue their existing practice while separately undertaking research activities after obtaining SEBI registration.

However, this flexibility comes with an important compliance responsibility:

The professional must clearly distinguish between their SEBI-regulated research activities and their other professional services.

One of the key requirements for Part-Time Research Analysts is the display of a prominent disclaimer while providing invoices or documents relating to their non-research professional activities.

This requirement ensures that clients do not mistakenly believe that:

  • Tax services,
  • Audit services,
  • Consulting services,
  • Accounting services,
  • Corporate advisory services,

are covered under SEBI Research Analyst regulations.


Why Is a Disclaimer Required for Part-Time Research Analysts?

A Part-Time Research Analyst may simultaneously operate in two different capacities:

Capacity 1 – SEBI Registered Research Analyst

In this role, the person provides:

  • Securities research
  • Research reports
  • Investment recommendations
  • Research-related services

These activities are regulated by SEBI.


Capacity 2 – Existing Professional Activity

The same person may also provide:

  • Chartered Accountancy services
  • Secretarial services
  • Tax consultancy
  • Business consulting
  • Other professional services

These activities are governed by their respective professional frameworks and are not Research Analyst services.


The disclaimer requirement exists to prevent confusion between these two roles.


What Disclaimer Must a Part-Time Research Analyst Provide?

A Part-Time Research Analyst must prominently provide a disclaimer while providing services or raising invoices related to activities outside the scope of SEBI Research Analyst services.

The disclaimer should clearly state that:

  • The activity/invoice relates to services outside the purview of SEBI.
  • No complaint relating to such services can be raised before SEBI under the Research Analyst framework.

The disclaimer should be:

  • Clear
  • Prominent
  • Easily noticeable
  • Presented in a manner that attracts investor attention

Minimum Font Size Requirement

The disclaimer provided by a Part-Time Research Analyst must be displayed prominently.

SEBI requires that such disclaimer should be displayed with:

Minimum font size of 10.

The purpose of this requirement is to ensure that the disclaimer is not hidden in small text or placed in an inconspicuous portion of the invoice.


Where Should the Disclaimer Be Displayed?

The disclaimer should be included on documents relating to non-Research Analyst services.

Examples may include:

  • Professional invoices
  • Service bills
  • Engagement letters
  • Other documents issued for non-RA activities

The objective is that the recipient understands the nature of the service being provided.


Example of Non-RA Activities Requiring Disclaimer

A Chartered Accountant registered as a Part-Time Research Analyst may issue invoices for:

  • Statutory audit services
  • Tax audit services
  • GST consultancy
  • Income-tax advisory
  • Accounting support
  • Corporate restructuring consultancy

Such invoices should carry the prescribed disclaimer.


Example Disclaimer Format

A Part-Time Research Analyst may use wording substantially similar to:

"The above services are not covered under the SEBI (Research Analysts) Regulations, 2014 and are not part of Research Analyst services. No complaint relating to the above services can be raised before SEBI under the Research Analyst framework."

The exact wording may be refined based on the professional's circumstances, but the regulatory intent must remain clear.


Does This Disclaimer Apply to Research Service Invoices?

No.

The disclaimer requirement applies specifically to invoices or documents relating to activities outside the scope of Research Analyst services.

For research services, the Research Analyst must comply with separate requirements including:

  • Client agreements
  • Research disclosures
  • Fee disclosures
  • Risk disclosures
  • SEBI registration details

Difference Between RA Disclosures and Non-RA Disclaimer

A Research Analyst has multiple disclosure obligations.

For Research Services

The RA must disclose:

  • SEBI registration details
  • Research analyst status
  • Risks
  • Conflicts of interest
  • Financial interests

For Non-RA Professional Services

The professional must clarify:

  • The service is not a Research Analyst service
  • SEBI RA regulations do not apply
  • Complaints cannot be filed with SEBI under the RA mechanism for such services

Importance for Chartered Accountants and Other Professionals

Many professionals operate hybrid practices.

For example:

A Chartered Accountant may provide:

  • Audit services
  • Tax advisory
  • Due diligence
  • Financial research

If the professional obtains Part-Time RA registration, each activity must be clearly classified.

Without proper segregation, there may be a risk that clients misunderstand the nature of services.


Common Compliance Mistakes by Part-Time Research Analysts

Not Adding Disclaimer on Professional Invoices

Many professionals assume that SEBI registration only impacts research documents.

However, non-RA service documents also require appropriate clarification.


Using Research Analyst Branding on Non-RA Services

A professional should avoid creating confusion by:

  • Using RA terminology on unrelated services
  • Marketing non-RA services as investment research
  • Combining unrelated service offerings

Mixing Fees Received for Different Services

Separate accounting records should ideally be maintained for:

  • Research service income
  • Professional service income

This helps demonstrate regulatory segregation.


Providing Investment Advice Through Non-RA Engagements

A Part-Time RA should ensure that other professional services do not indirectly become:

  • Investment advice
  • Portfolio management
  • Securities recommendation services

Such activities may trigger separate regulatory requirements.


Recommended Compliance Framework for Part-Time Professionals

Professionals operating as Part-Time RAs should maintain:

Separate Engagement Documentation

Maintain separate agreements for:

  • Research services
  • Other professional services

Separate Billing Structure

Invoices should clearly identify:

  • Nature of service
  • Applicable regulatory framework
  • Relevant disclosures

Separate Communication Channels

Where practical, maintain distinction between:

  • Research communications
  • Professional service communications

Internal Compliance Review

Periodically review:

  • Website content
  • Marketing material
  • Invoice formats
  • Client communications

to ensure proper segregation.


Impact on Professional Firms

Where a professional firm has multiple partners or members, the firm should carefully evaluate:

  • Which individuals are registered as RAs
  • Which services are being provided
  • Whether the firm name creates confusion
  • Whether separate branding or disclosures are required

Regulatory clarity becomes increasingly important as professional firms expand into capital market-related services.


Practical Example

A CA firm has a partner who is registered as a Part-Time Research Analyst.

The firm provides:

  • Audit services
  • Tax advisory
  • Financial modelling
  • Equity research reports

For audit and tax invoices:

The firm should include the Part-Time RA disclaimer wherever applicable.

For research reports:

The firm must comply with SEBI RA disclosure requirements.

The two activities should not be mixed.


Compliance Checklist for Part-Time RA Disclaimer Requirement

A Part-Time Research Analyst should verify:

  • Disclaimer included on non-RA invoices
  • Minimum 10 font size followed
  • Disclaimer is prominently displayed
  • Research and non-research services are segregated
  • Separate documentation maintained
  • Client communications clearly identify service nature

Conclusion

The disclaimer requirement for Part-Time Research Analysts is a critical investor protection measure.

It ensures that clients clearly understand whether they are receiving:

  • SEBI-regulated research services; or
  • Other professional services outside the Research Analyst framework.

Professionals adopting the Part-Time RA model must carefully maintain segregation between their professional practice and research activities.

A properly designed compliance framework helps professionals expand into securities research while maintaining regulatory clarity and avoiding unnecessary compliance risks.


How Anuj Desai & Associates Can Assist

Anuj Desai & Associates assists professionals with:

  • Part-Time Research Analyst registration advisory
  • SEBI compliance framework implementation
  • Invoice and disclosure review
  • Research Analyst SOP preparation
  • Professional practice restructuring
  • Regulatory documentation support
  • Annual compliance audit assistance

Our team helps professionals build compliant Research Analyst practices while maintaining proper separation from their existing professional activities.

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