The SEBI (Research Analysts) Regulations, 2014 impose numerous ongoing compliance obligations on Research Analysts. Missing deadlines can result in regulatory action, penalties, and reputational damage. This comprehensive compliance calendar consolidates all key deadlines for the financial year 2026-27.
Annual Reporting Deadlines
April
| Deadline | Obligation | Reference |
|---|---|---|
| April 30 | Deposit amount revision based on maximum number of clients in previous financial year | Regulation 8, RA Regulations |
| April 30 | Periodic report submission for half-year ending March 31 | Circular SEBI/HO/MIRSD/MIRSD-PoD1/P/CIR/2024/148 |
June
| Deadline | Obligation | Reference |
|---|---|---|
| June 30 | Compliance with client-level segregation requirements | Regulation 26C, RA Regulations |
| June 30 | Model portfolio guidelines compliance | Regulation 24(8), RA Regulations |
| June 30 | Disclosure of terms and conditions for existing clients | Regulation 24(6), RA Regulations |
| June 30 | KYC and record maintenance compliance | Regulation 25(1), RA Regulations |
| June 30 | AI tools disclosure for existing clients | Regulation 19(vii), RA Regulations |
| June 30 | Website maintenance and details compliance | Regulation 19A, RA Regulations |
| June 30 | MITC communication to existing clients | Circular SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/20 |
July
| Deadline | Obligation | Reference |
|---|---|---|
| July 31 | Periodic report submission for half-year ending March 31 (extended) | Circular SEBI/HO/MIRSD/MIRSD-PoD1/P/CIR/2024/148 |
| July 31 | NISM certification for PARS (within one year from July 23, 2025) | Circular SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/105 |
August
| Deadline | Obligation | Reference |
|---|---|---|
| August 31 | NISM certification for PARS (within one year from July 23, 2025) | Circular SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/105 |
September
| Deadline | Obligation | Reference |
|---|---|---|
| September 30 | Partnership firm conversion to LLP/body corporate (where no partner has required qualifications) | Regulation 2(1)(oa), RA Regulations |
| September 30 | Deposit compliance using liquid/overnight mutual funds or bank deposit | Regulation 8, RA Regulations |
| September 30 | Periodic report submission for half-year ending September 30 | Circular SEBI/HO/MIRSD/MIRSD-PoD1/P/CIR/2024/148 |
October
| Deadline | Obligation | Reference |
|---|---|---|
| October 31 | Annual compliance audit report submission | Regulation 25(3), RA Regulations |
Ongoing Compliance Obligations
Monthly
| Deadline | Obligation | Reference |
|---|---|---|
| 7th of succeeding month | Complaint data disclosure on website/mobile application | Investor Charter Circular |
Half-Yearly
| Reporting Period | Submission Deadline | Reference |
|---|---|---|
| September 30 | October 30 | Circular SEBI/HO/MIRSD/MIRSD-PoD1/P/CIR/2024/148 |
| March 31 | April 30 | Circular SEBI/HO/MIRSD/MIRSD-PoD1/P/CIR/2024/148 |
Annual
| Deadline | Obligation | Reference |
|---|---|---|
| Within 6 months of financial year end | Annual compliance audit completion | Regulation 25(3), RA Regulations |
| October 31 | Compliance audit report submission | Regulation 25(3), RA Regulations |
| Within 6 months of financial year end | Client-level segregation annual certificate | Regulation 26C(5), RA Regulations |
Compliance Audit Requirements
Audit Completion
- Within 6 months from end of financial year: Annual compliance audit must be completed
- Period: Audit covers the financial year (April 1 to March 31)
Audit Report Submission
- Within one month from audit report date: Submit to RAASB/SEBI
- Not later than October 31: For the previous financial year
- Website Publication: Publish audit report status on website
- Adverse Findings: Publish adverse findings and action taken on website
- Client Communication: Provide compliance audit report to clients
Complaint Data Disclosure
Monthly Requirements
- 7th of succeeding month: Disclose complaint data on website/mobile application
- Format: As per Annexure E of Master Circular
- Content: Complaint data including SCORES complaints
Format Requirements
- Data for the month ending: Month-end date
- Pending at end of last month: Opening balance
- Received during month: New complaints received
- Resolved during month: Complaints resolved
- Total pending: Closing balance
- Pending > 3 months: Ageing information
- Average Resolution Time: Average time taken to resolve complaints
Fee Related Obligations
Fee Limit Compliance
- Maximum ₹1,51,000 per annum per family: For individual and HUF clients
- Revision: RAASB to revise once in three years based on CII
Advance Fee
- Maximum one year: Advance fee cannot exceed one year
Refund
- Proportionate refund: On premature termination
- No breakage fee: Cannot charge breakage fee
Key Regulatory Dates
Effective Dates
- July 25, 2024: RAASB/IAASB framework operational
- December 16, 2024: Third Amendment to RA Regulations effective
- January 8, 2025: Guidelines for Research Analysts circular
- June 2, 2025: Investor Charter circular effective
Expert Legal Guidance
Anuj Desai & Associates provides expert legal services for Research Analysts on compliance calendar management. Our securities law experts help RAs track deadlines, maintain compliance, and respond to regulatory inquiries. We assist in developing compliance checklists, establishing compliance procedures, and ensuring timely submission of all regulatory filings.
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