A Small Requirement That's Easy to Overlook, and Easy to Get Flagged For
Of everything a part-time IA needs to manage, this is one of the smallest in scope and one of the most mechanically overlooked — because it doesn't feel like "real" compliance work. It's a text disclaimer on an invoice. But SEBI's Master Circular is specific about it, and getting it wrong (or forgetting it entirely on some invoice templates but not others) is a genuinely checkable compliance gap.
Why This Disclaimer Exists
Once you hold part-time IA registration, clients could reasonably assume that everything you tell them — including your general tax and compliance advice — carries the same SEBI-backed regulatory protection as your actual investment advisory activity. The disclaimer exists specifically to prevent that conflation, making clear which of your services fall outside SEBI's purview and therefore outside SEBI's grievance/recourse mechanisms.
What the Requirement Actually Specifies
Every invoice or communication relating to your non-IA services — your core tax filing, audit, or other professional services entirely unrelated to investment advisory — must carry a disclaimer stating that this activity is outside SEBI's purview, and that no SEBI complaint recourse exists for it. SEBI specifies a minimum 10-font size for this disclaimer — meaning it can't be buried in illegible fine print at the bottom of an invoice.
Where This Needs to Actually Appear
This isn't limited to formal invoices alone — it should appear consistently across the range of client-facing documents and communications relating to your non-IA services: engagement letters, fee notes, and any other formal client communication touching your tax/compliance practice, not just the final billing document.
The Compliance Trap: Inconsistent Application Across Templates
The most common failure mode we see isn't a firm that ignores this requirement entirely — it's a firm that implements it correctly on one invoice template (say, tax filing invoices) but forgets to add it to another (say, a separate compliance-retainer invoice template, or an ad hoc fee note format used less frequently). Because the requirement needs to apply consistently across every non-IA communication, partial implementation is itself a compliance gap.
Suggested Disclaimer Language
While exact wording should be confirmed against your specific registration and current SEBI guidance, the disclaimer should clearly convey, in text no smaller than 10-font: that the services covered by this specific invoice/communication are outside the scope of your SEBI Investment Adviser registration, are not subject to SEBI regulation, and that SEBI/IAASB grievance mechanisms don't apply to them.
Why This Deserves a Proper Template Audit, Not a One-Time Fix
Because firms often use multiple invoice and communication templates across different service lines, a proper implementation means auditing every template your practice uses — not just updating the one you thought of first — and building the disclaimer into your standard document generation process so it can't be accidentally omitted on a one-off communication.
Auditing and Implementing This Correctly Across Your Practice
We review CA firms' complete set of client-facing templates once part-time IA registration is granted, ensuring the disclaimer is correctly and consistently implemented across every non-IA communication — not just the most obvious one.
Recently registered as a part-time IA and need your invoice templates properly audited and updated? Anuj Desai & Associates can handle this as part of your post-registration compliance setup.
This article is for general informational purposes. Please confirm exact disclaimer wording requirements against current SEBI Master Circular provisions before finalising your templates.