Investment adviser compliance — SEBI guides
Guides by CA Anuj Desai for SEBI-registered investment advisers (RIAs) — individual and non-individual registration, fee modes and limits, segregation of advisory and distribution, risk profiling, advertisement and brand-name rules, PaRRVA, record-keeping and the annual compliance audit.
- Dual Registration as IA and RA – Arms-Length Relationship Requirement
A comprehensive analysis of the arms-length relationship requirement for dual registrants as both a Research Analyst and an Investment Adviser, including implementation guidelines and compliance obligations.
CA Anuj Desai · 25 Jul 2026
- Why IAs Can No Longer Charge Upfront Fees — And What "Advance Fee" Actually Means Now
How SEBI's advance-fee rules actually work for Investment Advisers — the one-year cap, the breakage-fee mechanics on early termination, and why "upfront fee" and "advance fee" aren't the same thing.
CA Anuj Desai · 18 Jul 2026
- UPI Fee Collection for IAs — The Standardised, Validated, Exclusive ID Requirement
Why Investment Advisers can't simply use any UPI handle to collect client fees — the Standardised, Validated, Exclusive UPI ID requirement explained.
CA Anuj Desai · 18 Jul 2026
- Fee-Only vs Commission-Based Advice — Why India's IA Framework Forces This Choice
Why SEBI's regulatory architecture effectively forces a choice between fee-only advisory and commission-based distribution — and what that means for how an advisory practice must be structured.
CA Anuj Desai · 18 Jul 2026
- Why IAs Can't Offer Free Trials — And What to Do Instead to Win a Prospective Client's Trust
Why SEBI expressly prohibits Investment Advisers from offering free trials to prospective clients — and the compliant alternatives that still let you build trust before a client commits.
CA Anuj Desai · 18 Jul 2026
- Direct Plan Recommendation Obligations — Why an IA Must Always Point Clients to Direct Plans
Why SEBI's Investment Adviser framework specifically requires recommending direct (non-commission) plans wherever available — and what this means for how you document product recommendations.
CA Anuj Desai · 18 Jul 2026
- Record-Keeping Requirements for IAs — What to Maintain, For How Long, and How
What Investment Advisers are actually required to record and retain — from first client interaction through execution instructions — and for how long.
CA Anuj Desai · 18 Jul 2026
- Change in Control for an IA Firm — What Approval Process Applies and When
What actually counts as a "change in control" for a SEBI-registered Investment Adviser, and the prior-approval process that must be completed before it can take effect.
CA Anuj Desai · 18 Jul 2026
- Outsourcing Compliance Functions as an IA — What You Can Delegate and What You Can't
What SEBI actually permits Investment Advisers to outsource — and the critical distinction between delegating a task and delegating accountability, which never actually transfers.
CA Anuj Desai · 18 Jul 2026
- The "Finfluencer" Restriction Explained — Why IAs Must Be Careful Who They Associate With Publicly
SEBI's 2024 finfluencer crackdown doesn't just target unregistered creators — it makes every registered IA directly accountable for who they're seen collaborating with. Here's exactly where that liability line sits
CA Anuj Desai · 18 Jul 2026
- Brand Name vs SEBI-Registered Name — The Display Rule Every IA's Website Must Follow
Your marketing team wants a catchy brand name. SEBI wants your registered name front and centre on every client-facing surface. Here's how to run both without falling foul of the display rule
CA Anuj Desai · 18 Jul 2026
- Can an IA Publish Educational Content Without It Being Treated as Solicitation?
SEBI has drawn a genuine, usable line between education and advice — but it's a narrower line than most IA content calendars assume, and it's easy to cross without realising it
CA Anuj Desai · 18 Jul 2026
- Can an IA Show Prospective Clients Their Past Performance? — The Interim Rules Right Now
Referencing your own past performance to a prospective client feels like the most natural thing in the world to do — and it's precisely the area where SEBI's current rules are narrowest and most easily misjudged
CA Anuj Desai · 18 Jul 2026
- Why Past Performance Disclaimers Matter More Than Most IAs Realise
A disclaimer isn't legal decoration at the bottom of a page — it's evidence. Get the wording, placement, or consistency wrong, and it stops functioning as the protection it's meant to be.
CA Anuj Desai · 18 Jul 2026
- SaaS-Based Compliance Tools for IAs — What the Data Localisation Rules Require
Every SaaS tool an IA adopts — CRM, portfolio tracking, document management — now sits inside a specific compliance obligation most practices haven't fully mapped: a periodic undertaking on where client data actually lives, and who can access it.
CA Anuj Desai · 18 Jul 2026
- Investor Charter for IAs — What Every Client Is Entitled To Expect
SEBI's Investor Charter isn't a marketing document — it's a specific list of rights, service standards, and timelines every Investment Adviser is expected to publish and actually honour. Here's what it actually promises you.
CA Anuj Desai · 18 Jul 2026
- What Happens to Your Advisory Relationship If Your IA Changes Ownership or Shuts Down?
EBI's framework for a change in control at an IA isn't just a back-office regulatory formality — it includes a specific requirement that you, as an existing client, be told before the change actually takes effect
CA Anuj Desai · 18 Jul 2026
- MITRA and Unclaimed Mutual Fund Folios — How IAs Can Help Clients Recover Lost Investments
MITRA gives IAs a genuine, compliance-relevant reason to review a new client's full investment history — surfacing forgotten holdings that materially change the suitability and portfolio picture
CA Anuj Desai · 18 Jul 2026
- Should You Register as an Individual or Set Up a Company for Your IA Practice?
SEBI's individual and non-individual IA registration categories aren't just paperwork variants — they carry genuinely different net worth, client-scaling, and succession implications worth weighing carefully before you apply
CA Anuj Desai · 18 Jul 2026
- Individual vs Non-Individual IA Registration — Which Structure Should You Choose?
How to decide between individual and non-individual Investment Adviser registration — the practical, structural, and compliance differences that should drive the decision.
CA Anuj Desai · 17 Jul 2026
- The 300-Client / ₹3 Crore Rule — When an Individual IA Must Become a Non-Individual IA
The specific SEBI rule requiring individual Investment Advisers to transition to non-individual registration once they cross 300 clients or ₹3 crore in fees — and how to manage that transition without disrupting your practice.
CA Anuj Desai · 17 Jul 2026
- Principal Officer Requirements for Non-Individual IAs — Eligibility, Certification & Responsibilities
What SEBI requires of a Principal Officer at a non-individual Investment Adviser — qualification criteria, certification, and what happens if no partner meets the bar.
CA Anuj Desai · 17 Jul 2026
- IA Deposit Requirements Explained — The Client-Count Slabs and How to Stay Compliant
How the SEBI Investment Adviser deposit requirement actually works — the client-count slabs, permitted deposit forms, and the annual revision deadline advisers often miss.
CA Anuj Desai · 17 Jul 2026
- When Does a Chartered Accountant Need IA Registration? — The Line Between Tax Planning and Investment Advice, Explained With Real Examples
The exact line SEBI draws between a CA's incidental commentary on securities and advice that requires part-time Investment Adviser registration — with the worked examples straight from the Master Circular.
CA Anuj Desai · 17 Jul 2026
- Part-Time IA Registration for CAs: A Practical Compliance Checklist
A practical, step-by-step compliance checklist for Chartered Accountants who've determined they need part-time IA registration — from application through ongoing obligations.
CA Anuj Desai · 17 Jul 2026
- The Disclaimer Every CA Must Put on Non-IA Invoices Once They Hold Part-Time IA Registration
The specific, mandatory disclaimer SEBI requires on every non-IA invoice and communication once a Chartered Accountant holds part-time Investment Adviser registration — and why getting this small detail wrong is a real compliance gap.
CA Anuj Desai · 17 Jul 2026
- CA + CFP + IA — How These Three Credentials Actually Differ and Why You Might Need More Than One
CA, CFP and IA sound like overlapping credentials but each unlocks a different, legally distinct scope of work. Here's what each one actually permits — and where professionals get the boundaries wrong.
CA Anuj Desai · 17 Jul 2026
- Should Your CA Firm Build an In-House IA Practice or Refer Clients Externally? — The Business Case
Building an in-house IA vertical inside a CA firm isn't just a compliance decision — it's a structural business call with real cost, liability and governance trade-offs against simply referring clients out.
CA Anuj Desai · 17 Jul 2026
- Family Office Advisory and IA Registration — Where the Two Intersect for a CA-Led Family Office Practice
Not every family office activity needs IA registration — but the line between structuring/consolidation work and regulated investment advice is thinner than most CA-led family offices assume.
CA Anuj Desai · 17 Jul 2026
- Succession & Estate Planning Advice — Does It Require IA Registration, or Does It Stay Purely in the CA's Domain?
Succession and estate planning is core CA territory — until the plan starts recommending what to hold, sell, or reallocate. Here's exactly where that boundary sits.
CA Anuj Desai · 17 Jul 2026
- Presumptive Taxation for Part-Time IAs — Can Section 44ADA Apply to Advisory Income Alongside Professional Income?
Part-time IAs earning advisory fees alongside CA or CS professional income often assume 44ADA covers both. The eligibility, threshold and aggregation rules say otherwise in several common scenarios
CA Anuj Desai · 17 Jul 2026
- IA Fee Structures Explained — AUA Mode vs Fixed Fee Mode, and How the ₹1,51,000 Cap Actually Works
SEBI gives Investment Advisers exactly two fee modes to choose from per client per year — AUA-based or fixed fee — each with its own cap and switching restriction. Here's how the mechanics actually work.
CA Anuj Desai · 17 Jul 2026
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