In short: SEBI has relaxed the rule that required research analysts to record calls with clients. For institutional investors, keeping call recordings is no longer mandatory. The change takes effect from 8 November 2026, and record-keeping for other clients continues as before.
What has changed?
On 23 October 2026, SEBI issued a circular to all registered Research Analysts (RAs) and to the Research Analysts Administration and Supervisory Body (RAASB). Regulation 25(1)(vii) of the Securities and Exchange Board of India (Research Analysts) Regulations, 2014 requires an RA or research entity (RE) to maintain records of communication, including call recordings. That regulation has now been amended, and the requirement is relaxed for clients who are institutional investors.
SEBI says it acted on representations from market participants, as part of its ongoing efforts to improve ease of doing business. It has also modified its Master Circular for Research Analysts dated 6 February 2026 to reflect the change.
What do the revised provisions say?
Paragraph 1.13 of Chapter I of the Master Circular has been replaced. An RA must still keep records of interactions with all clients, including prospective clients before onboarding, where any conversation about its services has taken place. Such records may take these forms:
- a physical record written and signed by the client;
- call recordings;
- emails from the client's registered email ID;
- records of SMS messages; or
- any other legally verifiable record.
A new proviso says that maintaining call recordings of interactions with institutional investors is not mandatory. The same proviso has been added to the FAQ at paragraph 33 of Annexure I in Chapter VII of the Master Circular.
What stays the same?
SEBI has stated that all other provisions of the Master Circular remain unchanged. In particular:
- Duration: records begin with the first interaction and continue until the research services to the client are completed.
- Retention: RAs and REs must keep these records for five years. If a dispute has been raised, records must be kept until it is resolved. If SEBI wants specific records preserved, they must be kept until SEBI says otherwise.
- Fee-paying and non-fee-paying clients: the record-keeping requirement applies to both, according to the FAQ.
- Digital interactions: call recording is not needed where the interaction happens through email or similar means that leave a digital footprint.
SEBI explains that the purpose of these records is to document interactions so that potential client grievances about research services can be addressed.
| Client type | Call recording from 8 November 2026 |
|---|---|
| Institutional investors | Not mandatory |
| Other clients, including prospective clients | Records of interactions must still be kept, and call recordings remain one accepted form |
Who is affected?
Registered research analysts and research entities that deal with institutional investors benefit most, since they no longer have to record those calls. The RAASB has been asked to amend its relevant bye-laws and rules to implement the circular. It must also bring the circular to the notice of registered RAs and publish it on its website.
Legal basis
The circular is issued under section 11(1) of the Securities and Exchange Board of India Act, 1992, read with Regulation 25(1)(vii) of the RA Regulations. SEBI says the aim is to protect investors in securities and to promote and regulate the securities markets.
What should readers do?
- Research analysts: review your record-keeping processes before 8 November 2026. Keep records for non-institutional clients and prospective clients as before.
- Retail clients: nothing changes for you. Your interactions with an RA should still be documented.
Frequently asked questions
When does the new rule apply?
The circular's provisions come into effect from 8 November 2026.
Do research analysts have to stop recording institutional calls?
No. The circular only says that maintaining call recordings for institutional investors is not mandatory. It does not prohibit recording.
Has the five-year record retention period changed?
No. RAs and REs must still keep records for five years, or longer if a dispute is pending or SEBI asks for specific records to be preserved.