SEBI cancels registrations of 11 research analysts over unpaid fees

The Enforcement Action

The Securities and Exchange Board of India (SEBI) has cancelled the certificates of registration of 11 research analysts, in an order dated 21 July 2026 passed by Soma Majumder, Chief General Manager, at Mumbai. The order was made under Section 12(3) of the SEBI Act, 1992 read with Regulation 30A of the SEBI (Intermediaries) Regulations, 2008, and it came into force with immediate effect.

The entities and individuals named in the order, which SEBI collectively terms the "Noticees", are 24 Carat Financial Services (INH000003358), Pankaj Mahasukhlal Shah (INH000000305), Sridhar Reddy Eragamreddy (INH200007788), Amar Kumar Srivastava (INH100006409), Lakshmishree Investment & Securities Pvt Ltd (INH000004565), PCS Securities Ltd (INH200000196), Manoj Asok Kumar (INH200006567), Sagar Shah (INH000004714), Yash Utmani (INH000002632), Bansal Finstock Private Limited (INH000006165) and Pinank (INH000006998).

According to the order, each of these research analysts had failed to pay the renewal fee that a registered research analyst must pay every five years to keep a registration in force, and their certificates had already ceased to be in force before the cancellation was formalised. This is a regulatory action for non-payment of fees rather than any finding of market misconduct. The order records no allegation of manipulation, mis-selling or investor loss. SEBI stated that the object of cancellation is to prevent the misuse of registration certificates that are "no longer in force, on unaware investors".

The order also notes that the respondents numbered 4 to 11 themselves submitted that their registration may be cancelled, while the respondents numbered 1 to 3 filed no reply to the notices served on them. None of the named parties has, on the record of the order, contested the cancellation.

How the Scheme Worked

The matter turns on a recurring compliance obligation rather than any elaborate design. Under Clause 3 of the Second Schedule to the SEBI (Research Analysts) Regulations, 2014, a research analyst granted a certificate of registration must, to keep it in force, "pay fee every five years, from the date of grant of certificate of registration, within three months before expiry of the period for which fee has been paid". The order reproduces that clause verbatim.

SEBI recorded that the renewal fees fell due and were not paid across a spread of dates. The earliest lapses date back several years: per the order, the renewal fee remained unpaid from 14 April 2020 for Pankaj Mahasukhlal Shah and 24 March 2020 for PCS Securities Ltd, from 09 February 2021 for Yash Utmani and 16 August 2021 for 24 Carat Financial Services, and from 05 January 2022 for Lakshmishree Investment & Securities Pvt Ltd and 20 April 2022 for Sagar Shah. More recent defaults run from 2023, 2024 and, in the case of Sridhar Reddy Eragamreddy, 06 October 2025.

Because the fees were unpaid, SEBI initiated summary proceedings under Regulation 30A of the Intermediaries Regulations, 2008 read with Section 12(3) of the SEBI Act. The order states that the Noticees were called upon, through notices dated 03 February 2025, 04 February 2025, 24 February 2025, 29 May 2026 and 04 June 2026, to show cause as to why the certificates granted to them should not be cancelled or suspended. Each notice gave the recipient 21 days to file a written reply with documentary evidence.

The order records that the notices were duly served. No replies were received from the first three Noticees, and the summary-proceedings framework permits an order of cancellation or suspension where no written submissions are filed within the specified period. The remaining eight respondents wrote in to say that their registration may be cancelled. SEBI concluded that, the renewal fees being unpaid, the certificates "have ceased to be in force", and that the prescribed procedure for cancellation had been followed before the direction was issued.

The Law Invoked

The order rests on provisions the document itself cites. Section 12(3) of the SEBI Act, 1992 empowers the Board, by order, to suspend or cancel a certificate of registration in the manner determined by regulations. Section 19 of the same Act is the delegation provision under which the Board's powers may be exercised by a designated officer, here the Chief General Manager who signed the order.

Regulation 30A of the SEBI (Intermediaries) Regulations, 2008, headed "Summary Proceedings", supplies the fast-track process for such matters. Sub-regulation (2) requires a notice communicating the grounds; sub-regulation (3) gives the noticee 21 calendar days to respond in writing; and sub-regulation (7) empowers the competent authority to pass "an appropriate order of cancellation or suspension of the certificate of registration of the noticee or any other order, as deemed fit". Regulation 30A(10), which the order directs the Noticees to abide by, governs the wind-down obligations that survive a cancellation.

The underlying fee obligation flows from Clause 3 of the Second Schedule to the SEBI (Research Analysts) Regulations, 2014. In plain terms, registration as a research analyst is not a one-time grant: it must be renewed with a fee every five years, and a lapse in payment means the certificate stops being valid. These are administrative provisions, not penal ones; the order imposes no monetary penalty and makes no finding of dishonesty.

What Happens Next

An order of this kind is appealable. A person aggrieved by a SEBI order may approach the Securities Appellate Tribunal (SAT), ordinarily within 45 days, and from the SAT a further appeal on a question of law lies to the Supreme Court. On the record of this order, none of the named parties has indicated an intention to appeal, and most consented to the cancellation.

For the affected research analysts the practical effect is immediate: they can no longer hold themselves out as SEBI-registered research analysts. The order expressly preserves their residual duties. They "shall continue to be liable for anything done or omitted to be done" while registered, and must arrange for the maintenance and preservation of records, the redressal of investor grievances, the transfer of client records, funds or securities, and the continuity of service to existing clients. A copy of the order has been served on BSE Limited, which functions as the Research Analyst Administration and Supervisory Body, to ensure the necessary compliances follow.

Because this is a completed administrative action for non-payment of fees, there is no pending criminal process and no question of guilt or innocence to be tested at trial. The order simply removes a lapsed registration from the register.

What It Means

For ordinary investors, the useful takeaway is about verification rather than alarm. A cancelled registration means a person or firm is no longer authorised to operate as a SEBI-registered research analyst, and the regulator's stated concern is that a lapsed certificate could be shown to "unaware investors" as if it were still live. If you receive research recommendations, buy-sell calls or model portfolios from an analyst, it is worth confirming that the registration is current, not merely that it once existed.

That check is straightforward. SEBI publishes registration details for research analysts and investment advisers, and the number always begins with the prefix "INH" for a research analyst. You can verify a registration number against SEBI's records and against the Research Analyst Administration and Supervisory Body run by BSE. A valid-looking certificate that has quietly expired is precisely the risk this order is meant to close off.

More broadly, the action reflects the tighter administrative supervision of the research-analyst segment, where registrations now carry periodic renewal obligations and a summary route exists to strike off those that lapse. It is a reminder that registration is a continuing status, not a permanent badge, and that investors should treat "SEBI-registered" as a claim to be checked afresh rather than taken on trust.

FAQ

What exactly did SEBI order?

SEBI cancelled the certificates of registration of 11 research analysts with effect from 21 July 2026, because they had not paid the renewal fee required every five years to keep a registration in force. The order was passed under Section 12(3) of the SEBI Act, 1992 read with Regulation 30A of the SEBI (Intermediaries) Regulations, 2008.

Does the cancellation mean these research analysts did something fraudulent?

No. The order is limited to non-payment of renewal fees and records no allegation of manipulation, mis-selling or investor loss. It imposes no monetary penalty and makes no finding of dishonesty. The certificates had already ceased to be in force; the order formalises their cancellation.

Can the order be appealed?

Yes. A person aggrieved by a SEBI order may appeal to the Securities Appellate Tribunal, ordinarily within 45 days, with a further appeal on a question of law to the Supreme Court. On the record of this order, most of the named parties consented to the cancellation and none indicated an intention to appeal.

How can I check whether my research analyst is registered with SEBI?

Ask for the registration number, which begins with "INH" for a research analyst, and verify it against SEBI's published records and the Research Analyst Administration and Supervisory Body operated by BSE. Confirm the registration is current, since a certificate can lapse if renewal fees go unpaid.

What should clients of these research analysts do?

The order requires the affected analysts to maintain records, redress investor grievances, and arrange the transfer of client records, funds or securities and continuity of service. Clients should contact the analyst for an orderly handover and seek advice only from an entity whose SEBI registration is currently in force.

Where can I read the official order?

The full order, signed by Chief General Manager Soma Majumder and dated 21 July 2026, is published on SEBI's enforcement orders page and is linked in the source note below.

This report is based on the official SEBI order dated 21 July 2026 in the matter of certain Research Analysts, published on the regulator's enforcement orders page.