SEBI cancels ten research analyst registrations over unpaid fees

The Enforcement Action

SEBI, on 28 July 2026, cancelled the certificates of registration of ten research analysts for failing to pay the renewal fee that keeps such a registration in force. The order, numbered MIRSD/MIRSD-RAC-2/2026-2027/210035640 and signed at Mumbai by Soma Majumder, Chief General Manager, was passed under Section 12(3) of the SEBI Act, 1992 read with Regulation 30A of the SEBI (Intermediaries) Regulations, 2008. It comes into force with immediate effect.

The ten entities, named as Noticees No. 1 to 10, are a mix of individuals and firms. Among them are InGovern Research Services Private Ltd (registration number INH200002754) and Affluence Fincon Service Private Limited (INH000002707). The others named in the order are Imtiaz Rehman Merchant (INH000001683), Praveen Pathiyil (INH200008051), Mahesh Shrikrishna Joshi (INH000005458), Dhruvesh Sanghvi (INH000000875), Praful Bohra (INH000005227), Priya Clyde Andrades (INH000007003), Riyas Cholamughath (INH200003034) and Satish Kumar Chamaria (INH200002796).

Two points should be clear at the outset. This is an administrative action for non-payment of a periodic fee, not a finding of misconduct against any of the named parties. And per the order, eight of the ten had themselves written to SEBI asking that their registration be cancelled; the remaining two filed no reply. There is no allegation of investor loss, mis-selling or market manipulation anywhere in the document. It is, in plain terms, a housekeeping order that removes lapsed registrations from the regulator's rolls.

How the Scheme Worked

There is no scheme here, and the order alleges none. The mechanism is a straightforward compliance lapse, and understanding it is useful for anyone who relies on registered research. Under the SEBI (Research Analysts) Regulations, 2014, registration is not a one-time event. Clause 3 of the Second Schedule requires that a research analyst "shall pay fee every five years, from the date of grant of certificate of registration", and that the payment be made within three months before the current period expires. Miss that window, and the registration ceases to be in force.

That is what the order records happened. It sets out, for each analyst, the date registration was granted and the date from which the renewal fee remained unpaid. For the first noticee those dates are 8 September 2015 and 8 September 2020; for another, 17 May 2016 and 17 May 2021. Once a fee period lapses without payment, the certificate is, in the regulator's account, no longer valid, and the holder is no longer authorised to carry on the activity of a research analyst.

SEBI then followed the summary-proceedings route built for exactly this situation. The regulator issued notices dated 3 February 2025, 4 February 2025, 24 February 2025 and 29 May 2026, calling on the analysts to explain, within 21 days, why their certificates should not be cancelled or suspended. Per the order, the notices were duly served. Noticees No. 1 and 2 sent no reply, which under Regulation 30A permits the competent authority to proceed on the record before it. Noticees No. 3 to 10 replied and, rather than contest the matter, submitted that their registrations may be cancelled.

With the procedure complete and the fee periods already expired, the Chief General Manager held that the certificates should be cancelled and directed accordingly. The order also records that a copy would be served on BSE Limited, which acts as the Research Analyst Administration and Supervisory Body, so that its register reflects the change.

The Law Invoked

The order cites only the provisions relevant to registration and its cancellation. Section 12(1) of the SEBI Act, 1992 is the requirement that intermediaries such as research analysts hold a certificate of registration. Section 12(3) is the enabling power: it lets the Board, "by order, suspend or cancel a certificate of registration in such manner as may be determined by regulations". Section 19 of the same Act allows the Board to delegate its powers, which is how a Chief General Manager, rather than a Whole Time Member, comes to sign an order of this kind.

The procedural spine is Regulation 30A of the SEBI (Intermediaries) Regulations, 2008, headed "Summary Proceedings". It requires the competent authority to issue a notice setting out the grounds, gives the noticee 21 calendar days to respond in writing with documentary evidence, and empowers the authority to pass an appropriate order of cancellation or suspension. Regulation 22 of the same regulations defines the "competent authority" as a Whole Time Member or a designated officer not below the rank of Chief General Manager.

The substantive obligation sits in Clause 3 of the Second Schedule to the SEBI (Research Analysts) Regulations, 2014, the five-yearly renewal fee described above. Taken together, these provisions let SEBI clear lapsed registrations from the register through a documentary process, without a full adjudication of any conduct.

What Happens Next

A cancellation under Regulation 30A is a final order of the competent authority, and orders of SEBI of this nature are appealable to the Securities Appellate Tribunal within the statutory period. Any of the named analysts who disputes the cancellation, for instance by showing the fee was in fact paid, can take that route; those who themselves asked for cancellation are unlikely to.

The order does not simply end the relationship. It directs that, despite cancellation, each analyst shall continue to be liable for anything done or omitted to be done while registered. Each must also arrange for the maintenance and preservation of records, the redressal of investor grievances, the transfer of records, funds or securities of its clients, and continuity of service, and must comply with Regulation 30A(10) of the Intermediaries Regulations. In short, winding down a registration does not extinguish obligations to existing clients.

For BSE Limited, as the Research Analyst Administration and Supervisory Body, the practical step is to update its records so that the ten registrations no longer show as active. An analyst who later wishes to resume the activity would need to seek fresh registration rather than revive a lapsed one.

What It Means

For investors, the useful takeaway is not about these ten names but about a habit. A research analyst's SEBI registration can lapse quietly, for something as mundane as an unpaid renewal fee, without any wrongdoing attached. Yet an analyst whose registration is no longer in force is not authorised to issue research for consideration, and, as the order puts it, the purpose of cancellation is to prevent the misuse of certificates that are no longer valid on unaware investors.

The protection is simple and free. Before acting on a stock tip, a model portfolio or a "research report", check whether the person or firm behind it currently holds a valid research analyst registration. SEBI maintains a searchable list of registered intermediaries on its website, and BSE's Research Analyst Administration and Supervisory Body publishes the enforceable register of active analysts. A registration number that does not appear, or that shows as cancelled, is a reason to pause. Not because the person has necessarily done anything wrong, but because the regulatory accountability that registration carries is no longer in place.

This order is also a quiet reminder that "SEBI-registered" is a status with an expiry, not a permanent badge. The safest assumption is to verify at the point of use, every time money is at stake.

FAQ

What exactly did SEBI order?

SEBI cancelled the research analyst certificates of registration of ten intermediaries, with effect from 28 July 2026, because they had not paid the five-yearly renewal fee required 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 a cancellation for unpaid fees mean the analysts did something wrong?

No. This is an administrative action for non-payment of a periodic fee, and the order records no allegation of misconduct, investor loss or manipulation. In fact, eight of the ten had themselves asked SEBI to cancel their registration. A lapsed registration simply means the entity is no longer authorised to act as a research analyst.

Can the order be appealed?

Yes. Orders of SEBI of this kind are appealable to the Securities Appellate Tribunal within the statutory period. An analyst who believes the fee was paid, or that the cancellation was otherwise wrong, can pursue that remedy. Those who themselves requested cancellation are unlikely to appeal.

How can I check whether my research analyst is registered?

Use SEBI's list of registered intermediaries on sebi.gov.in, and the register maintained by BSE Limited as the Research Analyst Administration and Supervisory Body. Match both the name and the INH registration number, and confirm the status shows as active before acting on any recommendation.

What must the cancelled analysts still do for their clients?

Per the order, cancellation does not end their duties. They must preserve records, redress investor grievances, transfer clients' records, funds or securities, ensure continuity of service and comply with Regulation 30A(10) of the Intermediaries Regulations. They also remain liable for anything done while they were registered.

Where can I read the official order?

The order dated 28 July 2026 in the matter of certain Research Analysts is published in the enforcement orders section of SEBI's website. It is linked at the end of this report.

This report is based on the official SEBI order dated 28 July 2026 in the matter of certain Research Analysts, published on the SEBI website.