SEBI drops mandatory call recording for research analysts' institutional clients

The Securities and Exchange Board of India (SEBI) has relaxed a record-keeping rule for research analysts. Under a circular dated 23 October 2026, research analysts and research entities no longer have to keep call recordings of conversations with clients that are institutional investors. The change takes effect from 8 November 2026.

What Happened

SEBI's Research Analysts Regulations require analysts to keep records of their communication with clients, including call recordings. SEBI said it received representations from market participants and, as part of efforts to improve ease of doing business, the regulation has been amended to relax this requirement for institutional investor clients.

The circular replaces the relevant parts of SEBI's Master Circular for Research Analysts. Analysts must still keep records of interactions with all clients, including prospective clients before onboarding, where their services were discussed. These records can be a physical record signed by the client, call recordings, emails from a registered email ID, SMS records or any other legally verifiable record. Only call recordings with institutional investors are now not mandatory.

Records must start from the first interaction and continue until the research services end. They must be kept for five years, or longer if a dispute is raised or SEBI asks for specific records to be preserved. SEBI also clarified that a call recording is not needed when the interaction happens through a channel such as email that leaves a digital footprint.

The Research Analysts Administration and Supervisory Body, which oversees registered analysts, has been asked to amend its bye-laws and inform analysts.

What It Means

For individual investors who pay for research advice, nothing changes: analysts must still keep a record of every conversation about their services, whether by call recording, email, SMS or signed document. SEBI said the purpose of these records is to deal with possible client grievances about research services. The relaxation applies only to calls with institutional investors.

Source: SEBI circular