The Securities and Exchange Board of India (SEBI) on October 23, 2026, notified the review of regulatory requirements for maintenance of call records of institutional clients by Research Analysts or Research Entities.
The following has been stated:
• SEBI has amended its Master Circular for Research Analysts dated February 6, 2026, to relax the requirement for maintaining call recordings of interactions with institutional investors, effective November 8, 2026. Under the revised provisions, Regulation 25(1) of the SEBI (Research Analysts) Regulations, 2014, requires Research Analysts (RAs) and Research Entities (REs) to maintain records of interactions with all clients, including prospective clients, from the first interaction until completion of research services. Such records may include physical records signed by clients, call recordings, emails from registered email IDs, SMS messages, and other legally verifiable records.
• However, maintaining call recordings of interactions with institutional investors is no longer mandatory. Call recordings are also not required where interactions take place through channels such as email that provide a digital footprint. Records of client interactions shall generally be preserved for five years; where a dispute has been raised, they shall be retained until its resolution, or longer where SEBI directs that specific records be preserved. These requirements apply to both fee-paying and non-fee-paying clients.
• The Research Analysts Administration and Supervisory Body is required to amend its relevant bye-laws and rules, notify registered Research Analysts and disseminate the revised provisions through its website. All other provisions of the Master Circular remain unchanged.
[Notification No. - HO/38/11/(9)2026-MIRSD-POD/I/24272/2026]
