SEBI’s 23 October circular removes the mandatory requirement for research analysts and research entities to retain call recordings of institutional-client interactions from 8 November 2026. It retains the wider obligation to document interactions with clients and prospective clients about research services.[1]
At a glance01
Record-keeping after the change
| Area | Continuing requirement |
|---|---|
| Institutional call audio | No longer mandatory under this specific requirementSource 1 |
| Other evidence | Signed written records, registered-email correspondence, SMS or another legally verifiable recordSource 1 |
| Period covered | First interaction through completion of servicesSource 1 |
| Retention | Five years; preserve longer for unresolved disputes or a SEBI directionSource 1 |
| Client scope | Fee-paying clients and specified non-fee-paying clients receiving research as a paid-group-service benefitSource 1 |
Email and similar channels already provide a digital record; the circular does not require audio where no call takes place. The change is an institutional audio-recording relaxation, rather than an exemption from documenting research-client relationships.[1]
Sources & further reading
- Review of institutional-client call-record requirements, 23 October 2026 SEBI · Accessed 26 Oct 2026