SEBI relaxes research call-recording rules for institutional clients

Indian research analysts and research entities will gain an exemption from mandatory recordings of calls with institutional-investor clients under a newly notified SEBI amendment. The change adds a narrow exception to the communications-record requirement in Regulation 25, reducing the recording obligation for that client category.[1]

SEBI posted the notification on 10 October. The legal instrument is dated 8 October and provides that it takes effect on the thirtieth day calculated from publication in the Official Gazette. Firms therefore need to distinguish notification from commencement when changing their procedures.[2][1]

The exemption uses the institutional-investor definition in Regulation 2(1)(y) of the Issue of Capital and Disclosure Requirements Regulations, 2018. It does not create an exemption based simply on an account’s size. The amended provision leaves the recording requirement for clients outside that category in place.[1]

The broader recordkeeping framework matters because research relationships extend beyond telephone conversations. SEBI’s May consultation reproduced requirements for evidence of interactions beginning with the first discussion with a prospective client and continuing through completion of the research service. Recognised forms include signed written records, emails from registered addresses, SMS messages and other legally verifiable evidence.[3]

That consultation also set out a five-year retention period, extended where a dispute remains unresolved or SEBI requires particular records to be kept. The October amendment changes the institutional call-recording obligation rather than deleting the wider records regime.[3]

Firms serving both retail and institutional clients will need recording policies based on verified client classification, while preserving the remaining evidence of communications.[1][3]

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