Research policies and trading restrictions
A Research Analyst works under dealing limits around every report, a factsheet standard for any model portfolio and a five-year records rule. We write the policies and the registers that show you followed them.
Research Analysts.
To see when this and your other duties fall due, use the free compliance calendar.
- Regulation 16: no dealing in a recommended security for 30 days before and 5 days after publication of the report.
- No trading contrary to your own recommendation, and no pre-IPO purchase in the same line of business.
- A model portfolio, meaning a basket of securities with weightages, is issued as a research report with a factsheet. The factsheet carries the rationale, methodology, launch and update date, true-to-label naming, investment horizon, rebalancing frequency, risk disclosures and a benchmark to a relevant index.
- A list of securities with no weightages is not a model portfolio.
- Records are kept for five years, including interactions with clients and prospective clients from the first contact, and until resolution where a dispute is raised.
- The research rationale has to be documented, and the model portfolio is covered by the annual compliance audit.
- Write the trading-restriction policy and a register that logs each report and the 30-day and 5-day windows.
- Prepare the model-portfolio factsheet template to the Annexure A content.
- Write the record-keeping procedure for the five-year rule.
- Keep the policy current when SEBI revises it.
- The kinds of research you publish and whether you issue model portfolios.
- Who in your team can deal in securities, and how research is circulated.
- Your existing records and any register you already keep.
Inside the ₹24,999 Documentation Pack
The trading-restriction policy, model-portfolio factsheet template and record-keeping templates are part of the Adviser Documentation Pack. Ongoing upkeep is quoted on a call.
What are the dealing windows?
No dealing in a recommended security for 30 days before and 5 days after publication of the report.
Does a watchlist count as a model portfolio?
A list with no weightages is not a model portfolio. A basket with weightages is, and it has to be issued as a research report with a factsheet.
How long do I keep records?
Five years, including interactions with clients and prospective clients from the first contact. If a dispute is raised, records are kept until it is resolved.
Want this taken off your list?
Tell us your registration type and financial year end. We will tell you what we would handle and what we need from you.
Sources: SEBI (Research Analysts) Regulations, 2014, as last amended on 6 August 2025; SEBI circular 2025/105 of 23 July 2025 (FAQs for Research Analysts); SEBI circular 2025/004 of 8 January 2025 (Guidelines for Research Analysts); SEBI Master Circular for Research Analysts, 6 February 2026.