What are BSE's penalties for SEBI research analysts and investment advisers?
Since 1 May 2026 BSE fines RAs and IAs on a fixed schedule: ₹25,000 for a missed annual audit or a change in control without approval, ₹100 a day for a late report, ₹5,000 for a missing display, up to ₹1 lakh for mixing advice with distribution. An unpaid penalty stops you taking new clients.
Want this checked against your own position? We handle the documentation and the filing.
BSE issued two notices on 29 April 2026, 20260429-16 for research analysts and 20260429-17 for investment advisers. Each carries a penalty table as Annexure A and applies to non-compliances BSE observes on or after 1 May 2026. The two tables match on the common rows. Each also has rows only for its own registration.
The penalties most advisers run into
| What went wrong | Penalty |
|---|---|
| Change in control without SEBI's prior approval | ₹25,000 per violation |
| Annual compliance audit not done | ₹25,000 |
| Periodic report or audit report filed late | ₹100 a day in the first month, ₹200 a day in the second |
| A required display or filing missing: complaint data, investor charter, action taken report, name, logo or registration number | ₹5,000 per violation |
| No working website | A warning with 30 days to fix it, then ₹5,000 a month |
| MITC or terms and conditions not given to a client | ₹1,000 per client, up to ₹25,000 |
| No compliance officer (firms and companies) | ₹20,000 for the first three months, then ₹20,000 a month |
| Advertisement issued without approval, content otherwise compliant | A warning, then ₹5,000, then ₹10,000 per advertisement |
| Advertisement content that breaks the advertisement code | ₹10,000, then ₹20,000 per advertisement, and it comes down at once |
| Fees charged outside SEBI's limits | A warning and a refund, then ₹10,000 |
| Complaints left unresolved | ₹100, then ₹200, per complaint per day |
| Advice or research not kept apart from distribution | ₹10,000 per client; over 10 clients, ₹1 lakh, a stop on new clients and a reference to SEBI |
| Part-time client cap crossed, or AI use not disclosed | A warning, then ₹10,000 |
| Past performance shown without the required verification | ₹10,000, then ₹20,000, then a three-month stop on new clients |
| Deposit not maintained | No fine: if a shortfall is not made good in time, new clients are blocked for at least a month, and SEBI is told if you give BSE no plan to fix it |
From Annexure A of BSE notices 20260429-16 (RA) and 20260429-17 (IA). After three advertisement breaches BSE may freeze your advertising for three months.
When a fine becomes a stop on new clients
If a penalty is still unpaid when the appeal period ends, BSE stops you onboarding new clients until you comply and pay. For late reports and audit reports the restriction starts two months after the due date. For inspection data BSE gives 10 days, then two reminders of 7 days each, then fines ₹5,000 plus ₹200 a day for up to 7 days, and after that refers you to SEBI.
These are BSE's own penalties. SEBI can still act separately under the SEBI Act, through its adjudicating officer.
Rows only for one registration
- Research analysts: research report disclosures, report content, trading restrictions, analyst pay, public appearances and third-party research, each ₹5,000 to ₹20,000, some only after a first warning.
- Investment advisers: risk profiling and suitability at ₹5,000 per client up to ₹50,000; implementation services at ₹5,000; a second opinion on assets you distributed at ₹1,000 per client up to ₹25,000, plus a refund.
Our view: almost every line in this table is a missed date or a missing page. The cheapest protection is a calendar someone watches and a website that carries every display. Our monthly compliance plan keeps the dates, our compliant website service keeps the displays, and the website checker tests several of them on your site today.
- 1.BSE notice 20260429-16, 29 April 2026, Penalty Structure for Research Analysts, Annexure A (non-compliances observed on or after 1 May 2026)
- 2.BSE notice 20260429-17, 29 April 2026, Penalty Structure for Investment Advisers, Annexure A
- 3.Securities and Exchange Board of India Act, 1992, sections 15EB and 15-I (penalties imposed by SEBI's adjudicating officer)
We handle the documentation and filing: Monthly compliance plan
Sources read on 4 November 2026. SEBI revises these requirements, so we re-confirm every figure against the current circular before it goes into an application.
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