Can you hold both SEBI research analyst and investment adviser registration?
Yes. SEBI allows an individual or partnership firm registered as a research analyst to be granted investment adviser (advisor) registration, and the reverse. You then comply with both sets of regulations and both reporting requirements separately, and undertake to keep the two activities at arm's length.
Want this checked against your own position? We handle the documentation and the filing.
SEBI's FAQs for both registrations say a research analyst can be granted investment adviser registration and an investment adviser can be granted research analyst registration. The condition is separation. Each set of regulations and each reporting requirement is met on its own, and you undertake that the two services stay clearly segregated at arm's length.
Why a practice takes both
The registrations cover different work. Investment advice is personalised to one client, with a risk profile and suitability at its centre. Research analysis is a recommendation issued to whoever receives it. A practice that advises named clients and also publishes research needs both, and holding both is the clean structure for that.
What you carry twice
| Item | Research analyst | Investment adviser |
|---|---|---|
| NISM certification | Series XV, renewed with XV-B | Series X-A and X-B, renewed with X-C |
| SEBI fees, individual or firm | ₹2,000 application, ₹3,000 registration | ₹2,000 application, ₹3,000 registration |
| BSE body | RAASB | IAASB (BSE Limited holds both roles) |
| Client fee ceiling | ₹1,51,000 a year per family | ₹1,51,000 fixed, or 2.5% of AUA, a year per family |
| Track-specific rules | Regulation 16 trading restrictions, model portfolio rules | Risk profiling, KYC through a KRA, no trading calls under the adviser registration |
How we set up the separation
- A client agreement and MITC for each service.
- Labels on every communication saying whether it is research or advice.
- Separate records, so each compliance audit reads its own file.
Applying for the second one
The BSE application form opens by asking whether you are already a SEBI registered investment adviser and, if you are, for your registration number and BSE enlistment number. An adviser adding research registration starts there.
Note
SEBI's FAQs describe this for an individual or partnership firm. Whether one deposit can serve both registrations is not answered in the texts we cite, so we confirm it with BSE before you budget.
- 1.SEBI, FAQs on SEBI Registered Investment Advisers, 13 August 2025
- 2.SEBI circular SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/105 dated 23 July 2025, FAQs for Research Analysts
- 3.SEBI Master Circular for Investment Advisers dated 6 February 2026
- 4.SEBI Master Circular for Research Analysts, HO/38/12/11(1)2026-MIRSD-PoD/I/4360/2026 dated 6 February 2026
We handle the documentation and filing: Investment Adviser registration
Sources read on 28 October 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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