How long do SEBI research analysts and investment advisers keep records?

SEBI's January 2025 guidelines for research analysts set retention at five years. The record starts at the first interaction with a client or prospective client, wherever the conversation about the services took place, and runs to the completion of the service. Where a dispute has been raised, records stay until it is resolved, or longer if SEBI asks.

What a research analyst keeps

• Records of interactions with clients and prospective clients: documents signed by the client, telephone recordings, email from a registered address, SMS records, or any other legally verifiable record.
• The documented rationale for each research recommendation.
• The MITC disclosure and the client's consent, taken before any service or fee.
• A record of personal trading by the analysts you employ, which you monitor against the regulation 16 restrictions.
• The factsheet for any model portfolio, with each rebalancing and its rationale.

Call recording is not required where the interaction already leaves a digital footprint, such as email.

What an investment adviser keeps

• KYC done through a KYC Registration Agency.
• The completed risk profile and the client's consent to it, taken before any advice.
• The investment advisory agreement with the MITC.
• For implementation or execution services, a recording of every consent taken over the phone, with all such communication time stamped. Consent by email stands on par with a call recording.

Why it matters in September

The annual compliance audit, due within six months of the financial year end, reads these records. A file kept month by month answers the auditor quickly. A file rebuilt in August from inboxes and phones is where the gaps show.