Using AI tools as a SEBI adviser or research analyst: what you must disclose
You are solely responsible for client data and for advice based on AI output, and you disclose the extent of AI use to the client.
Want this checked against your own position? We handle the documentation and the filing.
A SEBI investment adviser or research analyst using AI tools is solely responsible for the security, confidentiality and integrity of client data and for advice based on AI output. You must also disclose the extent of your AI use to the client.
The regulations behind each duty
| Duty | Investment adviser | Research analyst |
|---|---|---|
| Sole responsibility for data and AI-based advice | Regulation 15(14) | Regulation 24(7) |
| Disclose the extent of AI use to the client | Regulation 18(9) | Regulation 19(vii) |
What this means in practice
- A tool vendor's error is your error. The responsibility sits with the registrant.
- Client data pasted into a chatbot is client data you are answerable for.
- The client is told how far AI went into the advice or research, in terms that match what you actually do.
- Clients who were already on your books were to be covered by 30 April 2025.
Writing the disclosure
SEBI asks for the extent of use, so a line saying you use AI does not meet it. Say which tasks use it, such as screening, drafting or summarising, and which stay with a person. If you use none, say that, and revisit the line when your tools change.
Note
SEBI's text we have read does not give a prescribed wording or a fixed place for the disclosure. We draft it to fit your workflow and place it in the client agreement and on your website.
- 1.SEBI Master Circular for Investment Advisers, SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/94 dated 27 June 2025
- 2.SEBI Master Circular for Research Analysts, HO/38/12/11(1)2026-MIRSD-PoD/I/4360/2026 dated 6 February 2026
- 3.SEBI circular SEBI/HO/MIRSD/MIRSD-PoD-1/P/CIR/2025/004 dated 8 January 2025, Guidelines for Research Analysts
- 4.SEBI circular SEBI/HO/MIRSD/MIRSD-PoD-1/P/CIR/2025/003 dated 8 January 2025, Guidelines for Investment Advisers
We handle the documentation and filing: Compliant website for advisers
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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