What changed for IA and RA registration on 16 December 2024
SEBI rewrote the entry requirements for both registrations in one go. Net worth is gone, a part-time category exists, and BSE now sits between you and SEBI.
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If the last time you looked at Investment Adviser or Research Analyst registration was 2023, most of what you remember about qualifying is out of date. SEBI notified amendments to both sets of regulations on 16 December 2024, and they took effect the same day. Two circulars on 8 January 2025 filled in the working detail.
Net worth was replaced by a deposit
Capital adequacy used to be the first thing that stopped people. It is no longer the test. An Investment Adviser and a Research Analyst each maintain a deposit instead, sized by how many clients they had, and SEBI states plainly that there is no capital adequacy requirement for a Research Analyst at all.
| Clients in the previous financial year | Deposit |
|---|---|
| Up to 150 | ₹1 lakh |
| 151 to 300 | ₹2 lakh |
| 301 to 1,000 | ₹5 lakh |
| 1,001 and above | ₹10 lakh |
Same slabs for Investment Advisers and Research Analysts.
The deposit sits in a scheduled bank, marked as lien in favour of IAASB for advisers or RAASB for analysts. The slab is set by the maximum number of clients on any day of the previous financial year, and you revise it by 30 April of the next year if you have crossed into a higher band. Someone starting out with a handful of clients is looking at ₹1 lakh parked in a bank account. No capital has to be raised for it.
Applications go to BSE before they reach SEBI
SEBI recognised BSE Limited as both the Investment Adviser Administration and Supervisory Body and the Research Analyst Administration and Supervisory Body. The recognition as IAASB runs for five years from 25 July 2024. You apply to the body, it assesses the application, and it recommends registration to SEBI. SEBI still grants the certificate. Registration and enforcement were never delegated.
Practically, this changes who you correspond with. Enlistment with IAASB or RAASB is its own requirement on top of SEBI registration, and the body charges its own administrative fee.
Part-time registration now exists
This is the change that opens the door widest. A part-time Investment Adviser or Research Analyst is an individual or partnership firm that also runs another business or holds another job, as long as that other work is unrelated to securities, does not involve handling client money, and does not involve advising anyone on assets for investment.
SEBI's own examples of who qualifies: a member of ICAI, ICSI or ICMAI doing statutory work, an IRDAI-licensed insurance agent, a professional such as an architect, lawyer or doctor, a professor or teacher. For the Research Analyst side, a teacher or professor also needs a no-objection certificate from the employer, and a fresh one if they change employers. The Investment Adviser circular does not carry that condition.
Note
Advising on gold, real estate or cryptocurrency as a business disqualifies you from part-time registration. SEBI names those three specifically.
Part-time registrants carry the label. The words "part-time investment adviser" or "part-time research analyst" have to appear in all client correspondence, and for advisers the registration certificate itself records the status. Invoices for the other business need a disclaimer in at least 10 point saying that work is outside SEBI's purview.
Experience is no longer a barrier for advisers
The 2020 amendment had loaded regulation 7 with enhanced qualification and experience requirements, with a transition window that ran to 30 September 2025. The Second Amendment Regulations of December 2024 removed the experience requirement and relaxed the qualification requirement. Advisers who meet the revised criteria no longer have to satisfy the 2020 version.
Note
The exact revised wording of regulation 7 is the one thing we will not paraphrase here. Plenty of commentary states a specific degree standard. We have not read that text off the amended regulations ourselves, so we do not publish it. We confirm what applies to your qualification during scoping.
You can hold both registrations
An individual or partnership firm registered as a Research Analyst can be granted Investment Adviser registration, and the reverse also works. You comply with each set of regulations and each reporting requirement separately, and you give an undertaking to keep the two activities at arm's length with the services clearly segregated.
What this adds up to
The old shape of these registrations assumed a full-time firm with capital. The new shape assumes a qualified individual who may be doing something else on Tuesday. That is a deliberate widening, and it is why the number of applications in front of BSE went up rather than the requirements getting softer. The obligations that follow registration did not get lighter at all.
- 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 circular SEBI/HO/MIRSD/MIRSD-PoD-1/P/CIR/2025/003 dated 8 January 2025, Guidelines for Investment Advisers
- 4.SEBI circular SEBI/HO/MIRSD/MIRSD-PoD-1/P/CIR/2025/004 dated 8 January 2025, Guidelines for Research Analysts
- 5.SEBI Master Circular for Investment Advisers, SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/94 dated 27 June 2025
Sources read on 5 August 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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