What is the client level segregation certificate for SEBI investment advisers and research analysts?
A yearly certificate from a member of ICAI, ICSI or ICMAI (or your auditor) confirming that no client received both your advice or research and distribution services from you or your family. You obtain it within six months of the financial year end, by 30 September, and it forms part of the compliance audit.
Want this checked against your own position? We handle the documentation and the filing.
The certificate tests one rule. An individual investment adviser may not distribute (regulation 22 of the IA Regulations), and neither may an individual research analyst (regulation 26C of the RA Regulations). Their family may not distribute to the clients they advise or research for, and they may not take on a client whom the family already serves as a distributor. A company or LLP keeps the same separation across its group.
The family of an individual investment adviser shall not provide distribution services to the client advised by the individual investment adviser and no individual investment adviser shall provide advice to a client who is receiving distribution services from other family members.
Who signs it and when
| Point | Rule |
|---|---|
| Signed by | A member of ICAI, ICSI or ICMAI, or an auditor. For a non-individual research analyst, the statutory auditor |
| Due | Within six months of the financial year end, which is 30 September for a 31 March year |
| Where it goes | It forms part of the annual compliance audit |
| First year | The financial year ending 31 March 2025 |
What the certifier checks
- Your client list, with the PAN of each client. SEBI's master circulars make the PAN the control record for segregation.
- That no client is also taking distribution services from you or your family. For a research analyst, family means you, your spouse, children and parents (regulation 2(1)(fb)).
- That existing clients have not switched sides inside the family.
- For a company or LLP, that the separation holds across its group.
Stock broking is not distribution for this rule, as both master circulars state. An adviser or analyst who serves only institutional clients and accredited investors may be outside the segregation requirements, provided each client signs SEBI's standard waiver.
Why it is a separate document
The compliance audit covers the whole of the regulations. The segregation certificate is a narrower sign-off on one rule, obtained separately and then filed with the audit. The master circulars we read do not stop one professional doing both. We keep the person who prepares your records apart from the person who certifies them.
The certificate is due by the same 30 September date as the audit. See the annual compliance audit and the annual compliance certificate.
- 1.SEBI (Investment Advisers) Regulations, 2013, consolidated text as amended up to 25 November 2025 (latest amendment notification SEBI/LAD-NRO/GN/2025/278)
- 2.SEBI (Research Analysts) Regulations, 2014, consolidated text as amended up to 10 October 2026 (latest amendment notification SEBI/LAD-NRO/GN/2026/321)
- 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: Client-segregation certificate
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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