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No, once the change takes effect. SEBI's circular of 23 October 2026 says the requirement to keep call recordings for clients that are institutional investors "shall not be mandatory" from 8 November 2026. The matching amendment to the Research Analysts Regulations, 2014 comes into force on 9 November 2026. Retail and other non-institutional clients are untouched: you still keep a record of every conversation with them about your services, from the first contact.
This post covers two instruments together. The RA (Amendment) Regulations, 2026, notified on 8 October and listed by SEBI on 10 October 2026, change only what concerns call recordings, so this post also covers everything that changed in the RA Regulations.
8 Nov 2026
Circular takes effect
9 Nov 2026
Regulation amendment in force
5 years
How long records are kept
What the RA Regulations amendment says
The Securities and Exchange Board of India (Research Analysts) (Amendment) Regulations, 2026 (F. No. SEBI/LAD-NRO/GN/2026/321) do two things. They add a definition of "institutional investor" as regulation 2(1)(ia), borrowed from the ICDR Regulations. And they add a proviso to regulation 25(1)(vii), the clause that lists records of communication.
Legal extract
Provided that the requirement to maintain call recordings of communications with clients which are institutional investors shall not be mandatory.
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Source: Regulation 25(1)(vii), proviso, inserted by the RA (Amendment) Regulations, 2026, reg 3(II)(b)
The amendment also drops the word "etc." from regulation 25(1)(vii). SEBI's consolidated text now reads "records of communication including emails, call recordings with all clients including prospective clients in such manner as may be specified", followed by the proviso. The consolidated text, "Amended upto October 10, 2026", gives the date in force as 9 November 2026 in its footnotes. The notification itself says the amendment comes into force on the thirtieth day after publication in the Gazette.
Who counts as an institutional investor
The new regulation 2(1)(ia) points to clause (y) of regulation 2(1) of the SEBI (Issue of Capital and Disclosure Requirements) Regulations, 2018. In the ICDR text consolidated to 21 March 2026, that clause reads:
Legal extract
"institutional investor" means (i) qualified institutional buyer; or (ii) family trust or intermediaries registered with the Board, with net worth of more than five hundred crore rupees, as per the last audited financial statements, for the purposes of listing and/or trading on innovators growth platform in terms of Chapter X;
Source: SEBI (ICDR) Regulations, 2018, regulation 2(1)(y)
Our reading: a client you serve that is a qualified institutional buyer under the ICDR Regulations is an institutional investor for this relief. The second limb covers family trusts and SEBI-registered intermediaries with net worth above Rs 500 crore on their last audited accounts. That limb carries ICDR wording about the innovators growth platform, and the RA amendment does not say how that wording applies to research services. Until SEBI or RAASB clarifies it, we would treat only clear QIB clients as covered and keep recording the rest.
What the 23 October 2026 circular says
Circular HO/38/11/(9)2026-MIRSD-POD/I/24272/2026 rewrites paragraph 1.13 of the Master Circular for Research Analysts of 6 February 2026 and the answer to FAQ 33(iii). The new paragraph 1.13(b)(i) keeps the same list of acceptable records and adds the same proviso as the regulation.
Legal extract
RA shall maintain records of interactions, with all clients including prospective clients (prior to onboarding), where any conversation related to its services has taken place, inter-alia, in the form of: (a) Physical record written and signed by client; (b) Call recordings; (c) Email from registered email id; (d) Record of SMS messages; (e) Any other legally verifiable record.
Source: Circular dated 23 October 2026, para 4.1, new Master Circular para 1.13(b)(i)
The records start with the first interaction and run until the research service to that client ends. You keep them for five years, or longer if a dispute is open or SEBI asks you to preserve them (new para 1.13(b)(ii) and (iii)). Paragraph 6 of the circular sets the start date: "The provisions of this circular shall come into effect from November 08, 2026."
Legal extract
For the purpose of abundant clarity, it is to be stated that call recording is not required if the interaction with client is made through means such as email, etc. for which digital footprint is available.
Source: Circular dated 23 October 2026, para 4.2, new answer to Master Circular FAQ 33(iii)
What this means for an individual RA
Until 7 November 2026
✕Call recordings are one of the listed forms of record for every client, including institutional clients
✕No defined term "institutional investor" in the RA Regulations
From 8 and 9 November 2026
✓Call recordings optional for clients that are institutional investors
✓Retail and other clients: every service conversation still on record, from the first contact
✓Email or other digital trail still counts as the record, for any client
✓Five-year retention unchanged
For an RA whose clients are retail subscribers, nothing changes. The relief matters to an RA or research entity whose clients include qualified institutional buyers.
Two practical points from our reading. The proviso makes call recordings optional; it does not remove the duty to keep a record of the interaction. If you stop recording calls with an institutional client, keep a written trail instead, such as an email from your registered ID after each call. And you will need to show, at audit or inspection, why a client was treated as institutional. A note on file with the client's QIB status and the document you relied on covers that.
List your current clients and mark which are institutional investors under ICDR reg 2(1)(y)
Keep the evidence of each one's status on the client file
Update your record-keeping policy to quote the new para 1.13 and the date 8 November 2026
For institutional clients you stop recording, follow each call with an email from your registered email ID
Leave call recording on for every retail and non-institutional client
Questions RAs ask about this change
No. Both instruments are addressed to research analysts and research entities. The circular is addressed to "All registered Research Analysts" and RAASB, and the amendment changes only the RA Regulations, 2014.
This page is our reading of the SEBI text as it stood on 29 October 2026. BuildWright provides documentation, filing and compliance facilitation for SEBI research analysts and investment advisers.
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