Description
SEBI has issued the second amendment to the Research Analysts Regulations, 2014, modifying qualification requirements and certification processes for research analysts and related personnel.
Summary
SEBI has notified the Securities and Exchange Board of India (Research Analysts) (Second Amendment) Regulations, 2025, dated November 25, 2025, under File No. SEBI/LAD-NRO/GN/2025/277. These amendments modify Regulation 7 and Schedule I (Form-A) of the SEBI (Research Analysts) Regulations, 2014, introducing changes to qualification requirements, certification processes, and recertification timelines for research analysts and associated personnel.
Key Points
- Amendment effective from the date of publication in the Official Gazette (November 25, 2025)
- Expands scope to include “persons associated with research services” in qualification requirements
- Introduces two alternative qualification pathways for research analysts
- Modified certification requirements from NISM or NISM-recognized institutions
- Removes previous sub-regulation (2) of Regulation 7
- Establishes recertification requirements within three years of registration
- Changes application submission process to SEBI-recognized supervising bodies
Regulatory Changes
Regulation 7 Amendments:
Sub-regulation (1) modifications:
- Added “persons associated with research services” alongside research analysts and partners to qualification requirements
- Replaced clauses (i) and (ii) with new alternative qualification pathways:
Option (a):
- Graduate degree or equivalent from university/institution recognized by Central/State Government or foreign recognized university/institution/association
- PLUS CFA Charter from CFA Institute
- PLUS relevant certificate from National Institute of Securities Markets (NISM) or NISM-recognized organization/institution
Option (b):
- Post Graduate Program in Securities Market (Research Analysis) from NISM
- OR any other program specified by SEBI from NISM
Sub-regulation (2): Deleted entirely
Sub-regulation (3) replaced with:
- Individual research analysts registered under these regulations
- Principal officers of non-individual research analysts
- Persons appointed as research analysts
- Persons associated with research services
- Partners of partnership firms (engaged in providing research services)
All above categories must obtain/re-obtain relevant NISM certificate as specified by SEBI within:
- Validity period of existing certificate expires, OR
- Three years from date of registration certificate grant
This ensures continuous compliance with certification requirements.
Schedule I (Form-A) Amendments:
Instruction-2 modifications:
- Application submission changed from “principal office of the Board in Mumbai” to “body or body corporate recognized by SEBI for supervision of research analysts”
- If no such recognized body exists, then submit to the Board
- Requires submission with all necessary supporting documents
Compliance Requirements
For Registered Research Analysts:
- Individual research analysts must comply with revised qualification requirements
- Obtain NISM certification as per new framework
- Complete recertification within three years of registration or before existing certificate expiry
- Ensure continuous validity of certification
For Non-Individual Research Analyst Firms:
- Principal officers must meet qualification requirements
- All appointed research analysts must obtain required NISM certificates
- Partners engaged in research services (for partnership firms) must be certified
- Persons associated with research services must meet qualification standards
For New Applicants:
- Submit applications to SEBI-recognized supervising body/body corporate
- If no recognized body exists, submit directly to SEBI
- Choose appropriate qualification pathway (Option a or b)
- Provide all necessary supporting documents
Important Dates
- Notification Date: November 25, 2025
- Effective Date: November 25, 2025 (date of gazette publication)
- Recertification Deadline: Within 3 years of registration certificate grant OR before existing certificate validity expires (whichever is earlier)
- Gazette Reference: CG-MH-E-25112025-267960, No. 766, Tuesday, November 25, 2025/Agrahayana 4, 1947
Impact Assessment
Industry Impact:
- High regulatory significance: All registered research analysts and firms must review compliance with revised qualification framework
- Broader coverage: Extension to “persons associated with research services” significantly expands the universe of individuals requiring certification
- Operational changes: Research analyst firms must ensure all relevant personnel obtain appropriate NISM certifications
- Timeline pressure: Three-year recertification window requires planning for compliance
Market Impact:
- Enhanced professionalization of research analyst ecosystem
- Potential improvement in quality standards for research services
- May require industry participants to invest in training and certification programs
- Introduction of alternative qualification pathways (CFA Charter route) may attract internationally qualified professionals
Compliance Burden:
- Moderate to high for firms with multiple research personnel
- Ongoing recertification requirements create perpetual compliance obligations
- Application process changes require familiarization with new SEBI-recognized supervising bodies
Key Considerations:
- Firms should immediately audit current personnel against new qualification requirements
- Identify gaps and create certification roadmap for compliance within three-year window
- Monitor SEBI notifications for recognition of supervising bodies for application submissions
- Budget for NISM certification/recertification costs for relevant personnel
Impact Justification
Significant regulatory amendment affecting all registered research analysts and firms, introducing revised qualification criteria and certification requirements with immediate effect from gazette publication date.