Description

BSE advises Investment Advisers to review and revise their SEBI-mandated deposit requirements based on the maximum number of clients serviced on any single day during F.Y. 2025-26, with revised deposits due by April 30, 2026.

Summary

BSE has issued a notice directing all registered Investment Advisers (IAs) to review their existing deposit obligations under Regulation 8 of the SEBI IA Regulations. Based on the maximum number of clients serviced on any single day during F.Y. 2025-26, IAs must calculate any shortfall in their deposit and submit the additional amount in the same form as their existing deposit (Fixed Deposit or liquid/overnight mutual funds) on or before April 30, 2026.

Key Points

  • IAs must determine the maximum number of clients serviced on any single day during F.Y. 2025-26 to assess their deposit requirement.
  • Deposits must be maintained in a single form only — either Fixed Deposit (FD) or liquid/overnight mutual funds (Non-Demat or Demat); additional deposits must match the form of earlier deposits.
  • Deposit slabs: Up to 150 clients → ₹1 lakh; 151–300 clients → ₹2 lakh; 301–1,000 clients → ₹5 lakh; 1,001+ clients → ₹10 lakh.
  • An illustrative example is provided: an IA with up to 150 clients (deposit ₹1 lakh) that serviced 250 clients on peak day must submit an additional ₹1 lakh to meet the ₹2 lakh requirement.
  • Submission procedures differ by deposit type: FD requires physical documents at BSE regional/head office; Non-Demat MF requires email to ia.membership@bseindia.com with SOA; Demat MF requires a pledge request through the Depository Participant.

Regulatory Changes

No new regulations have been introduced. This notice operationalizes the existing provision 1(iv) of the SEBI Master Circular for Investment Advisers (Ref: HO/38/12/11(2)2026-MIRSD-POD/I/4300/2026 dated February 06, 2026), which mandates annual review and revision of deposit amounts based on peak client numbers from the preceding financial year.

Compliance Requirements

  • Review: Identify the maximum number of clients serviced on any single day in F.Y. 2025-26.
  • Calculate shortfall: Compare current deposit held with the applicable slab based on peak client count.
  • Submit additional deposit (if applicable) in the same form as the existing deposit:
    • Fixed Deposit: Submit covering letter (Annexure-I), bank covering letter (Annexure-II), and original FDR (duly discharged with ₹1 revenue stamp) to BSE regional/head office.
    • Liquid/Overnight MF (Non-Demat): Email covering letter (Annexure-III) and SOA to ia.membership@bseindia.com with subject “Request for creation of lien in favor of BSE Limited – towards additional deposit”.
    • Liquid/Overnight MF (Demat): Raise a pledge request through the Depository Participant (Annexure-IV).

Important Dates

  • April 30, 2026: Deadline for submission of revised/additional deposit by all Investment Advisers.

Impact Assessment

This circular has a moderate operational impact limited to BSE-registered Investment Advisers. IAs whose client base grew significantly during F.Y. 2025-26 — particularly those crossing the 150, 300, or 1,000 client thresholds — will need to arrange and submit additional funds. The requirement is administrative and financial in nature, with no direct impact on trading, listed securities, or broader market operations. Non-compliance could result in regulatory action against the IA’s membership status.

Impact Justification

Routine annual compliance requirement for Investment Advisers to review and top up deposits per SEBI IA Regulations; affects only registered IAs on BSE, not broader market participants.