SEBI relaxes call-recording duty for research analysts dealing with institutional clients

On 23 October 2026, the Securities and Exchange Board of India issued a circular amending Regulation 25(1)(vii) of the SEBI (Research Analysts) Regulations, 2014, which obliges every registered Research Analyst (RA) and Research Entity (RE) to maintain records of their interactions with clients, including call recordings. The amendment relaxes this duty for one category of client: RAs and REs are no longer required to maintain call recordings of interactions with clients that are institutional investors. For all other clients, fee-paying and non-fee-paying alike, the circular keeps the existing requirement to record interactions in some verifiable form, such as a signed physical record, a call recording, registered email, an SMS record, or any other legally verifiable record, and clarifies that call recording is unnecessary wherever the interaction already leaves a digital footprint, such as email.

SEBI replaced the relevant paragraph of its Master Circular for Research Analysts dated 6 February 2026 and the corresponding FAQ to reflect the change. Records of client interaction, whatever form they take, must still be preserved for five years, longer if a dispute arises or SEBI directs continued preservation. SEBI issued the amendment citing representations from market participants and its ongoing effort to ease compliance burdens for intermediaries without diluting investor-grievance safeguards.