SEBI ends mandatory call recording for analysts' institutional clients
From 8 November 2026 research analysts need not record calls with institutional clients, but other interaction records and five-year retention stay.
From 8 November 2026, research analysts registered with SEBI will no longer have to record phone calls with clients that are institutional investors. A circular dated 23 October 2026 says call recordings for those clients "shall not be mandatory". Every other client, including retail investors and people being pitched before they sign up, is still covered by the record-keeping rule, and the five-year retention period is unchanged. For small research firms and for the funds and banks that buy their work, the change removes a costly routine but leaves a gap that firms must fill with some other record.
What the circular changes
The circular, numbered HO/38/11/(9)2026-MIRSD-POD/I/24272/2026, is addressed to all registered research analysts and to the Research Analysts Administration and Supervisory Body (RAASB), the industry body that supervises them. It explains that SEBI has already notified an amendment to Regulation 25(1)(vii) of the Research Analysts Regulations, 2014, which had required analysts to keep records of communication, including call recordings. SEBI says it acted on representations from market participants and as part of its "ease of doing business" effort.
The circular then rewrites two parts of the Master Circular for Research Analysts dated 6 February 2026. Paragraph 1.13 now lists the kinds of record an analyst may keep of interactions with any client, including a prospect before onboarding, where a conversation about the service took place:
- a physical record written and signed by the client;
- a call recording;
- an email from the client's registered email address;
- a record of SMS messages; or
- any other legally verifiable record.
A proviso then says that call recordings for institutional investors are not mandatory. The same proviso is added to an answer in the master circular's frequently-asked-questions annexure. All other provisions stay as they were, and the circular comes into effect on 8 November 2026. The RAASB must amend its bye-laws and rules and tell registered analysts.
Why recording was a burden, and why it exists
Research analysts, in SEBI's regime, are people and firms that publish views on securities for a fee. The regulator wants a trail of what was said to clients so that a complaint, say that a client was promised a return, can be checked against evidence rather than memory. The circular itself states the purpose: to document client interactions "to cater to potential client grievances" about research services.
For retail clients the logic is easy to see. They may be less able to judge a pitch, and a recording protects both sides. For institutions the picture is different. A mutual fund or insurer buying research typically has its own compliance staff, and talks to the analyst on lines that are often already recorded on the institution's side. The law firm Sansa Legal, summarising the change, says record keeping had been one of the obligations analysts found hardest to run. The firm does not quote SEBI on its reasons, and neither does the circular beyond the "representations" and ease-of-business wording. A consultation on the idea ran from 18 May 2026, according to secondary coverage we could not independently open, which would make the gap between consultation and circular about 158 days.
What stays the same
It is easy to read "optional" as "gone". The circular does not do that. Four things remain.
First, the duty to keep records of interactions with all clients, institutional or not, continues, and it includes prospects before onboarding and non-fee-paying clients who receive research as a value-added service. Second, the records must begin with the first interaction and continue until the research service is complete. Third, the retention period is five years, extended until a dispute is resolved if one is raised, or until further intimation from SEBI if it asks for specific records to be preserved. Fourth, call recording is not required where the interaction happens through email or another channel with a digital footprint.
The practical result, as Sansa Legal points out, is that a firm that stops recording institutional calls must still produce some permitted record of each interaction. A short written confirmation sent from a registered email address after the call is the example it gives. The circular does not itself define "institutional investor", so firms will need to apply the definitions in the existing research analyst rules and master circular. The Sansa article also does not define the term, and we have not checked it beyond that.
A closer look at what counts as a record
The list in the new paragraph 1.13 is wide on purpose. A signed paper note, a call recording, an email from a registered address, a text message log or "any other legally verifiable record" all qualify. The test is whether the record can later be checked by a third party, such as SEBI or a client's complaint handler. A diary entry written by the analyst alone is unlikely to meet it, while an email that the client can confirm receiving is much stronger. The circular also says non-fee-paying clients, meaning people who get research as an extra with another paid service, fall under the same record-keeping duty as fee-paying ones.
What it means for analysts and their clients
For a small research entity serving a handful of funds, the saving is real. Recording, storing and searching calls for five years takes software, storage and staff time. Dropping the requirement for the institutional side frees up that effort, though firms that serve both institutional and retail clients may find it simpler to keep one recording system for everyone.
The risk shifts to documentation habits. A call that ends with no email or note is, for compliance purposes, not a record. An analyst who talks to a fund manager on Monday and has nothing in writing may find in a dispute that nothing proves what was said. That cuts both ways: institutions lose a neutral recording they might have wanted if a view later proved costly.
Firms should map clients into institutional and non-institutional groups, decide what record each type of interaction will produce, and check that their systems can hold records for at least five years. Sansa Legal also warns that deleting a record on its fifth anniversary without checking for a dispute or a SEBI hold could itself be a breach. Nothing here is legal advice, and firms should read the circular and take professional counsel.
Use the simulator below to see how much storage a five-year call archive might need for the institutional side of a small firm. The inputs are examples to change, not figures from SEBI.
What to watch next
The circular takes effect on 8 November 2026, so the first test is how analysts change their processes that week and whether the RAASB issues its own amendments to bye-laws as the circular directs. Watch for any SEBI clarification on the definition of an institutional client, and for inspection findings later on whether firms replaced recordings with usable alternative records.
Key takeaways
- SEBI's circular of 23 October 2026 makes call recording for institutional investor clients non-mandatory for research analysts from 8 November 2026.
- Analysts must still keep records of interactions with all other clients, including prospects, and keep them for five years or until any dispute is resolved.
- A call that leaves no written or digital record does not count as a record, so firms need a replacement such as an email confirmation.
- The change follows an amendment to Regulation 25(1)(vii) of the Research Analysts Regulations, 2014, and industry representations.
- The circular does not define an institutional investor, so firms must check the existing definitions.
Sources
- [SEBI: Circular on review of regulatory requirement for maintenance of call records of institutional clients by Research Analysts, 23 October 2026](https://www.sebi.gov.in/sebidata/attachdocs/oct-2026/1792753022042.pdf)
- [Sansa Legal: SEBI makes call recording optional for research analysts' institutional clients from November 8](https://www.sansalegal.com/post/sebi-makes-call-recording-optional-for-research-analysts-institutional-clients-from-november-8)
Tags: SEBI Research analysts Regulation Compliance Investor protection