SEBI has introduced standardized MITC for Research Analysts (RAs) and Investment Advisers (IAs) by way of two separate circulars dated February 17, 2025. The MITC are applicable to both existing and new clients of IAs and RAs. For existing clients, IAs and RAs must communicate the MITC via email or any other preservable mode of communication by June 30, 2025. For new clients, i.e., those entering into investment advisory agreements after February 17, 2025, IAs must incorporate the MITC within the investment advisory agreement, while RAs must include the MITC in the โTerms and Conditionsโ of providing research services.
Common Terms and Conditions
The MITC for RAs and IAs contains several shared MITC which are mentioned below:
(a) Both RAs and IAs cannot execute buy/sell transactions on behalf of clients. Investors are advised not to permit them to execute trades.
(b) Both entities are subject to SEBI-mandated fee ceilings to prevent overcharging. Fees must be collected through legitimate means like bank transfers, UPI, or the Centralized Fee Collection Mechanism. Cash payments are strictly prohibited.
(c) Both RAs and IAs cannot offer fixed or assured returns, as such schemes are prohibited by law.
(d) Both entities must disclose and mitigate any potential conflicts of interest that could affect their recommendations.
(e) Both RAs and IAs are prohibited from asking for client login credentials, OTPs, or account details.
Regstreet Law Advisors Comment
It is important to note that while the MITC enhances clarity regarding the required elements in the client-IA/RA agreement, it does not impose new regulatory obligations but rather reinforces existing ones in a more explicit manner. This raises the question of whether .’s initiative is primarily aimed at improving disclosure rather than addressing broader structural issues in advisory and research services. Additionally, the effectiveness of the MITC framework will largely depend on SEBIโs enforcement measures and whether clients actively engage with the disclosures or simply view them as another procedural formality. Research Analyst Administration and Supervisory Body (RAASB) and Investment Adviser Administration and Supervisory Body (IAASB) โ both under BSE India โ must enhance their capacity to evaluate the extent and effectiveness of supervision over IAs and RAs, especially when SEBI has delegated the responsibility completely.
Copy of the aforementioned circulars are attached herewith.
Readers are welcome to provide their comments on the MITC to Regstreet Law Advisors at info@resgtreetlaw.com
Sumit Agrawal Abhineet Pange Aditi Sahu Kavish Garach