To protect investors and make financial services more transparent, SEBI (Securities and Exchange Board of India) introduced an Updated Investor Charter on June 2, 2025, for all Investment Advisers (IAs) and Research Analysts (RAs). This updated charter replaces the old one from 2021 and tells investors what services they can expect, what their rights are, and how to raise complaints if something goes wrong. SEBI has also added new systems like SCORES 2.0 and SMART ODR to make complaint handling faster and easier. This step is meant to help investors make better decisions and trust the advice or research they receive from registered professionals.
Learn more about Deposit Requirement in place of Net Worth Certificate for RAs.
Key Additions to the Investor Charters
Below is a detailed explanation of the key additions introduced in the revised Investor Charter:
Adherence to Advertisement Code
SEBI now requires that all advertisements, promotions, or public communications issued by IAs and RAs strictly comply with the SEBI-prescribed Advertisement Code.
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This code ensures that all promotional material is truthful, not misleading, and clearly discloses the risks involved in investing.
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Misleading performance claims, unrealistic return promises, and unverified testimonials are prohibited.
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Advertisements must clearly display the SEBI registration number of the IA/RA and include appropriate disclaimers as per the regulations.
This move is aimed at curbing aggressive and deceptive marketing practices often seen across social media and digital platforms.
Non-Discrimination in Services
The revised charter explicitly states that Investment Advisers and Research Analysts must not discriminate among clients who are availing similar types of services.
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Clients seeking the same category of service (e.g., equity research or portfolio advisory) must be treated equitably, regardless of their investment size or profile.
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This provision is intended to promote fairness and consistency, especially in pricing, turnaround times, and access to insights or recommendations.
It reinforces SEBI's vision of inclusive investor servicing, where all investors large or small receive professional and unbiased treatment.
Disclosure of Use of Artificial Intelligence (AI) Tools
With the growing adoption of technology in financial services, SEBI now mandates that IAs and RAs must disclose the extent of usage of Artificial Intelligence (AI) or machine learning tools in delivering services.
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The disclosure must clarify whether AI tools are used for client profiling, risk assessment, research generation, or portfolio tracking.
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Investors must be informed how much human judgment vs automated systems contribute to the services they receive.
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This ensures that investors understand the role of AI in shaping recommendations or research insights, promoting transparency and informed consent.
Record Keeping Obligations Extended to RAs
While Investment Advisers were already required to maintain comprehensive records of all client interactions under the SEBI (Investment Advisers) Regulations, 2013, this provision is now extended to Research Analysts.
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RAs must maintain records of all communications and interactions with clients, including prospective clients even before formal onboarding.
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This includes any discussions related to research services, recommendations, or reports shared verbally or in writing.
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Records should be securely stored for a minimum period as specified under SEBI regulations, and be made available during regulatory audits or inspections.
This change enhances auditability, ensures accountability, and protects both the analyst and the investor in case of disputes or miscommunication.
Terms and Conditions for Research Services
SEBI now requires all Research Analysts to formally define and disclose the terms and conditions for their research services.
This must include:
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Scope and frequency of reports
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Charges, if any
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Mode of delivery (email, app, dashboard, etc.)
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Validity period of recommendations
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Cancellation or refund policy
These terms must be shared with the client at the time of onboarding and be part of the signed agreement.
The objective is to create a clear of deliverables, pricing, and service boundaries between the analyst and the client, thereby reducing ambiguity and potential legal disputes.
Mandatory KYC for Fee-Paying Clients of RAs
In a major compliance change, Research Analysts must now complete full KYC (Know Your Customer) processes for all fee-paying clients.
This includes:
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Collection of PAN, Aadhaar, and address proofs
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Verification of client identity and financial background
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Risk profiling, if research is customized
KYC norms must be followed as per SEBI and PMLA (Prevention of Money Laundering Act) guidelines, and records must be securely maintained.
This change ensures that only legitimate, verified individuals access paid research services, aligning RA compliance with existing IA norms and strengthening the anti-money laundering framework.
Revised Grievance Redressal Mechanism
SEBI has standardized a detailed and time-bound grievance redressal mechanism across both IAs and RAs. This involves a three-level structure:
Level 1 – Direct Resolution by IA/RA: All investor complaints must be addressed by the intermediary within 21 calendar days from the date of receipt.
Level 2 – SEBI SCORES 2.0 or Supervisory Body: If unresolved, the complaint must be escalated via:
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The SCORES 2.0 portal (SEBI’s updated complaint platform), or
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The Supervisory Body like IAASB (for IAs) or RAASB (for RAs)
These bodies will provide structured oversight and facilitate faster redressal.
Level 3 – Dispute Resolution via SMART ODR:
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For complaints still unresolved, SEBI now mandates referral to the SMART ODR (Online Dispute Resolution) platform for e-conciliation or e-arbitration.
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This ensures a completely digital, efficient, and legally binding dispute resolution process.
This addition ensures timely and effective grievance resolution, reduces dependency on courts or offline arbitration, and increases investor confidence in the regulatory system.
To get more information about How to File a Periodic Reporting for RAs with SEBI.
Compliance Requirements for IAs and RAs
Following SEBI’s revised guidelines issued on June 2, 2025, all registered Investment Advisers (IAs) and Research Analysts (RAs) are required to implement a series of mandatory compliance actions to ensure transparency, investor awareness, and regulatory accountability. These steps are non-optional and form an integral part of SEBI’s investor-first approach. Below is a detailed explanation of each compliance requirement:
Mandatory Display of Investor Charter on Website and Mobile Application
All IAs and RAs must ensure that the updated Investor Charter is clearly visible and accessible on the homepage of their official website and, if applicable, their mobile application.
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The document should be hosted in a manner that allows easy and viewing by investors or potential clients.
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The display should not be hidden within multi-layered menus or obscure links; it should be prominently placed.
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Hyperlinks or downloadable PDF formats are acceptable.
For reference and implementation, SEBI has provided downloadable formats of the updated charters:
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Download the Updated Investor Charter for Investment Advisers (IAs)
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Download the Updated Investor Charter for Research Analysts (RAs)
This requirement ensures that all users visiting the digital platforms of IAs and RAs are immediately informed of their rights and the scope of services offered.
Learn more about Post Registration Compliances for RAs.
Physical Display at Office Premises
In addition to the digital display, all registered IAs and RAs must exhibit the Investor Charter at a prominent location within their office.
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The printed copy must be easily visible to walk-in clients and visitors.
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Display boards, posters, or standees can be used, provided the content is readable and updated.
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If the intermediary has multiple branches or regional offices, this requirement applies to all client-facing premises.
This ensures that even offline clients who may not visit the website are made aware of the Charter and their rights as investors.
Mandatory Dissemination of Investor Charter to All Clients
One of the most important compliance mandates is the compulsory communication of the updated Investor Charter to all clients, whether existing or newly onboarded.
For Existing Clients:
The updated Investor Charter must be shared through one of the following methods:
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Email communication, either as:
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A direct attachment (PDF format)
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A hyperlink directing the client to the Charter on the official website
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Alternatively, a physical copy may be delivered or made available upon request.
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There is no requirement to use a letterhead while sharing the charter standard PDF or printed formats are acceptable.
For New Clients:
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The Investor Charter must form a part of the onboarding process.
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It should be included as an annexure to the client agreement or shared as a standalone document during the registration process.
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The charter must be presented before or at the time of signing the client agreement, ensuring full disclosure and understanding from the beginning of the engagement.
This requirement aligns with SEBI’s objective of pre-contractual transparency, ensuring that clients know what services to expect, how to raise complaints, and what obligations they and the intermediary hold.
Summary of IA/RA Charter Compliance Checklist
Compliance Action |
Required For |
Mode of Fulfilment |
Display on website and app |
All IAs & RAs |
Homepage placement; downloadable PDF or hyperlink |
Display in office premises |
All IAs & RAs |
Printed copy at reception or visible wall location |
Communication to existing clients |
All IAs & RAs |
Via email (attachment or link) or physical handout |
Inclusion for new client onboarding |
All IAs & RAs |
Part of onboarding pack or as annexure to client agreement |
Use of official letterhead |
Not required |
Plain document format is sufficient for circulation |
To Summarize
The updated Investor Charter introduced by SEBI on June 2, 2025, marks a significant advancement in investor protection and service transparency for Investment Advisers (IAs) and Research Analysts (RAs). With new provisions like adherence to the Advertisement Code, fair treatment of clients, AI usage disclosures, mandatory KYC for fee-paying clients, and extended record-keeping for RAs, SEBI has strengthened regulatory oversight and investor trust. The structured grievance redressal system via SCORES 2.0 and SMART ODR ensures timely, digital, and effective resolution of investor complaints. Mandatory display of the charter on websites, apps, and office premises, along with compulsory dissemination during client onboarding, further reinforces investor awareness and rights. These reforms aim to create a transparent, ethical, and compliant ecosystem in the financial advisory and research domain. By aligning practices with investor interests, SEBI empowers investors to make informed decisions and ensures that intermediaries uphold the highest standards of professionalism and accountability.
Frequently Asked Questions (FAQs)
Q1. What is the Investor Charter issued by SEBI?
Ans. The Investor Charter is a SEBI-mandated document that outlines the rights, responsibilities, services offered, and grievance redressal mechanisms available to investors engaging with SEBI-registered Investment Advisers (IAs) and Research Analysts (RAs).
Q2. When was the updated Investor Charter released?
Ans. The updated Investor Charter was released by SEBI on June 2, 2025, replacing the previous version issued in 2021. It applies to all registered IAs and RAs.
Q3. What are the key changes introduced in the 2025 update?
Ans. Major additions include:
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Compliance with SEBI’s Advertisement Code
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Non-discriminatory service for similar clients
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Disclosure of AI tool usage
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Record-keeping for RAs (extended from IAs)
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Mandatory KYC for fee-paying RA clients
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Structured three-tier grievance redressal via SCORES 2.0 and SMART ODR
Q4. What is the purpose of the updated Investor Charter?
Ans. The Charter ensures transparency, investor education, and accountability. It informs investors about the nature of services, their rights, and how they can resolve complaints efficiently.
Q5. Do IAs and RAs need to share the Investor Charter with clients?
Ans. Yes. SEBI mandates that IAs and RAs must share the updated Investor Charter with all clients both existing and new either through email, physical handouts, or as part of the onboarding process.
Q6. Is the Investor Charter required to be displayed publicly?
Ans. Yes. IAs and RAs must display the Investor Charter on their website, mobile app (if applicable), and at a prominent place in their office premises.
Q7. What is SCORES 2.0 and SMART ODR?
Ans. SCORES 2.0 is SEBI’s enhanced online platform for investors to file and track complaints.
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SMART ODR is a digital platform for e-conciliation and e-arbitration, used when complaints are not resolved via SCORES.
Q8. What is the penalty for non-compliance with the Investor Charter?
Ans. Non-compliance may lead to regulatory action, including fines, suspension, or cancellation of registration under SEBI (IA) or (RA) Regulations, 2013/2014.
Q9. Are RAs now required to complete KYC like IAs?
Ans. Yes. All fee-paying clients of RAs must undergo KYC as per SEBI and PMLA guidelines. This includes identity verification and risk profiling.
Q10. Why is the disclosure of AI tools important under the new charter?
Ans. It helps investors understand how much of the advice or research is automated versus human-driven, ensuring informed consent and greater transparency in service delivery.