Somebody who writes memos and shows them to other people has crossed from being an investor to being a publisher, and India regulates publishers of securities research directly.
The SEBI (Research Analysts) Regulations, 2014 define a research analyst as a person primarily responsible for preparing or publishing the content of a research report, or for providing one, or for making a buy, sell or hold recommendation, or for giving a price target, or for offering an opinion on a public offer. A research report is a written or electronic communication containing research analysis, a recommendation or an opinion on securities that provides a basis for an investment decision. General commentary on market trends, broad economic or political conditions and purely internal communications sit outside the definition. Registration under Regulation 3 follows from being within it.
What obligations bind a registered research analyst?
Five operative obligations bind a registered analyst, and they are the ones a learner who starts publishing will meet first.
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The first is disclosure on every report. Regulation 19 requires a defined set of items in the report itself, and that list is the substance of the regime rather than a formality attached to it. Any financial interest of the analyst or the analyst's relatives in the subject company. Actual or beneficial ownership of one percent or more of its securities at the end of the month preceding publication. Any other material conflict. Compensation received from the subject company in the previous twelve months, and separately whether the analyst or an associate managed or co-managed a public offering or took investment banking, merchant banking or brokerage compensation. Whether the analyst has been an officer, director or employee of the subject company. And whether there has been market-making activity in the security.
Two of those carry thresholds and the rest do not, which is the distinction people get wrong. Beneficial ownership is disclosed at one percent and above. Financial interest is disclosed at any size. An analyst holding 62,000 shares of a company with 55,00,000 outstanding holds 1.127273 percent and discloses under both heads; one holding 5,000 shares of the same company holds 0.09 percent, is below the ownership threshold, and still discloses the financial interest.
The second is the trading blackout. Regulation 16 prohibits dealing in securities the analyst recommends or follows within thirty days before and five days after publication. For a report published on 18 March 2026 that is a closed period from 16 February to 23 March, 36 calendar days inclusive. It is the provision most likely to catch somebody who has been publishing informally and then registers.
The third is the prohibition on trading against a live recommendation. Regulation 16 separately forbids dealing, directly or indirectly, in a manner contrary to the recommendation given. A live BUY with a ₹640 target against a market price of ₹512, implying 25.00 percent upside, is a public statement, and selling into it is the breach whether or not the sale is profitable.
The fourth and fifth are certification and record-keeping. Analysts must hold the applicable NISM certification and keep records of the basis for every recommendation, so a report can be reconstructed later.
Verify the current certification requirement, the deposit and net-worth conditions and the supervisory arrangements at sebi.gov.in, checked 7 September 2026. The regime was substantially amended with effect from 2025, including administration of registration through an exchange-hosted supervisory body.
How does it differ from the investment adviser regime?
The investment adviser regime sits beside it and answers a different question. The SEBI (Investment Advisers) Regulations, 2013 catch a person who, for consideration, is engaged in the business of providing investment advice to clients, which is a personalised relationship rather than a publication. They expressly exclude advice given through a newspaper, magazine or electronic or broadcasting medium that is widely available to the public. The dividing question, then, is whether the output is a publication or a relationship. Verify the current wording of the definition and its proviso at sebi.gov.in, checked 7 September 2026.