SEBI Notified Regarding the Periodic Reporting for Research Analysts

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Periodic reporting is an important part of the regulatory framework for Research Analysts (RAs) and proxy advisors (PAs). The Securities and Exchange Board of India (SEBI) has introduced a standardized format to ensure timely and accurate reporting by these professionals. This measure enhances transparency, accountability, and efficient communication between research analysts, proxy advisors, and regulatory bodies. In this article, we will break down all the details related to periodic reporting for research analysts and proxy advisors, including deadlines, submission formats, and requirements. Additionally, we’ll provide clear answers to frequently asked questions to help you understand this process better.

What is Periodic Reporting for Research Analysts?

Periodic reporting refers to the submission of data and information by research analysts and proxy advisors at regular intervals. SEBI has made it mandatory for research analysts to submit half-yearly reports to the Research Analyst Administration and Supervisory Body (RAASB), managed by BSE Ltd., and for proxy advisors to submit their reports directly to SEBI.

These reports aim to ensure that RAs and PAs remain transparent about their operations, client engagements, and compliance with SEBI regulations. This framework helps regulatory bodies monitor the activities of these professionals efficiently.

Key Details About SEBI’s Standardized Reporting Framework

Reporting Period and Due Dates

The reports must be submitted on a half-yearly basis. The first reporting period is for the half-year ending March 31, 2025. The due date for submission is April 30, 2025.

Subsequent reports will also follow the same structure:

-Half-year ending September 30 – Reports due by October 30

-Half-year ending March 31 – Reports due by April 30

This six-month preparatory period allows research analysts and proxy advisors to make necessary arrangements for data collection and submission.

Who Needs to Submit the Report?

-Research Analysts (RAs): Submit their periodic reports to RAASB through the BSE Ltd. portal.

-Proxy Advisors (PAs): Submit their periodic reports directly to SEBI.

It is important to note that all research analysts, whether individual or non-individual entities, are required to comply with this periodic reporting requirement.

Format for Submission

SEBI has specified a standard reporting format in Annexure I of its circular. Research analysts need to log in to the BSE Ltd. portal (RAASB) to download the latest reporting format.

The format covers:

-Registration details

-Official website and social media handles

-Advertisements issued

-Bank accounts used for fee collection

-Shareholding patterns

-Details of directors or partners

-Complaints received

-Non-resident client details

Where to Submit the Reports?

-Research Analysts (RAs): Submit reports to RAASB using the BSE portal.

-Proxy Advisors (PAs): Submit reports directly to SEBI.

The BSE will provide additional instructions through future circulars, so RAs should stay updated with any changes.

Special Note on Non-Resident Clients

Research analysts are required to include details of non-resident clients in their periodic reports. It is advisable to start collecting this information now to avoid any delays or errors during the submission period.

However, if research services are provided free of charge as a value-added service alongside stockbroking, PMS, or other services, client details do not need to be submitted.

SEBI’s Guidance for Non-Individual Investment Advisers

In a separate development, SEBI has allowed non-individual investment advisers to obtain an annual compliance certificate for client-level segregation from any auditor. This step promotes ease of doing business and ensures that investment advisers comply with client segregation norms.

For periodic reporting, Investment Advisers (IAs) also need to submit their half-yearly reports within 30 days from the end of the reporting period.

Why is Periodic Reporting Important?

1. Transparency: Periodic reporting ensures that RAs and PAs provide clear, accurate, and timely information to regulatory authorities.

2. Accountability: It holds research analysts responsible for their activities, ensuring compliance with SEBI guidelines.

3. Efficient Monitoring: Regulators can efficiently track operations, complaints, and financial activities of RAs and PAs.

4. Improved Trust: By maintaining transparency, RAs and PAs can build trust with clients, stakeholders, and regulators.

How to Prepare for the First Reporting?

1. Download the Format: Log in to the BSE portal and download the latest reporting format from Annexure I.

2. Collect Data: Start gathering required data, such as client information, bank details, complaints, and advertisements.

3. Organize Non-Resident Client Data: Ensure all non-resident client details are updated as required by Table-3 of Annexure I.

4. Verify Information: Double-check all details for accuracy before submission.

5. Prepare for Future Updates: Stay informed about any additional requirements or changes from BSE or SEBI.

Common Challenges in Periodic Reporting

1. Data Collection: Gathering accurate and complete information, especially for non-resident clients, can be time-consuming.

2. Format Compliance: Ensuring the report aligns with the SEBI-specified format requires attention to detail.

3. Deadlines: Missing submission deadlines can lead to penalties or non-compliance issues.

4. System Issues: Learning to navigate the BSE portal or addressing any technical issues can be challenging for first-time users.

Conclusion

SEBI’s introduction of a standardized format for periodic reporting ensures that research analysts and proxy advisors maintain transparency and accountability. With clear deadlines, structured formats, and specific requirements, this framework promotes efficient regulation and enhances trust among stakeholders.

By preparing in advance, gathering all necessary data, and following SEBI’s guidelines, research analysts can ensure smooth and timely submission of their reports. Staying organized and up to date is key to avoiding compliance issues.

If you need help in complying with the periodic reporting requirement, please send an email to info@ccoffice.in or WhatsApp/Call us at +91 9988424211. 

FAQs

1. What are the due dates for periodic reporting?

Ans. The first report is due for the half-year period ending March 31, 2025, and must be submitted by April 30, 2025. Subsequent reports are due within 30 days from the end of each half-year period:

-September 30 – Due by October 30

-March 31 – Due by April 30

2. Where can I find the reporting format?

Ans. The reporting format is available in Annexure I of SEBI’s circular. To download it, research analysts need to log in to the BSE Ltd. (RAASB) portal.

3. Where do I submit the periodic reports?

Ans. -Research Analysts (RAs): Submit reports to RAASB via the BSE portal.

-Proxy Advisors (PAs): Submit reports directly to SEBI.

4. Do I need to include non-resident client details in the report?

Ans. Yes, research analysts must include details of non-resident clients in their reports. This information is specified in Table-3 of Annexure I.

5. What if research services are provided for free?

Ans. If research services are offered as a value-added service to clients of stockbroking, PMS, or other services, client details do not need to be submitted in the report.

6. What happens if I miss the submission deadline?

Ans. Failing to submit the periodic report on time can result in non-compliance penalties. It is important to adhere to SEBI’s deadlines and requirements.

7. How can I prepare for the first report submission?

Ans. To prepare for the first submission:

-Download the format from the BSE portal.

-Start collecting data, including non-resident client details.

-Organize the required information in advance to avoid last-minute errors.

-Stay updated with any further instructions from SEBI or BSE.

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