In order to facilitate ease of doing business for the Investment Advisors (“IAs”) and Research Analysts (“RAs”), SEBI has, through a consultation paper dated August 7, 2025 sought comments on proposed amendments to the SEBI (Investment Advisers) Regulations, 2013 (“IA Regulations”) and the SEBI (Research Analysts) Regulations, 2014 (“RA Regulations”).

Following SEBI’s notification of certain amendments to the IA Regulations and the RA Regulations in December 2024, Industry Associations of IAs and RAs have made representations to the SEBI to introduce additional measures which are reflected in the present consultation paper. A concise reference setting out the status quo, perceived difficulties, representations made and SEBI’s proposals addressing such representations is given below:

S.No	Current Scenario	Difficulties	Representations from IAs/ RAs	SEBI’s Proposal under the Consultation Paper
1	IAs/RAs are restricted from sharing data on past performance prior to implementation and operationalization of the ‘Past Risk and Return Verification Agency’ (“PaRRVA”).	This restriction limits the ability of IAs/ RAs to showcase their historical track record and deprives clients of useful data while also disregarding past performance of IAs/RAs.	IAs/RAs should be permitted to provide certified past performance data relating to the period before implementation of PaRRVA to be shared with clients on request and with disclaimers.	IAs/RAs will be permitted to provide past performance data, provided that the data is: (i)Certified by ICAI/ICSI/ICMAI member; (ii)Shared privately with clients upon request; and (iii)Provided along with a prescribed, mandatory disclaimer. The above permission is only in relation to past, prior to implementation of PaRRVA. After a period of 2 years from PaRRVA’s establishment, only PaRRVA-verified data shall be provided to clients.
2	IAs cannot consider assets under pre-distribution agreements as a portion of Assets under Advice (“AUA”) due to which IAs cannot charge fees under the AUA mode.	IAs are restricted from providing and clients are restricted from seeking second opinions for assets under pre-distribution agreements, as fees for the same cannot be charged under AUA mode.	The IAs should be permitted to charge up to 2.5% AUA-based fee for second opinion on such assets.	It is proposed to allow IAs to charge clients for second opinions on assets under pre-distribution agreements as if such assets are covered as AUA, provided that: (i) IAs disclose and seek consent annually from the client acknowledging additional costs for such advice/ second opinions (in addition to the fee payable under the pre-distribution agreement); and (ii) the fee cap of 2.5% pertaining to such assets is maintained.
3	Individual IAs must corporatize within 3 months of crossing client/fee thresholds i.e., either 300 clients or ₹ 3 crores in a financial year (while adhering to restrictions on such client/fee thresholds pending completion of corporatization and grant of Non-Individual IA registration).	The timeline provided for corporatization is limited and restrictions relating to client/fee thresholds during the transition is onerous.	The timeline for the process of corporatization to be extended and IAs should be allowed to exceed the thresholds during the transition.	It is proposed to modify the process as follows: The IAs shall notify Investment Advisers Administration and Supervisory Body (“IAASB”) immediately upon crossing applicable client/fee threshold; Timeline of 3 months provided to apply for in-principle approval and a further time period of 3 months post the in-principle approval to complete transition; IAs will be permitted to onboard new clients and collect fees exceeding the threshold during the transition.
4	In an application for registration as an IA/RA, the proof of address of various persons, such as directors/partners/ beneficial owners etc. are required.	The services of an IA/RA do not warrant for significant physical infrastructure as services are provided largely through online means.	The requirement to submit proof of address for such persons to be removed.	To simplify the application process, the requirement of addresses of multiple persons is proposed to be done away with. However, address details are to be provided on declaration basis to the Administration and Supervisory Board (ASB) during the application for registration.
5	In an application for registration as an IA/RA, detailed information of infrastructure of the IA/RA are required.	The services of an IA/RA do not warrant for significant physical infrastructure as services are provided largely through online means.	The requirement to provide infrastructure details in an application to be removed.	The requirement to provide infrastructure detail is proposed to be removed. However, a declaration affirming that the IA/RA possess necessary infrastructure to effectively discharge their duties is to be provided.
6	In an application for registration as an IA/RA, CIBIL credit report is required.	The submission of the CIBIL credit report is redundant as the IAASB/SEBI already has access and checks several databases (including CIBIL) to ascertain the fit and proper status of the applicant.	The requirement to submit CIBIL report is to be removed.	The requirement to provide CIBIL report is proposed to be removed as this is already implemented through fit-and-proper checks using existing databases and declarations.
7	Net worth, asset-liability details of IAs/ RAs and ITR/Form 16 are requirements in applications.	The requirement is no longer relevant as there exists no net worth threshold for such application.	Requirement to be removed especially in light of an earlier amendment requiring maintenance of a deposit with lien marked to the ASB.	Requirement to submit details of net worth/ assets and liabilities/ income tax returns/ Form 16 is proposed to be removed.
8	Graduation required in specified fields for IA/RA registration.	Excludes capable candidates from other disciplines.	Allow graduates in any discipline with relevant certification; NISM may accredit equivalent programs.	Accept graduates in any field with NISM/external accredited certification, or relevant NISM PG programs (some exempt from NISM exams).