Investment Adviser Fee Dispute: Agreement, Invoice and SEBI Registration Evidence
By Ravi Sisodia · Reviewed by CA Divyanshu Sengar · Updated 5 October 2026
India-first finance and compliance workflow with primary-source anchors.
2-minute summary
- An investment-adviser fee dispute should start with the adviser’s SEBI registration, client agreement, fee method, billing period, service scope and termination/refund clauses. A payment receipt alone does not prove that every charged amount complied with the regulatory and contractual framework.
- SEBI issued a consolidated Investment Adviser Master Circular on 6 February 2026. Older guidance should therefore be checked against that current master circular and the IA Regulations before alleging an excess fee, prohibited advance charge or service failure.
- Separate a fee-calculation dispute from an investment-performance complaint. Advisers do not guarantee returns merely because advice underperformed; however, misrepresentation, undisclosed conflicts, unauthorised services or fees inconsistent with the agreement/regulations can create a distinct grievance.
Current position
Control and decision map
| # | Control / decision step |
|---|---|
| 1 | Verify the adviser and registration details on SEBI records. |
| 2 | Read the client agreement, fee mode, billing cycle and termination terms. |
| 3 | Recompute fees from the agreed base and period, including taxes separately. |
| 4 | Identify whether disputed amounts are adviser fees, execution/platform charges or third-party product costs. |
| 5 | Raise a written fee calculation request and preserve the adviser response. |
| 6 | Escalate an unresolved regulated-entity grievance through SCORES/ODR where eligible. |
Evidence pack
- SEBI registration details
- Signed IA agreement and risk-profile/advice records
- Invoices, receipts and bank payments
- Fee calculation worksheet
- Complaint, SCORES and ODR correspondence
Worked example
A client pays an annual advisory fee but terminates after four months and expects a full refund. The answer depends on the agreement and current SEBI fee/refund rules, not merely on dissatisfaction with portfolio returns. The calculation should show service period, permitted advance fee and any breakage/refund terms.
Common mistakes
- Equating investment loss with an automatic fee refund.
- Paying an unverified person claiming to be a SEBI-registered IA.
- Ignoring the signed fee method and billing period.
- Combining product commissions and advisory fees without tracing who charged them.
Frequently asked questions
How do I verify an adviser?
Check SEBI registration/official records and match the legal entity and registration number.
Does poor performance prove the fee was improper?
No. Performance and fee compliance are separate questions.
Which circular should be used in 2026?
Use SEBI’s 6 February 2026 IA Master Circular together with the applicable regulations and agreement.
Official sources
- Securities and Exchange Board of India - Master Circular for Investment Advisers (Master Circular; 2026-02-06)
- Securities and Exchange Board of India - SEBI SCORES 2.0 - investor grievance framework (SCORES 2.0; current)
- Securities and Exchange Board of India - Master Circular for Online Resolution of Disputes in the Indian Securities Market (SEBI/HO/OIAE/OIAE_IAD-3/P/CIR/2023/195; 2023-12-28; current framework subject to later changes)
Disclaimer
Educational and professional reference only; confirm the current law, rates and the facts of your case before relying on this page.