Research analyst - Governance and responsible persons
Board, trustee, compliance officer, principal officer, designated person and accountable-function mapping under SEBI Research Analysts Regulations, 2014.
Finin2min Summary
- Research analyst - Governance and responsible persons is a source-controlled working page for SEBI Research Analysts Regulations, 2014.
- It focuses on board, trustee, compliance officer, principal officer, designated person and accountable-function mapping for research analysts, research entities, principal officers, supervisory analysts, clients, distributors and compliance teams.
- The bare-law spine is registration, qualification, research report standards, disclosures, conflict management, personal trading, compensation controls, records and inspection; this page narrows that spine to responsible officer, compliance officer, board/trustee duties, audit, code of conduct and fit-and-proper provisions.
- The official source used for this batch is dated 25 November 2025; the SEBI regulation listing should still be checked before filing or advising.
Bare Law and Source Map
| Instrument | SEBI Research Analysts Regulations, 2014 |
|---|---|
| Audience | research analysts, research entities, principal officers, supervisory analysts, clients, distributors and compliance teams |
| Page focus | board, trustee, compliance officer, principal officer, designated person and accountable-function mapping |
| Provision family | responsible officer, compliance officer, board/trustee duties, audit, code of conduct and fit-and-proper provisions |
| Official source | https://www.sebi.gov.in/legal/regulations/nov-2025/securities-and-exchange-board-of-india-research-analysts-regulations-2014-last-amended-on-november-25-2025-_98248.html |
Section-wise / Para-wise Decode
- Applicability paragraph for Research analyst - Governance and responsible persons: first identify whether the person or transaction sits inside SEBI Research Analysts Regulations, 2014 and whether any exemption, saving or transitional clause applies.
- Clause paragraph for Research analyst - Governance and responsible persons: read the numbered regulation, proviso, explanation and schedule dealing with responsible officer, compliance officer, board/trustee duties, audit, code of conduct and fit-and-proper provisions; do not rely only on a heading or circular summary.
- Evidence paragraph for Research analyst - Governance and responsible persons: connect the clause to registration certificate, research report, model/valuation file, conflict declaration, holding disclosure, approval log, distribution list and record-retention file and record who supplied, reviewed and approved each document.
- Risk paragraph for Research analyst - Governance and responsible persons: the main practical failure pattern is undisclosed conflict, unsupported recommendation, stale financial data, personal-trading breach, misleading rating language or missing supervisory approval.
- Decision paragraph for Research analyst - Governance and responsible persons: state whether the action is permitted, restricted, reportable, approval-linked, disclosure-linked or prohibited, and cite the official source URL.
Linked Rules, Circulars and Notifications
- The regulations distinguish research analysis from general market commentary, investment advice and distribution communication.
- Research reports need factual basis, valuation method, rating/target-price logic, conflict disclosures and supervisory approval.
- Analyst/entity holdings, compensation links and merchant-banking or issuer relationships must be disclosed and controlled.
- Inspection risk is managed through report files, data support, approval logs, client distribution records and personal-trading controls.
- For Research analyst - Governance and responsible persons, the controlling question is whether board, trustee, compliance officer, principal officer, designated person and accountable-function mapping has been tested against the official text and the facts actually on record.
- For Research analyst work under Governance and responsible persons, SEBI Act sections 11, 11B, 12, 15-I and 15HB/15HA may become relevant where registration, direction, inspection, adjudication or penalty consequences arise.
Before filing or issuing advice, check the SEBI regulations listing, the family source page, applicable master circulars, exchange or depository specifications and any SEBI order affecting the same fact pattern.
Workflow / Flow Chart
- Step 1Confirm applicability of SEBI Research Analysts Regulations, 2014 to the entity, role, security, investor/client and event date before using Research analyst - Governance and responsible persons.
- Step 2Open the official source dated 25 November 2025 and locate the exact clause family for responsible officer, compliance officer, board/trustee duties, audit, code of conduct and fit-and-proper provisions.
- Step 3Freeze the facts: parties, transaction, approval date, amount, security, investor/client class, filing channel and responsible officer.
- Step 4Build the Research analyst - Governance and responsible persons evidence file using registration certificate, research report, model/valuation file, conflict declaration, holding disclosure, approval log, distribution list and record-retention file; mark each item as available, pending or not applicable.
- Step 5Translate the legal requirement into one owner, one due date, one approval trail and one acknowledgement or retention record.
- Step 6Check linked circulars, master circulars, exchange/depository specifications and enforcement orders before closing the advice.
- Step 7Record deviations, board or trustee escalation, client/investor communication and remediation status in the working paper.
Practical Examples
- buy report issued while group has issuer relationship: use Research analyst - Governance and responsible persons to decide the legal trigger, evidence owner and corrective filing before the transaction proceeds.
- target price changed without documented model support: map the facts to Governance and responsible persons and test whether the record supports every field in the compliance conclusion.
- analyst trading around a research publication: if the fact pattern changes after approval, rerun applicability, investor/client communication and reporting checks.
Highlighted Points
- Do not treat Research analyst commercial wording as enough; the official regulation source controls the legal label.
- Governance and responsible persons should end in a dated working paper, not only a verbal compliance clearance.
- Portal acceptance, exchange acknowledgement or trustee sign-off does not cure a wrong legal classification.
- Every Research analyst - Governance and responsible persons advice note should quote the provision family for responsible officer, compliance officer, board/trustee duties, audit, code of conduct and fit-and-proper provisions and keep the official SEBI source link beside it.
- Where a circular or master circular changes implementation, preserve both the regulation text and the circular instruction.
Exam and Advisory Case Studies
Case study: A compliance officer is asked to approve a Research analyst action involving buy report issued while group has issuer relationship. The short answer should not say only that SEBI Research Analysts Regulations, 2014 applies. It should classify the party and transaction, locate responsible officer, compliance officer, board/trustee duties, audit, code of conduct and fit-and-proper provisions, test the evidence pack against registration certificate, research report, model/valuation file, conflict declaration, holding disclosure, approval log, distribution list and record-retention file, identify the responsible officer and decide whether a filing, investor/client notice, trustee or board approval, or remediation note is needed.
Advisory build-out for Research analyst - Governance and responsible persons: prepare a one-page control sheet with columns for legal source, clause, fact proved, document reference, owner, due date, exception and closure evidence. Use the 25 November 2025 source link for the current text and keep the SEBI regulations listing in the file for later source-currentness checks.
Q&A
What is the first source to open?
For Research analyst - Governance and responsible persons, open the official SEBI source for SEBI Research Analysts Regulations, 2014 and then the current SEBI regulations listing before relying on any implementation note.
Is this page a substitute for the bare regulation?
No. It is a practitioner map. The official regulation, schedule, circular and filing system remain the controlling source.
What makes the working paper defensible?
For Research analyst - Governance and responsible persons, use a clause-to-evidence link covering registration certificate, research report, model/valuation file, conflict declaration, holding disclosure, approval log, distribution list and record-retention file, plus approval, filing and exception records.
When should enforcement risk be considered?
For Research analyst - Governance and responsible persons, consider enforcement risk as soon as the fact pattern shows undisclosed conflict, unsupported recommendation, stale financial data, personal-trading breach, misleading rating language or missing supervisory approval, or when an inspection, investor complaint, SEBI letter or exchange query is received.
Working Checklist
- Open and save the official SEBI Research Analysts Regulations, 2014 source.
- Prepare a Governance and responsible persons clause map with facts, documents and owner.
- Attach evidence from registration certificate, research report, model/valuation file, conflict declaration, holding disclosure, approval log, distribution list and record-retention file for the Governance and responsible persons issue on this page.
- Confirm linked circulars, master circulars, exchange/depository specifications and filing formats.
- Record closure evidence, investor/client communication and board/trustee/compliance approval where applicable.
Primary Official Sources
- Official SEBI source - SEBI Research Analysts Regulations, 2014
https://www.sebi.gov.in/legal/regulations/nov-2025/securities-and-exchange-board-of-india-research-analysts-regulations-2014-last-amended-on-november-25-2025-_98248.htmlofficial primary - SEBI current regulations listing
https://sebi.gov.in/sebiweb/home/HomeAction.do?doListing=yes&sid=2&smid=0&ssid=3official register - SEBI legal listing
https://www.sebi.gov.in/sebiweb/home/HomeAction.do?doListingLegal=yes&sid=1&ssid=3official register - SEBI Act, 1992
https://www.sebi.gov.in/commondata/acts.pdfofficial act