What does a SEBI-registered intermediary have to file, and when?

Which SEBI registrations does this calendar cover, and which sit elsewhere?

Start by drawing the boundary you are actually standing on. This is the ongoing-obligation companion: it covers entities that hold a SEBI intermediary registration and must keep filing for as long as that registration is live. Three populations arrive at a page like this one and they are routinely confused with each other.

(a) Intermediaries registered under a category-specific regulation. A stock broker, a registrar to an issue and share transfer agent, a merchant banker, an investment adviser, a research analyst, a portfolio manager, a debenture trustee, a custodian, a banker to an issue, a credit rating agency, a depository participant. Their duties flow from the registration itself. They are the subject of this page.

(b) Listed companies whose duties flow from listing rather than registration. An operating company with equity or debt admitted to trading owes a completely different body of obligations, governed by the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 , shown on SEBI's own listing page as last amended on July 14, 2026. Nothing on this page substitutes for that. Those duties are covered in the published guides on LODR obligations for listed companies , insider trading , raising capital, buyback and ESOP , takeover, delisting and control change , listing non-convertible securities and debt-listed issuer obligations .

(c) Entities that are both. A registered intermediary whose own securities are listed. For this population the two sets stack ; they do not substitute. The intermediary duties arise from holding the registration, the listing duties from having securities admitted to trading, and neither fact extinguishes the other. The commonest failure here is organisational rather than legal: one function builds the calendar it knows about and assumes the other half belongs to somebody else.

Why this page is organised by duty, not by category. The obvious layout for a page like this is one section per registration category. It is the wrong layout. Seven duties recur across essentially every category (periodic reporting, continuing capital conditions, named compliance personnel, grievance redressal, inspection and audit, KYC and anti-money-laundering, and advertising) and what changes between categories is the threshold, the format, the frequency and the body you send it to, not the existence of the duty. A per-category layout therefore writes the same page seven times over, and a reader who moves between categories, or holds two registrations, learns nothing transferable. Grouping by duty makes the pattern visible and turns the category-specific detail into a lookup, which is what the index in section 8 is for.

Every category named below is taken from SEBI's own regulations listing, with the title quoted as SEBI writes it and the listed document linked. Where a category has a master circular it is named; where SEBI lists no master circular for that category, the row says so rather than inventing one.

Which filings recur, and on what frequency?

This is the spine of the calendar, and it is best built as a frequency ladder rather than as a list of categories. Work down the rungs (monthly, quarterly, half-yearly, annual) and then, separately, build the list of things that are triggered by an event rather than by a date.

Make the calendar-versus-event distinction first, not last. A compliance calendar that contains only dated items looks complete and is not. Intimations have no date until something happens: a change in control, a change in key personnel, a change of registered address, a material adverse change, a breach of a continuing condition. None of these can be diarised in advance, because the date is created by the event. A firm that builds its calendar by opening a spreadsheet and filling in months will therefore capture every periodic filing and miss the entire event-driven half of its obligations. And the event-driven half is where lapses tend to be discovered by somebody else.

For each recurring item, record four things and not just the date: who owes it (the firm, the compliance officer, the principal officer), at what frequency , to whom it goes and which instrument prescribes it . The third of those is the one most often recorded wrongly.

The table below sets out the ladder and the obligation families that populate it. It deliberately does not print a due date against each row. Which rung a given obligation occupies for a given category, and the exact date and format, are prescribed in that category's master circular. And those are the details most likely to have moved since any secondary source was written. Read the rung from this table; read the date from the linked instrument.

Where is net worth or capital adequacy a continuing condition rather than an entry test?

Here is the most common structural misreading in this whole area. A firm assembles the net worth its category requires, proves it at registration, receives the certificate, and files the figure away as a thing that has been done. For several categories that is wrong. The figure is a condition of registration that must be maintained , which means it has to hold on every day the registration is live, not merely on the day it was granted. On that reading, a shortfall is a breach on the day it occurs. Not on the day somebody notices.

This also explains something about section 2 that otherwise looks like paperwork for its own sake. Part of the function of periodic reporting is precisely to evidence that the continuing condition is still met. That is why a net worth certificate signed by a chartered accountant appears in several categories' reporting packs: the certificate is the mechanism by which continued compliance is demonstrated, and the periodic filing is the occasion on which it is demonstrated.

Four concepts get collapsed into one in ordinary conversation, and they are not the same thing:

• Net worth. A computed figure, typically capital plus free reserves subject to prescribed deductions. The computation basis matters as much as the number, and it is set by the category regulation.
• Capital adequacy. A requirement calibrated to the scale or risk of the business rather than a flat floor, so it moves as the business moves.
• Deposit or base-minimum-capital style requirements. An amount actually placed with an exchange or administering body, not merely shown on a balance sheet.
• Net worth certification. The reporting mechanism, usually a chartered accountant's certificate. It is evidence of the condition, not the condition itself.

Not every category carries all four. Some carry none. And the categories that do carry a requirement do not carry the same figure, which is the whole point of this section: a threshold you have heard quoted for a neighbouring category tells you nothing reliable about your own.

What a shortfall triggers, procedurally. Three things tend to follow, in this order. First, intimation. The breach is itself a reportable event, and reporting it yourself is materially different from having it found. Second, a cure period where the category prescribes one, within which the shortfall must be made good. Third, a restriction on taking new clients where that is prescribed, which converts a balance-sheet problem into a commercial one very quickly. The exact mechanics, and whether all three apply to you, come from your category regulation.

Who inside the firm actually carries the obligation?

Everything so far has been owed by the firm. In practice it is carried by named humans, and SEBI's framework says so explicitly.

The compliance officer is a designated role. It is not a title appended to an existing job description. The role carries defined responsibility for monitoring compliance with the applicable regulations and for reporting non-compliance. And that second limb is the one firms under-read. Monitoring without a reporting duty would be an internal management function; the reporting duty is what makes it a regulatory office. The common machinery sits in the SEBI (Intermediaries) Regulations, 2008 , last amended April 16, 2026, read with your category regulation.

Appointment, resignation and replacement are themselves intimable events. They belong in the event-driven list from section 2, not in the dated calendar. They have no date until they happen, and they happen at exactly the moment the firm is least likely to be thinking about filings.

Whether one person may hold several designated roles is category-specific. In a small registrant the same individual is often proposed as principal officer, compliance officer and designated director. Whether that is permitted, and on what conditions, differs between categories. So this guide does not give a blanket answer, and you should not accept one from a firm registered in a different category. Read the point in your own regulation, linked in section 8. It is a question worth settling in writing before an inspection asks it, because the answer determines whether your governance structure was compliant for the whole period or none of it.

Certification and qualification requirements are continuing, not one-time. Where a category requires persons associated with the intermediary to hold a certification, the requirement is framed under the SEBI (Certification of Associated Persons in the Securities Markets) Regulations, 2007 , last amended July 15, 2025. The practical point is renewal: a certification obtained once and allowed to lapse leaves the associated person (and therefore the firm) non-compliant from the lapse date, silently, because nothing external announces it. Certification expiry dates belong on the dated calendar alongside the filings.

How must investor complaints be received, resolved, and reported?

SEBI treats grievance redressal as a standing operational system with a reporting tail, not as ad-hoc customer service. That framing matters, because a firm that resolves complaints well but treats the process informally will fail on the parts that are actually measured.

There are three layers to build, and they are sequential.

Layer one. Intake and internal resolution. A defined channel through which a client can complain, a named point of contact responsible for it, and disclosed contact details so the channel is findable without asking. Disclosure is part of the obligation, not a nicety: a complaints process that exists but is not published does not discharge it.

Layer two. Escalation to SEBI's investor complaint mechanism. Where the client is not satisfied, the complaint escalates into SEBI's own mechanism, and the intermediary carries a duty to respond within that mechanism's timelines. Two things follow. The clock there is not your clock. It runs on the mechanism's terms regardless of your internal service standards. And a complaint that has escalated is visible to the regulator whatever its merits, which is why the quality of layer one is measured indirectly by the volume reaching layer two.

Layer three. Onward dispute resolution. Where the complaint is not settled within the mechanism, it moves into the dispute resolution route prescribed for your category. The obligation at this layer is largely one of participation and record production, both of which depend on layers one and two having been documented properly.

Then there is the reporting tail, and it is separate. This is the part firms miss. Running the resolution well does not discharge the duty to report on it. Where prescribed, an intermediary owes a periodic statement of complaints received, resolved and pending , and website disclosure of that data. These are distinct obligations from handling the complaints themselves, they sit on the dated calendar from section 2, and they are assessed on whether the statement was filed rather than on whether the complainant was satisfied.

The portal, the mechanism and the reporting format applicable to you are named in your category's master circular, and so are the response timelines. This guide does not state a number of days, because that figure is prescribed inside the circular and differs across categories and versions. Read it from the linked document. For a registrar to an issue and share transfer agent that is the Master Circular for Registrars to an Issue and Share Transfer Agents dated Feb 06, 2026; for an investment adviser the Master Circular for Investment Advisers dated Feb 06, 2026; for a research analyst the Master Circular for Research Analysts dated Feb 06, 2026. In each of those three cases an earlier version from 2025 is still listed on SEBI's site. See section 8 before you open the copy you already have.

Match the activity to the registration category printed on your SEBI certificate, not to how you describe yourself commercially. Firms routinely market as one thing and are registered as another. </>), soThat: (<> You pull the obligations of your actual category rather than of the adjacent category whose rules read more familiar. </>), }, , , , , { ask: "Are you also a listed company, or an issuer of listed debt?", check: (<> If your own securities are listed, the listing obligations run in parallel with the intermediary ones and are covered in the separate published guides on

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What audits and inspections must an intermediary submit to, and what must it be able to produce?

Readers routinely merge three genuinely distinct exercises into a single mental category called 'audit'. They differ in who initiates them, who conducts them, and where the output goes. And the differences are what determine your obligations.

Internal audit is conducted at the registrant's own instance, at intervals prescribed for the category where it is required. You initiate it, you appoint the auditor, and you own the remediation. Systems or technology audit applies where the category's operations are systems-dependent, and examines the infrastructure rather than the transactions. Access controls, change management, business continuity, data integrity. Inspection is different in kind: it is conducted by SEBI or by an administering exchange or depository, and it is not scheduled by the registrant at all. You cannot prepare for it on notice, which is the entire point of it.

Underneath all three sits record retention, and it is the load-bearing obligation. An audit is only as good as the records it can examine, and an inspection is in substance a test of the records you kept during the period under review. Retention obligations are prescribed for client records, KYC documentation, order and transaction records, and communications. And the periods are not uniform across those classes or across categories, so read yours from your own instrument rather than applying a single house rule to everything.

What do the KYC, anti-money-laundering, and advertisement-code obligations require every month you stay registered?

These two families are continuing rather than periodic . They generate no calendar entry, which is precisely why they are the obligations most often found broken on inspection: nothing ever falls due, so nothing ever prompts a review, so the control drifts and no one notices until somebody external looks.

KYC and anti-money-laundering. Six components, each of which has to exist as an operating control rather than as a document:

• A documented policy adopted by the board or governing body and reviewed periodically. The periodic review is itself the obligation most commonly skipped. An adopted policy that has never been revisited fails the requirement even though the document exists.
• Client due diligence at onboarding and on an ongoing basis, including periodic refresh by risk category. Ongoing diligence is what makes this a continuing obligation: a client onboarded correctly three years ago is not thereby diligenced today.
• Upload and retrieval of KYC records through the prescribed registration agency infrastructure, framed under the SEBI KYC (Know Your Client) Registration Agency "} Regulations, 2011 , last amended February 10, 2025.
• Transaction monitoring with a defined internal escalation path from alert to report. An alerting system with no documented escalation route produces alerts nobody is obliged to action.
• Designation of a principal officer for the anti-money-laundering function. A named role, subject to the same category-specific question about role overlap discussed in section 4.
• Record retention on its own clock , which may run longer than the general retention period in section 6. Do not fold this into a single firm-wide deletion policy.

Advertising. Start with the definitional point, because it is where most firms go wrong before they consider a single rule: what counts as an advertisement is almost always broader than the reader assumes. It reaches your website, social posts, client presentations, webinars and messaging-app broadcasts. Not only paid media. A firm that runs its paid campaigns past compliance and lets its founder post performance figures on social media has inverted the risk, since the second channel is usually the higher-volume one.

From there, four questions for your category: whether any pre-approval or filing requirement applies before publication; what mandatory disclosures and disclaimers must appear, including registration number and the standard risk language; what the code says about testimonials and third-party endorsements; and the standing prohibition on performance claims and assured-return language , which holds regardless of how the claim is qualified in a footnote. Misleading claims also engage the SEBI (Prohibition of Fraudulent and Unfair Trade Practices relating to Securities Market) Regulations, 2003 , last amended December 05, 2025, independently of any category-specific advertisement code.

A Category I registrar and share transfer agent in Hyderabad (illustrative), twelve staff, servicing about 40 issuer clients. The compliance officer who built the filing calendar left in March. The successor has a folder of downloaded PDFs, no index, and wants to know what is due and what the firm is holding out of date. </> } result= >

Master circular index by intermediary category, and how to check yours is current

This is the index the rest of the guide routes into. Every row gives the governing regulation with its year and, where SEBI records one, its amendment date; the master circular that carries the operative detail; and a status flag. The superseded rows are shown rather than omitted, so that a reader arriving with the old document recognises it instead of concluding it is missing.

Four regulations carry no recorded amendment date at all. SEBI's regulations listing shows an amendment date in the title of most entries. For four it shows none: SEBI (Stock Brokers) Regulations, 2026 , SEBI (Procedure for making, amending and reviewing of Regulations) Regulations, 2025 , SEBI (Registrars to an Issue and Share Transfer Agents) Regulations, 2025 and SEBI (Appointment of Administrator and Procedure for Refunding to the Investors) Regulations, 2018 . Cite these as the principal regulation and its year. Do not append 'as amended', and do not supply a date from another source to fill the gap. Absent data is data, and an invented amendment date is worse than an acknowledged blank.

Frequently asked questions

My firm is a SEBI-registered intermediary and its shares are listed. Do the LODR obligations replace the intermediary ones or stack on top?

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Update history

• 2026-08-25 First published.