Registration
Which SEBI registration does my business actually need?
Every intermediary category mapped. What activity triggers registration, the governing regulation with its exact title and year, and the master circular that consolidates its circulars.
By Aaryan Kakani · · 20 min read
What actually triggers a SEBI registration?
The routing principle is narrower than most founders expect. SEBI registration attaches to an activity carried on for consideration on behalf of other people. It does not attach to a company type, a turnover threshold, an incorporation form or a self-description. A partnership firm with Rs. 40 lakh of revenue can be squarely inside a registration category; a Rs. 900 crore company that never touches anybody else's securities can be entirely outside one. And because the trigger is the activity, the unit of analysis is the revenue line, not the entity. Which is why a single firm can end up holding three registrations at once.
Before anything else, separate the two populations that land on this page, because they owe completely different things.
(a) The issuer. A listed or debt-listed operating company (an exporter, a manufacturer, a mid-cap services business) that has raised money from the public. Its duties are issuer duties, under the Listing Obligations and Disclosure Requirements Regulations, 2015 , the ICDR Regulations and the non-convertible securities regulations. Nothing on this page applies to it in that capacity, and no intermediary registration follows from being an issuer. Those obligations are already covered in six published guides. On LODR disclosure and filing obligations , raising capital under ICDR, buyback and ESOP , listing non-convertible securities , the debt-listed issuer's LODR chapter , insider trading and takeover, delisting and change of control. And are not restated here.
(b) The intermediary. A firm that advises, deals, pools, holds, rates, indexes or keeps records for other people. That is the population this page routes. If you are being paid to stand between an investor and the securities market in any capacity, you are somewhere on the map in section 8.
For most intermediary categories the common gateway is the Securities and Exchange Board of India (Intermediaries) Regulations, 2008 , shown on SEBI's listing as last amended on April 16, 2026. It is easy to overlook because it is not named after any category: it carries the common application, the fit-and-proper criteria and the registration procedure that run across categories. The category-specific regulation then carries what is particular. Eligibility, net worth, and the conduct obligations you will actually be inspected against. You need both. A firm that reads only its category regulation will meet the net worth test and fail the application.
Distinguish, too, between registering the firm and certifying the people . The Securities and Exchange Board of India (Certification of Associated Persons in the Securities Markets) Regulations, 2007 , last amended July 15, 2025, bind the individuals employed by or associated with an intermediary, not the entity itself. A registered firm staffed by uncertified associated persons is non-compliant even though its own registration is in order.
| Who you are | What you do | Governing instrument family | Where to read next |
|---|---|---|---|
| Listed operating company (issuer) | Raise equity from the public and stay listed | LODR Regulations, 2015; ICDR Regulations, 2018 | LODR obligations and ICDR, buyback and ESOP |
| Debt-listed issuer | Issue and list non-convertible securities | Issue and Listing of Non-Convertible Securities Regulations, 2021; LODR Chapter V | NCS listing and debt-listed LODR |
| Promoter, director or insider | Hold, trade or acquire control of a listed company | Prohibition of Insider Trading Regulations, 2015; Takeover Regulations, 2011 | insider trading and control change |
| Intermediary (firm) | Advise, deal, pool, hold, rate, index or keep records for others, for consideration | Intermediaries Regulations, 2008 as the common gateway, plus the category regulation and its master circular | Sections 2 to 6 below, indexed in section 8 |
| Individual employed by an intermediary | Advise, deal or handle client securities as an associated person | Certification of Associated Persons in the Securities Markets Regulations, 2007 (last amended July 15, 2025) | Certification is personal and separate from the firm's registration |
Am I an investment adviser, a research analyst or a portfolio manager?
These are the three most-confused categories on the whole list, and they are separated by a single test each. The test is not how sophisticated your output is, how much you charge, or what your website calls you. It is who the output is aimed at and whether you can act on it.
Research analyst. Impersonal research, or a buy/sell recommendation, issued to a subscriber base for consideration, with no assessment of any individual subscriber's suitability. If every recipient gets the same document and nobody's circumstances shaped it, this is your category. It is governed by the Securities and Exchange Board of India (Research Analysts) Regulations, 2014 , last amended November 25, 2025, and consolidated by the Master Circular for Research Analysts dated February 06, 2026.
Investment adviser. Advice personalised to a particular client's circumstances (their goals, their risk appetite, their existing holdings) for a fee. The moment a recommendation is fitted to one named person, you have crossed out of research and into advice. It is governed by the Securities and Exchange Board of India (Investment Advisers) Regulations, 2013 , last amended November 25, 2025, and consolidated by the Master Circular for Investment Advisers dated February 06, 2026.
Portfolio manager. Managing a client's own segregated account (discretionary or non-discretionary) with authority to transact in it. The distinguishing feature is not the advice but the mandate: you can move the money. It is governed by the Securities and Exchange Board of India (Portfolio Managers) Regulations, 2020 , last amended September 03, 2025, and consolidated by the Master Circular for Portfolio Managers dated July 16, 2025.
Make no assumption that these are alternatives. They are not a menu. They are three independent tests, and the same firm can trip all three at once . A firm that publishes a subscription research note, separately advises named clients for a fee, and separately again holds a mandate over one client's demat account needs three registrations, three sets of eligibility and net worth compliance, and three separate conduct regimes. There is no consolidated licence that covers the set. The worked example later on this page traces exactly that firm.
| Activity test | Category | Regulation | Master circular and date | Superseded version still displayed |
|---|---|---|---|---|
| Impersonal research or a buy/sell call issued to a subscriber base for consideration; no client-specific suitability | Research analyst | SEBI (Research Analysts) Regulations, 2014. Last amended November 25, 2025 | Master Circular for Research Analysts, February 06, 2026 | Yes. June 27, 2025 version |
| Advice personalised to a particular client's circumstances, for a fee | Investment adviser | SEBI (Investment Advisers) Regulations, 2013. Last amended November 25, 2025 | Master Circular for Investment Advisers, February 06, 2026 | Yes. June 27, 2025 version |
| Managing a client's own segregated account, discretionary or non-discretionary, with authority to transact | Portfolio manager | SEBI (Portfolio Managers) Regulations, 2020. Last amended September 03, 2025 | Master Circular for Portfolio Managers, July 16, 2025 | No |
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Which registration applies if I pool other people's money?
Pooling is the dividing line, and it is a sharper one than most people treat it as. The moment assets from more than one investor sit in a single vehicle, the category shifts off portfolio management and onto a fund registration. Ten clients with ten segregated demat accounts is portfolio management. The same ten clients whose money is combined into one vehicle with units or interests is a fund, whatever the paperwork calls it.
The principal domestic pooled categories are three. The Securities and Exchange Board of India (Alternative Investment Funds) Regulations, 2012 , last amended July 14, 2026, consolidated by the Master Circular for Alternative Investment Funds (AIFs) dated June 03, 2026, cover privately pooled vehicles raising from sophisticated investors. The Securities and Exchange Board of India (Mutual Funds) Regulations, 2026 , last amended July 07, 2026, consolidated by the Master Circular for Mutual Funds dated March 20, 2026, cover retail pooling through schemes. And the Securities and Exchange Board of India (Collective Investment Scheme) Regulations, 1999 , last amended December 05, 2025, are the residual anti-avoidance category: they catch pooled schemes that are neither an AIF nor a mutual fund. That residual character is the point. A structure designed to sit in the gap between the two named regimes does not thereby escape registration, it lands in the CIS regulations.
For offshore capital coming in, two further categories apply. The Securities and Exchange Board of India (Foreign Venture Capital Investor) Regulations, 2000 , last amended July 10, 2026, and the Securities and Exchange Board of India (Foreign Portfolio Investors) Regulations, 2019 , last amended July 07, 2026. These register the investor rather than a manager serving Indian clients, which is why they are easy to miss when mapping a group structure that has both an Indian manager and an offshore feeder.
Then there are the two trust vehicles that occupy both populations at once. A registered real estate investment trust under the SEBI (Real Estate Investment Trusts) Regulations, 2014 , last amended April 18, 2026, consolidated by the Master Circular for Real Estate Investment Trusts (REITs) dated July 11, 2025, and a registered infrastructure investment trust under the SEBI (Infrastructure Investment Trusts) Regulations, 2014 , last amended April 17, 2026, consolidated by the Master Circular for Infrastructure Investment Trusts (InvITs) dated July 11, 2025, are simultaneously a registered entity and a listed issuer .
| Pooling structure | Investor type | Category | Regulation | Master circular and date |
|---|---|---|---|---|
| Each investor's own segregated account | Individual clients | Portfolio manager | SEBI (Portfolio Managers) Regulations, 2020. Last amended September 03, 2025 | Master Circular for Portfolio Managers, July 16, 2025 |
| Privately pooled vehicle with units or interests | Sophisticated or institutional | Alternative investment fund | SEBI (Alternative Investment Funds) Regulations, 2012. Last amended July 14, 2026 | Master Circular for Alternative Investment Funds (AIFs), June 03, 2026 |
| Publicly offered scheme | Retail | Mutual fund | SEBI (Mutual Funds) Regulations, 2026. Last amended July 07, 2026 | Master Circular for Mutual Funds, March 20, 2026 |
| Pooled scheme that is neither an AIF nor a mutual fund | Any | Collective investment scheme (residual category) | SEBI (Collective Investment Scheme) Regulations, 1999. Last amended December 05, 2025 | Not listed by that name among SEBI's master circulars; work from the regulation |
| Offshore fund investing into India | Foreign investor | Foreign portfolio investor | SEBI (Foreign Portfolio Investors) Regulations, 2019. Last amended July 07, 2026 | Not listed by that name among SEBI's master circulars; work from the regulation |
| Offshore venture capital vehicle investing into India | Foreign investor | Foreign venture capital investor | SEBI (Foreign Venture Capital Investor) Regulations, 2000. Last amended July 10, 2026 | Not listed by that name among SEBI's master circulars; work from the regulation |
| Listed trust holding rent-yielding real estate | Unit holders, including retail | REIT. Registered entity and listed issuer | SEBI (Real Estate Investment Trusts) Regulations, 2014. Last amended April 18, 2026 | Master Circular for Real Estate Investment Trusts (REITs), July 11, 2025 |
| Listed trust holding infrastructure assets | Unit holders, including retail | InvIT. Registered entity and listed issuer | SEBI (Infrastructure Investment Trusts) Regulations, 2014. Last amended April 17, 2026 | Master Circular for Infrastructure Investment Trusts (InvITs), July 11, 2025 |
Which registration covers broking, exchanges, clearing, depositories and custody?
This is the market-plumbing cluster, and the trigger across all of it is the same: you touch an order, a settlement, or somebody else's securities. You do not need to give advice or take a view to be inside it. Executing, matching, settling, recording or simply holding is enough.
Stock broking is governed by the Securities and Exchange Board of India (Stock Brokers) Regulations, 2026 . Note this carefully: SEBI's own listing shows no amendment date for this regulation. Cite the base 2026 instrument and nothing more. Its consolidation is the Master Circular for Stock Brokers dated June 17, 2025. Which, on its face, predates the regulation it now sits under. That is not an error to correct by guessing; it is a sequencing fact to be aware of when you find a conduct requirement in the master circular and cannot locate its parent provision where you expect it.
Exchanges and clearing corporations are governed by the Securities Contracts (Regulation) (Stock Exchanges and Clearing Corporations) Regulations, 2018 , last amended November 22, 2025, consolidated by the Master Circular for Stock Exchanges and Clearing Corporations dated December 30, 2024. Note the parent statute here is the Securities Contracts (Regulation) Act rather than the SEBI Act, so the title does not open with "Securities and Exchange Board of India" the way most entries on the list do. A small thing that defeats a lot of keyword searches.
Depositories and depository participants are governed by the Securities and Exchange Board of India (Depositories and Participants) Regulations 2018 , last amended November 22, 2025, consolidated by the Master Circular for Depositories dated December 03, 2024.
Custody is governed by the Securities and Exchange Board of India (Custodian) Regulations, 1996 , last amended July 08, 2026. And this is a large, institutionally significant category with no dedicated master circular on SEBI's master circular list. For a custodian, the regulation plus the loose circulars issued under it is the whole of the law. There is no single consolidated document to work from, which makes the circular-tracking discipline in section 7 more important here than anywhere else on this page.
Finally, one cross-cutting instrument binds this entire cluster regardless of which category you sit in: the Master Circular on Surveillance of Securities Market dated May 15, 2026. A firm that has mapped only its own category's regulation and master circular has not finished reading.
| Function | Category | Regulation | Master circular and date | Dedicated master circular exists? |
|---|---|---|---|---|
| Executing client orders on an exchange | Stock broker | SEBI (Stock Brokers) Regulations, 2026. no amendment date shown | Master Circular for Stock Brokers, June 17, 2025 | Yes. But dated before the regulation |
| Operating a trading venue or clearing and settling trades | Stock exchange / clearing corporation | Securities Contracts (Regulation) (Stock Exchanges and Clearing Corporations) Regulations, 2018. Last amended November 22, 2025 | Master Circular for Stock Exchanges and Clearing Corporations, December 30, 2024 | Yes |
| Maintaining securities in dematerialised form, or serving clients as a participant | Depository / depository participant | SEBI (Depositories and Participants) Regulations 2018. Last amended November 22, 2025 | Master Circular for Depositories, December 03, 2024 | Yes |
| Holding securities and related assets on behalf of clients | Custodian | SEBI (Custodian) Regulations, 1996. Last amended July 08, 2026 | No dedicated master circular. Regulation plus loose circulars | No |
| Cross-cutting: market surveillance obligations | All of the above | Applies alongside the category regulation, not instead of it | Master Circular on Surveillance of Securities Market, May 15, 2026 | Yes. But not category-specific |
Which intermediaries does an issue of securities require?
This section has two audiences at once. The first is the firm seeking one of these registrations. The second (and, for most readers arriving from the ICDR and NCS guides) is the exporter or mid-cap issuer who is not becoming an intermediary at all, but must appoint several. Knowing which registered category each appointee must hold is the difference between a clean issue and a defective one.
Merchant bankers run the issue. They are governed by the Securities and Exchange Board of India (Merchant Bankers) Regulations, 1992 , last amended December 05, 2025, consolidated by the Master Circular for Merchant Bankers dated July 14, 2026. The most recently issued master circular on SEBI's entire list, and therefore the one where a two-year-old internal note is most likely to be out of date.
Debenture trustees hold security and act for the debenture holders. They are governed by the Securities and Exchange Board of India (Debenture Trustees) Regulations, 1993 , last amended October 27, 2025, consolidated by the Master Circular for Debenture Trustees (DTs) dated August 13, 2025. The reporting chain between the issuer and its trustee (what the issuer must give the trustee, and when) is set out in the non-convertible securities guide and the debt-listed issuer guide , and is not restated here.
Registrars and share transfer agents process applications, allotment and transfers. They are governed by the Securities and Exchange Board of India (Registrars to an Issue and Share Transfer Agents) Regulations, 2025 (again, no amendment date on SEBI's listing , so cite the base 2025 instrument) consolidated by the Master Circular for Registrars to an Issue and Share Transfer Agents dated February 06, 2026, which supersedes the June 23, 2025 version still displayed on the same page.
Bankers to an issue handle the money flow. They are governed by the Securities and Exchange Board of India (Bankers to an Issue) Regulations, 1994 , last amended February 10, 2025, with no dedicated master circular. KYC record-keeping is a registered activity in its own right under the Securities and Exchange Board of India {KYC (Know Your Client) Registration Agency} Regulations, 2011 , last amended February 10, 2025, also with no dedicated master circular. Both of these are commonly assumed to be functions performed by an intermediary rather than categories in themselves, which is exactly why they get missed in a group structure review.
For completeness on the other side of the table: the issue-side consolidation for the issuer is the Master Circular for Issue of Capital and Disclosure Requirements dated February 09, 2026, which supersedes the November 11, 2024 version SEBI still displays. That document, and the obligations it places on a company raising money, are covered in the capital-raising guide .
| Role in an issue | Category | Regulation | Master circular and date | Who appoints whom |
|---|---|---|---|---|
| Manages and underwrites the issue, files the offer document | Merchant banker | SEBI (Merchant Bankers) Regulations, 1992. Last amended December 05, 2025 | Master Circular for Merchant Bankers, July 14, 2026 | Appointed by the issuer |
| Acts for debenture holders and holds the security | Debenture trustee | SEBI (Debenture Trustees) Regulations, 1993. Last amended October 27, 2025 | Master Circular for Debenture Trustees (DTs), August 13, 2025 | Appointed by the debt issuer, owes duties to holders |
| Processes applications, allotment, transfers and the register | Registrar to an issue / share transfer agent | SEBI (Registrars to an Issue and Share Transfer Agents) Regulations, 2025. no amendment date shown | Master Circular for Registrars to an Issue and Share Transfer Agents, February 06, 2026 (supersedes June 23, 2025) | Appointed by the issuer |
| Receives application money and handles the issue account | Banker to an issue | SEBI (Bankers to an Issue) Regulations, 1994. Last amended February 10, 2025 | No dedicated master circular | Appointed by the issuer |
| Maintains and shares client KYC records across intermediaries | KYC registration agency | SEBI {KYC (Know Your Client) Registration Agency} Regulations, 2011. Last amended February 10, 2025 | No dedicated master circular | Used by intermediaries, registered in its own right |
| The issuer's own disclosure obligations in the issue | Not an intermediary category. Issuer side | ICDR Regulations, 2018 | Master Circular for Issue of Capital and Disclosure Requirements, February 09, 2026 (supersedes November 11, 2024) | See the capital-raising guide |
Who needs a credit rating, ESG rating, index provider or vault manager licence?
This is the opinion-and-infrastructure cluster: firms that do not hold client money or execute trades, but produce something the market relies on. A rating, an index, or the physical underlying of a traded instrument. It also contains the single most useful structural oddity on the whole list.
Credit rating agencies are governed by the Securities and Exchange Board of India (Credit Rating Agencies) Regulations, 1999 , last amended January 15, 2026, consolidated by the Master Circular for Credit Rating Agencies (CRAs) dated July 11, 2025. This category matters to more than the rating firms themselves: any issuer raising debt engages one, and the rating-change disclosure obligations that follow are traced in the non-convertible securities guide .
ESG rating providers are the oddity. State it plainly: there is no standalone ESG rating regulation on SEBI's regulations list. ERP registration sits inside the Credit Rating Agencies Regulations, 1999. Yet ERPs have a consolidation of their own. The Master Circular for ESG Rating Providers (ERPs) dated July 11, 2025. That inverts the normal reading order. For every other category on this page the regulation is the primary document and the master circular the operational companion; for an ERP, the master circular is the clearest statement of what the category actually is, and the regulation you register under is named after a different activity entirely. It is the sharpest example on SEBI's list of why "find the regulation for my category" is the wrong first question.
Index providers are governed by the Securities and Exchange Board of India (Index Providers) Regulations, 2024 , last amended November 28, 2024, with no dedicated master circular. The trigger is administering a significant index licensed for use in India. A registration obligation that can attach to a data or analytics business that has never thought of itself as a market intermediary.
Vault managers are governed by the Securities and Exchange Board of India (Vault Managers) Regulations, 2021 , last amended February 10, 2025, also with no dedicated master circular. The trigger is storing the underlying for electronic gold receipts. This is the category most often missed on the entire list, for a simple reason: the activity looks like logistics, not like a securities business. A vault, a weighing floor, an insurance policy and a goods-in register do not feel like regulated market infrastructure. But once what sits in the vault backs a traded instrument, SEBI registration follows.
| What you produce or hold | Category | Regulation | Master circular and date | Structural note |
|---|---|---|---|---|
| A credit rating on an instrument or issuer | Credit rating agency | SEBI (Credit Rating Agencies) Regulations, 1999. Last amended January 15, 2026 | Master Circular for Credit Rating Agencies (CRAs), July 11, 2025 | Regulation and master circular align normally |
| An environmental, social or governance rating | ESG rating provider | No standalone regulation. Registration sits within the SEBI (Credit Rating Agencies) Regulations, 1999 | Master Circular for ESG Rating Providers (ERPs), July 11, 2025 | Inverted: the master circular, not a dedicated regulation, is the operative day-to-day document |
| A significant index licensed for use in India | Index provider | SEBI (Index Providers) Regulations, 2024. Last amended November 28, 2024 | No dedicated master circular | Can attach to a data or analytics business |
| Physical gold underlying electronic gold receipts | Vault manager | SEBI (Vault Managers) Regulations, 2021. Last amended February 10, 2025 | No dedicated master circular | Most-missed category. The activity looks like logistics |
A Pune private limited company has advised exporters on DGFT incentives, EDPMS reconciliation and bank charges for six years, with no SEBI footprint at all. In 2026 it adds three services: a paid monthly report recommending listed commodity and logistics stocks, sent identically to every subscriber; one-to-one advice to a handful of promoter clients on their personal share portfolios, billed as a fee; and, for one of those promoters, discretionary management of a Rs. 60 lakh portfolio held in the promoter's own demat account. The founder assumes one registration covers all three. </> } result= >
Trace each revenue line separately, because SEBI registration attaches to the activity and not to the entity.
| Revenue line | The test applied | Category and two documents |
|---|---|---|
| 1. Existing DGFT, EDPMS and bank-charge advisory | Touches no security. Paid for, but outside SEBI's perimeter entirely. | No SEBI category triggered. Nothing to register. |
| 2. Identical subscription report recommending listed stocks | Impersonal research issued for consideration; no subscriber's circumstances shape it. | Research analyst. SEBI (Research Analysts) Regulations, 2014 (last amended November 25, 2025), with the Master Circular for Research Analysts dated February 6, 2026, and not the June 27, 2025 version still sitting directly beneath it on SEBI's page. |
| 3. Fee-bearing advice fitted to one promoter's own circumstances | Advice personalised to a particular client, for a fee. | Investment adviser. SEBI (Investment Advisers) Regulations, 2013 (last amended November 25, 2025), with the Master Circular for Investment Advisers dated February 6, 2026, again superseding a June 27, 2025 version. |
| 4. Discretionary authority over a segregated Rs. 60 lakh account | Authority to transact in the client's own account. Control, not opinion. | Portfolio manager. SEBI (Portfolio Managers) Regulations, 2020 (last amended September 3, 2025), with the Master Circular for Portfolio Managers dated July 16, 2025. |
| Counterfactual: twelve promoter clients pooled into one vehicle | Pooling crosses the dividing line in section 3. The category shifts off portfolio management altogether. | Alternative investment fund. SEBI (Alternative Investment Funds) Regulations, 2012 (last amended July 14, 2026), with the Master Circular for Alternative Investment Funds (AIFs) dated June 3, 2026. |
| Across all lines | Common gateway plus individual certification. | The common application and fit-and-proper test run through the SEBI (Intermediaries) Regulations, 2008 (last amended April 16, 2026); the staff advising clients are separately caught by the Certification of Associated Persons in the Securities Markets Regulations, 2007 (last amended July 15, 2025). |
How do I know the regulation or master circular I am holding is still current?
Everything above is only as good as the version you are reading, and SEBI's own pages will mislead a careful reader in three specific ways. None of them is a trick; each is a consequence of how the site archives documents. All three are worth knowing before you cite anything.
One: four master circulars appear twice. On SEBI's master circular listing, four categories carry both a current and a superseded consolidation, with the superseded version still displayed. Research Analysts. February 06, 2026 supersedes June 27, 2025. Investment Advisers. February 06, 2026 supersedes June 27, 2025. Registrars to an Issue and Share Transfer Agents. February 06, 2026 supersedes June 23, 2025. Issue of Capital and Disclosure Requirements. February 09, 2026 supersedes November 11, 2024. The arithmetic that follows matters: 25 master circulars are listed, but only 21 are live. Never quote 25 as the live count.
Two: four regulations carry no amendment date at all. The Stock Brokers Regulations, 2026; the Procedure for making, amending and reviewing of Regulations Regulations, 2025; the Registrars to an Issue and Share Transfer Agents Regulations, 2025; and the Appointment of Administrator and Procedure for Refunding to the Investors Regulations, 2018. For these, cite the base instrument by title and year. Do not manufacture an 'as amended' date. Not from a neighbouring entry, not from a commercial database, and not from the URL.
Three: the month-year in a sebi.gov.in URL is a posting date, not an issue date. The folder records when that version was posted to the site. The Listing Obligations and Disclosure Requirements Regulations, 2015 sit under a jul-2026 path; the regulations were made in 2015. This one catches out automated citation tooling constantly, because the URL is the most machine-readable thing on the page and the least reliable date on it. Never read an issue date off a link.
The verification drill is three lines long, and it is worth running on every instrument before it enters a filing or a manual.
- Open SEBI's own listing page for the category. The regulations listing or the master circular listing . Do not start from a search result.
- Take the topmost dated entry bearing that exact title. Where a title appears twice, the topmost is the live one and the lower is superseded.
- Read the date from the entry itself, not from the link. If the entry shows no amendment date, your citation has no amendment date either.
| Trap | What SEBI's page shows | What a reader wrongly concludes | Correct reading |
|---|---|---|---|
| Superseded master circulars still displayed | Research Analysts, Investment Advisers, RTA and ICDR each appear twice, current above superseded | That SEBI maintains 25 live master circulars, and that the first result found is the current one | 25 listed, 21 live . Take the topmost entry bearing the exact title; the lower one is superseded. |
| Regulations with no amendment date | Stock Brokers 2026, Procedure for making, amending and reviewing of Regulations 2025, RTA 2025 and Appointment of Administrator 2018 carry no 'last amended on' | That the date is simply missing from the display and can be sourced elsewhere | Cite the base instrument by title and year. No amendment date is shown, so none goes in the citation. |
| Month-year folder in the document URL | The LODR Regulations, 2015 sit under a /jul-2026/ path | That the instrument was issued or amended in July 2026 | The folder is when that version was posted . Read the year from the title and the amendment date from the listing entry. |
| Categories with no dedicated master circular | No entry for custodians, bankers to an issue, KYC registration agencies, index providers or vault managers | That the category is lightly regulated, or that the circulars must be filed under some other heading | The regulation plus the loose circulars issued under it is the whole of the law. There is nothing consolidated to find. |
Registration map: every SEBI category, its regulation and its master circular
This is the index the rest of the page exists to deliver: one row per category, the activity that triggers it, the regulation exactly as SEBI titles it, the amendment date SEBI shows (or the explicit absence of one) and the master circular that consolidates it, or the explicit absence of that. Nothing in a row is inferred. Where SEBI shows nothing, the row says so.
| Trigger activity | SEBI category | Regulation (exact title, year) | Last amended | Master circular and date |
|---|---|---|---|---|
| Managing and underwriting an issue of securities | Merchant banker | SEBI (Merchant Bankers) Regulations, 1992 | December 05, 2025 | Master Circular for Merchant Bankers, July 14, 2026 |
| Executing client orders on a stock exchange | Stock broker | SEBI (Stock Brokers) Regulations, 2026 | No amendment date shown | Master Circular for Stock Brokers, June 17, 2025 |
| Managing a client's segregated account with authority to transact | Portfolio manager | SEBI (Portfolio Managers) Regulations, 2020 | September 03, 2025 | Master Circular for Portfolio Managers, July 16, 2025 |
| Advice personalised to a client's circumstances for a fee | Investment adviser | SEBI (Investment Advisers) Regulations, 2013 | November 25, 2025 | Master Circular for Investment Advisers, February 06, 2026 |
| Impersonal research or recommendations to a subscriber base | Research analyst | SEBI (Research Analysts) Regulations, 2014 | November 25, 2025 | Master Circular for Research Analysts, February 06, 2026 |
| Pooling capital from sophisticated investors into one vehicle | Alternative investment fund | SEBI (Alternative Investment Funds) Regulations, 2012 | July 14, 2026 | Master Circular for Alternative Investment Funds (AIFs), June 03, 2026 |
| Pooling retail capital into publicly offered schemes | Mutual fund | SEBI (Mutual Funds) Regulations, 2026 | July 07, 2026 | Master Circular for Mutual Funds, March 20, 2026 |
| Running a pooled scheme that is neither an AIF nor a mutual fund | Collective investment scheme | SEBI (Collective Investment Scheme) Regulations, 1999 | December 05, 2025 | Not listed by that name among SEBI's master circulars |
| Investing into Indian securities as an offshore portfolio investor | Foreign portfolio investor | SEBI (Foreign Portfolio Investors) Regulations, 2019 | July 07, 2026 | Not listed by that name among SEBI's master circulars |
| Investing into Indian venture capital as an offshore vehicle | Foreign venture capital investor | SEBI (Foreign Venture Capital Investor) Regulations, 2000 | July 10, 2026 | Not listed by that name among SEBI's master circulars |
| Acting for debenture holders and holding the security | Debenture trustee | SEBI (Debenture Trustees) Regulations, 1993 | October 27, 2025 | Master Circular for Debenture Trustees (DTs), August 13, 2025 |
| Processing applications, allotment, transfers and the register | Registrar to an issue / share transfer agent | SEBI (Registrars to an Issue and Share Transfer Agents) Regulations, 2025 | No amendment date shown | Master Circular for Registrars to an Issue and Share Transfer Agents, February 06, 2026 |
| Receiving application money and handling the issue account | Banker to an issue | SEBI (Bankers to an Issue) Regulations, 1994 | February 10, 2025 | No dedicated master circular |
| Maintaining and sharing client KYC records across intermediaries | KYC registration agency | SEBI {KYC (Know Your Client) Registration Agency} Regulations, 2011 | February 10, 2025 | No dedicated master circular |
| Holding securities and related assets for clients | Custodian | SEBI (Custodian) Regulations, 1996 | July 08, 2026 | No dedicated master circular |
| Issuing a credit rating on an instrument or issuer | Credit rating agency | SEBI (Credit Rating Agencies) Regulations, 1999 | January 15, 2026 | Master Circular for Credit Rating Agencies (CRAs), July 11, 2025 |
| Issuing an environmental, social or governance rating | ESG rating provider | No standalone regulation. Registration sits within the SEBI (Credit Rating Agencies) Regulations, 1999 | January 15, 2026 (of the CRA Regulations) | Master Circular for ESG Rating Providers (ERPs), July 11, 2025 |
| Administering a significant index licensed for use in India | Index provider | SEBI (Index Providers) Regulations, 2024 | November 28, 2024 | No dedicated master circular |
| Storing the underlying for electronic gold receipts | Vault manager | SEBI (Vault Managers) Regulations, 2021 | February 10, 2025 | No dedicated master circular |
| Holding infrastructure assets in a listed trust for unit holders | InvIT | SEBI (Infrastructure Investment Trusts) Regulations, 2014 | April 17, 2026 | Master Circular for Infrastructure Investment Trusts (InvITs), July 11, 2025 |
| Holding rent-yielding real estate in a listed trust for unit holders | REIT | SEBI (Real Estate Investment Trusts) Regulations, 2014 | April 18, 2026 | Master Circular for Real Estate Investment Trusts (REITs), July 11, 2025 |
| Maintaining securities in dematerialised form, or serving clients as a participant | Depository / depository participant | SEBI (Depositories and Participants) Regulations 2018 | November 22, 2025 | Master Circular for Depositories, December 03, 2024 |
| Operating a trading venue, or clearing and settling trades | Stock exchange / clearing corporation | Securities Contracts (Regulation) (Stock Exchanges and Clearing Corporations) Regulations, 2018 | November 22, 2025 | Master Circular for Stock Exchanges and Clearing Corporations, December 30, 2024 |
This page answers which registration . The sibling page answers what you then file. The periodic returns, reports and certifications each category owes once it holds a registration, and by when: see the SEBI intermediary compliance calendar . Any term in a row above that is unfamiliar. Associated person, fit and proper, significant index, electronic gold receipt. Resolves in the glossary of SEBI capital market terms .
And if, having read the map, you conclude you are the issuer rather than the intermediary (the company raising the money rather than the firm serving it) then none of these categories applies to you and the six listed-company guides are where your obligations live: LODR disclosure and filing , raising capital under ICDR, buyback and ESOP , listing non-convertible securities , the debt-listed issuer's LODR chapter , insider trading and takeover, delisting and change of control .
Frequently asked questions
Does SEBI have 25 master circulars?
SEBI's master circular listing page displays 25 entries, but only 21 of them are live. Four categories appear twice, with the superseded version still shown on the page below the current one: Research Analysts, where the master circular dated February 6, 2026 supersedes the one dated June 27, 2025; Investment Advisers, where February 6, 2026 supersedes June 27, 2025; Registrars to an Issue and Share Transfer Agents, where February 6, 2026 supersedes June 23, 2025; and Issue of Capital and Disclosure Requirements, where February 9, 2026 supersedes November 11, 2024. Quoting 25 as the number of live consolidations is therefore wrong. The count is not a count of regulated categories either: several large registration categories have no dedicated master circular at all, including custodians, bankers to an issue, KYC registration agencies, index providers and vault managers, where the regulation plus the loose circulars issued under it is the whole of the operative law.
I publish a paid stock-recommendation newsletter. Do I need research analyst or investment adviser registration?
If every subscriber receives the same report and no recommendation is fitted to an individual subscriber's circumstances, that is research analyst activity under the Securities and Exchange Board of India (Research Analysts) Regulations, 2014, last amended November 25, 2025, consolidated by the Master Circular for Research Analysts dated February 6, 2026. Investment adviser registration under the Securities and Exchange Board of India (Investment Advisers) Regulations, 2013, last amended November 25, 2025, is triggered instead by advice personalised to a particular client's circumstances for a fee. The two are not alternatives. A firm that publishes an impersonal newsletter and separately advises named clients for a fee needs both registrations, and if it also holds authority to transact in a client's own segregated account it needs a third under the Securities and Exchange Board of India (Portfolio Managers) Regulations, 2020, last amended September 3, 2025. Build your compliance manual from the February 6, 2026 master circulars, not the June 27, 2025 versions SEBI still displays beneath them.
Which SEBI regulations show no amendment date, and what should I cite instead?
Four, on SEBI's own regulations listing page: the Securities and Exchange Board of India (Stock Brokers) Regulations, 2026; the Securities and Exchange Board of India (Procedure for making, amending and reviewing of Regulations) Regulations, 2025; the Securities and Exchange Board of India (Registrars to an Issue and Share Transfer Agents) Regulations, 2025; and the Securities and Exchange Board of India (Appointment of Administrator and Procedure for Refunding to the Investors) Regulations, 2018. None of these carries a 'last amended on' date in SEBI's own entry. Cite the base instrument by its exact title and year, and stop there. Do not append an 'as amended' date inferred from a neighbouring entry, from the month-year folder in the URL, or from a commercial database, because SEBI's listing does not show one.
Can I work out when a SEBI regulation was issued from its sebi.gov.in URL?
No. The month-year folder in a sebi.gov.in path records when that particular version of the document was posted to the site, not when the instrument was issued or when it was last amended. The Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 sits under a jul-2026 path, but the regulations were made in 2015. Read the year from the instrument's own title and read the amendment date from the listing entry itself. A URL is an address, not a date stamp, and every citation built by reading dates off links will eventually be wrong.
Do ESG rating providers have their own SEBI regulation?
No. There is no standalone ESG rating regulation on SEBI's regulations listing. ESG rating provider registration sits inside the Securities and Exchange Board of India (Credit Rating Agencies) Regulations, 1999, last amended January 15, 2026. ERPs do, however, have a master circular of their own: the Master Circular for ESG Rating Providers (ERPs) dated July 11, 2025, separate from the Master Circular for Credit Rating Agencies (CRAs) of the same date. That makes ERPs the clearest case on SEBI's whole list where the master circular, rather than a dedicated regulation, is the operative day-to-day document for a category. A registered ERP reads its eligibility and conduct obligations out of a credit rating regulation and its working obligations out of an ESG-specific consolidation.
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