SEBI Website Compliance Checklist for Investment Advisers and Research Analysts (2026 Guide)

Your website is often the first point of contact with a prospective client - and for SEBI-registered Investment Advisers (IAs) and Research Analysts (RAs), it doubles as a regulatory touchpoint. An outdated or non-compliant website can invite inspection observations, investor complaints, and reputational damage, well before a client ever signs an engagement letter.

2025 was an unusually active year for SEBI on this front. Beyond the familiar disclosure norms, IAs and RAs now face a specific, time-bound digital accessibility mandate, updated Most Important Terms and Conditions (MITC) requirements, and continued scrutiny of advertising content. This guide walks through what a compliant website should cover in 2026.

Why Website Compliance Matters

SEBI has steadily widened its focus on investor protection, fair disclosure, and digital accessibility. As advisory and research services move increasingly online, a website is no longer just a marketing surface - it functions as an extension of the entity's compliance framework.

Whether you are an IA or an RA, your website should accurately reflect your registration status, the services you are permitted to offer, your fee structure, and your grievance redressal process, while remaining usable by all visitors, including persons with disabilities.

Gaps here typically surface during SEBI inspections or annual compliance audits, and they are avoidable with a periodic review.

1. Display Registration and Identity Details Prominently

Every SEBI-registered IA and RA should clearly display, typically in the website footer and on a dedicated Contact/About page:

• SEBI registration number and registration category (IA / RA)
• Legal name of the entity and type (individual, partnership, LLP, or body corporate)
• Registered office address and contact details
• Name and contact details of the Compliance Officer / Principal Officer
• Grievance redressal contact information, including SCORES and the applicable RAASB/IAASB details (BSE Limited has been recognised as both the Research Analyst Administration and Supervisory Body and the Investment Adviser Administration and Supervisory Body)

1. Publish Mandatory Investor Disclosures - Including the Updated MITC

Investors should be able to locate key regulatory disclosures without difficulty. These generally include:

• Risk disclosures and conflict-of-interest disclosures
• The Investor Charter applicable to IAs/RAs
• Terms and Conditions, Privacy Policy, and Disclaimer
• Complaint redressal mechanism, including timelines and escalation

A point often missed in older website reviews: SEBI's guidelines for IAs and RAs (effective February 2025) made Most Important Terms and Conditions (MITC) mandatory. For IAs, MITC must be built into the advisory agreement; for RAs, it must be incorporated into the terms and conditions, with client consent obtained and records maintained. MITC typically covers scope of service, fee structure and caps, a clear statement that the IA/RA will not execute trades on the client's behalf, the conflict-of-interest policy, grievance redressal, termination terms, and disclosure of any use of AI tools in advice or research. If your website's T&C page or client agreement template hasn't been refreshed since early 2025, this is the first place to check.

RAs should also confirm their website reflects current fee caps and disclosure norms under the Master Circular for Research Analysts, including disclosure of AI use in research reports where applicable.

1. Ensure Advertisement Code Compliance

Website content - including landing pages, blogs, and social posts linked from the site - is treated as advertisement under SEBI's framework. Avoid:

• Assured or guaranteed return claims
• Misleading or unverifiable performance statements
• Cherry-picked testimonials or unverified rankings
• Superlative claims ("best," "No. 1," "guaranteed") without documented substantiation

Marketing content should be fair, balanced, and capable of being backed up if SEBI or RAASB/IAASB asks for evidence.

1. Digital Accessibility Is Now a Specific, Time-Bound Mandate

This is the area where generic compliance checklists tend to understate the requirement. SEBI issued a circular dated July 31, 2025 (and a follow-up on August 29, 2025 addressing timelines specifically for IAs and RAs) making digital accessibility mandatory for all SEBI-regulated entities. This followed an April 2025 Supreme Court ruling that recognised digital access as part of the right to life and personal liberty under Article 21 of the Constitution.

Under this framework, IA and RA websites, client portals, and investor-facing documents are expected to:

• Comply with the Rights of Persons with Disabilities Act, 2016 and its Rules, and align with WCAG
2.1 Level AA, the Guidelines for Indian Government Websites (GIGW), and IS 17802:2022
• Support screen readers and full keyboard navigation
• Provide descriptive alt text for images and charts
• Provide captions/transcripts for video and webcast content
• Designate a senior nodal officer responsible for accessibility compliance
• Maintain a grievance redressal channel specifically for accessibility issues

SEBI has since issued further clarifications (including a circular dated December 8, 2025) on reporting formats and readiness timelines. Because this area continues to evolve, IAs and RAs should track the accessibility circulars on SEBI's website directly rather than relying on a static checklist, and consider a formal accessibility audit rather than treating this as a design afterthought.

1. DPDP Act Compliance

If your website collects client enquiries, newsletter sign-ups, contact form submissions, KYC information, or cookies/analytics data, you also have obligations under the Digital Personal Data Protection Act, 2023. This means maintaining a clear privacy notice, obtaining valid consent where required, and having a defined process for data retention and grievance handling.

1. Keep Regulatory Documents Updated

Given how frequently SEBI has amended IA/RA norms through 2025, website documents can go stale quickly. Review at least:

• The Investor Charter
• Fee disclosures and fee caps
• Complaint-handling process and timelines
• MITC and terms of engagement
• Any AI-use disclosures in research or advice

1. Secure the Website

Cybersecurity is part of investor protection. Baseline controls include HTTPS/SSL, secure and updated hosting, regular software patching, backup procedures, malware monitoring, and multi-factor authentication for administrator access.

1. Review Website Content Periodically

Website compliance isn't a one-time task at the time of registration. A periodic review should check that regulatory references and registration details are current, contact information is accurate, broken links and expired announcements are removed, and marketing content still meets current advertisement norms.

Final Thoughts

A well-designed website is valuable; a SEBI-compliant one is a safeguard - for both the regulated entity and the investors relying on it. With MITC now mandatory, digital accessibility on a firm compliance timeline, and continued scrutiny of advertising and disclosures, IAs and RAs should treat website compliance as a recurring item on the annual compliance calendar, not a one-time project.

Frequently Asked Questions

Is a website mandatory for every SEBI-registered Investment Adviser or Research Analyst?

SEBI's regulations prescribe disclosure and communication requirements rather than mandating a website outright. However, where an IA or RA maintains a website, it must accurately reflect current regulatory disclosures, MITC, and registration details.

Is website content treated as an advertisement?

Yes. Promotional website content must comply with SEBI's advertisement-related norms and must not contain misleading statements, exaggerated claims, or promises of assured returns.

Does the SEBI digital accessibility mandate really apply to smaller IA/RA practices? Yes. The July 2025 circular and its follow-ups apply to all SEBI-regulated entities, including individual and small-practice IAs and RAs, though timelines for this category were extended via the August 2025 circular. It's worth checking the latest circular for your specific compliance deadline rather than assuming exemption based on size.

How often should a website compliance review be conducted? At minimum, annually - and additionally whenever SEBI issues a material regulatory change, such as the 2025 MITC and accessibility mandates.

Is your website SEBI compliant?

KP RegTech assists Investment Advisers and Research Analysts with comprehensive website compliance reviews - covering regulatory disclosures, MITC, digital accessibility, DPDP Act privacy compliance, advertisement review, cybersecurity best practices, and annual compliance readiness. Contact our team to schedule a website compliance assessment before your next SEBI audit.