SEBI RA Penalty Tracker — every BSE/RAASB penalty for Research Analysts
One place to see what attracts a penalty and how much. Below is the standardised BSE/RAASB penalty structure for Research Analyst non-compliances, grouped by area, followed by the separate SEBI Act penalties for serious breaches.
Source: BSE (RAASB) Notice No. 20260429-16, dated 29 April 2026 — “Penalty Structure for Research Analysts”, Annexure A; effective 1 May 2026 (applies to non-compliances observed on/after that date).
Two separate regimes: the amounts below are exchange-levied by BSE/RAASB. SEBI Act penalties (e.g. Section 15EB — up to ₹1 crore) are imposed separately by SEBI through adjudication for more serious breaches.
Kept current: our Circulars page auto-tracks new BSE/SEBI notices, so we update this table whenever the structure is revised.
Two separate regimes: the amounts below are exchange-levied by BSE/RAASB. SEBI Act penalties (e.g. Section 15EB — up to ₹1 crore) are imposed separately by SEBI through adjudication for more serious breaches.
Kept current: our Circulars page auto-tracks new BSE/SEBI notices, so we update this table whenever the structure is revised.
Most items give a warning on the first instance, with the amount applying from the second time onwards (unless stated otherwise). Where dues/penalties stay unpaid, BSE can restrict onboarding of new clients. The official Annexure A is authoritative — always confirm on bseindia.com.
Audit & periodic reporting
| Non-compliance | Penalty |
|---|---|
| Annual compliance audit not conducted within timeline (Reg. 25(3)) | ₹25,000 per violation |
| Late submission of the Annual Compliance Audit Report | ₹100/day (1st month) → ₹200/day (2nd month); unpaid > 2 months → new-client onboarding restricted |
| Late submission of the periodic (half-yearly) report to RAASB | ₹100/day (1st month) → ₹200/day (2nd month); same onboarding restriction if unpaid |
Registration, changes & deposit
| Non-compliance | Penalty |
|---|---|
| No prior SEBI approval for change in control / partner / legal formation / ownership (Reg. 24(3)) | ₹25,000 per violation |
| Failure to communicate a material change in information already submitted (Reg. 13(ii)) | ₹5,000 (1st) → ₹10,000 thereafter |
| Failure to meet qualification / renewal-certification requirements (Reg. 7) | Warning, then ₹5,000 |
| Failure to maintain the required deposit | New-client onboarding restricted until replenished (withdrawal shortfall to be made good within 30 days) |
Website, disclosures & Investor Charter
| Non-compliance | Penalty |
|---|---|
| Not displaying monthly complaint data / Investor Charter / SaaS advisory undertaking / ATR for adverse audit findings; missing identity info (RA name, logo, reg. no., grievance officer, disclaimer) | ₹5,000 per violation |
| Failure to maintain a functional website with the specified details (Reg. 19A) | Warning + 30 days to fix, then ₹5,000 per month (or part) of continued non-compliance |
Advertisements & public media
| Non-compliance | Penalty |
|---|---|
| Advertisement issued without prior RAASB approval | Warning (1st) → ₹5,000/ad (2nd) → ₹10,000/ad thereafter; ad freeze for 3 months after 3 instances |
| Advertisement content breaching the Advertisement Code (false/misleading, assured returns, “best/authentic”, MII-affiliation, profit screenshots, inducing more capital) | ₹10,000/ad (1st) → ₹20,000/ad thereafter; 3-month freeze after 3; immediate takedown |
| Recommendations in public media without disclosing registration status / finfluencer / associate details (Reg. 21) | Warning, then ₹5,000 per violation from the 2nd time |
| Past-performance breaches — non-audited historical performance, or missing disclaimers | ₹10,000 (1st) → ₹20,000 (2nd/3rd); 3-month onboarding restriction after 3 |
Research reports & disclosures
| Non-compliance | Penalty |
|---|---|
| Failure to make Reg. 19 disclosures (financial interest / beneficial ownership, material conflicts, compensation from subject company) | ₹10,000 per violation |
| Non-compliance with contents-of-research-report requirements (Reg. 20) | ₹10,000 (1st) → ₹20,000 thereafter |
| Non-compliance with limitations on publication / public appearance / conduct (Reg. 18) | Warning, then ₹10,000 from the 2nd time |
| Extent of AI-tool use not disclosed to clients | ₹10,000 |
Fees, MITC & client onboarding
| Non-compliance | Penalty |
|---|---|
| Charging fees in breach of the fee provisions (Reg. 15A/26C, Master Circular Para 1.9) | Warning + refund (1st) → ₹10,000 from the 2nd time |
| Failure to prepare/incorporate/disclose the MITC, or disclose T&C / obtain client consent | ₹1,000 per client, up to a maximum of ₹25,000 |
Segregation & part-time limits
| Non-compliance | Penalty |
|---|---|
| Failure to maintain client-level segregation of research & distribution | ₹10,000 per client; if > 10 clients affected → ₹1 lakh + prohibition on onboarding + reference to SEBI |
| Part-time RA breaching the client-number limit (max 75 clients) | Warning (1st) → ₹10,000 per violation thereafter |
Trading independence & conduct
| Non-compliance | Penalty |
|---|---|
| Breach of trading/dealing limitations (Reg. 16 — 30 days before / 5 days after window, etc.) | ₹10,000 per violation |
| Failure to maintain mechanisms ensuring independence of research (Reg. 15) | ₹10,000 per violation |
| No written internal policies / control procedures for analyst dealing/trading | Warning, then ₹5,000 from the 2nd time |
| Code of Conduct violation (Third Schedule) | ₹5,000 (1st) → ₹10,000 per instance thereafter |
KYC, records, PMLA
| Non-compliance | Penalty |
|---|---|
| KYC non-compliance | Warning, then ₹5,000 |
| Non-maintenance of records (Reg. 25(1)/(2): research reports, KYCs, communications, audit reports) | Warning, then ₹5,000 |
| PMLA/AML policy non-compliance or failure to intimate FIU-IND | ₹5,000 |
Grievances, inspection & compliance officer
| Non-compliance | Penalty |
|---|---|
| Non-redressal of client grievances within timeline / non-compliance with an arbitration or conciliation order | ₹100/complaint/day (1st month) → ₹200/complaint/day (2nd month); from 3rd month, name may be published under SEBI’s “name & shame” policy |
| Non-submission of data for inspection (Reg. 29), even after two reminders | ₹5,000 + ₹200/day up to 7 days, after which the matter is referred to SEBI |
| Non-individual RA fails to appoint a compliance officer / independent professional (Reg. 26) | ₹20,000 for the first three months, then ₹20,000 per month (or part) |
SEBI Act penalties (separate — SEBI-adjudicated)
For more serious breaches, SEBI itself imposes penalties through formal adjudication (Section 15-I), independent of the exchange schedule above:
| Provision | Penalty |
|---|---|
| Section 15EB — failure by an RA/IA to comply with SEBI regulations or directions | Not less than ₹1 lakh, up to ₹1 lakh per day of continuing failure, subject to a maximum of ₹1 crore |
| Section 15HB — residual/catch-all contravention with no specific penalty elsewhere | ₹1 lakh up to ₹1 crore |
These are levied by an Adjudicating Officer after a hearing under Section 15-I — not as an automatic schedule. Serious matters (e.g. assured returns, fraud, false documents) can also lead to suspension or cancellation of registration.
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Disclaimer
This is a plain-English summary of the BSE/RAASB penalty structure (Notice 20260429-16, Annexure A) and relevant SEBI Act provisions, compiled with the help of AI. It is for general information only and is not legal, compliance, tax or investment advice. Penalty amounts, conditions and item coverage may change; the official Annexure A on bseindia.com is authoritative.
Always verify the current requirement and amount from the official BSE / SEBI sources, or consult a qualified professional, before relying on it. RA Sahayak is a free, non-commercial resource and is not affiliated with SEBI, BSE, or any regulator.