**Summary:**
This circular, reference number SEBI/HO/MIRSD/MIRSDPoD/P/CIR/2025/116, issued by the Securities and Exchange Board of India (SEBI) on August 12, 2025, addresses the use of liquid mutual funds and overnight mutual funds for compliance with deposit requirements by registered Investment Advisers (IAs) and Research Analysts (RAs).
Previously, Regulation 8 of the SEBI Investment Advisers Regulations, 2013 (IA Regulations) and the SEBI Research Analysts Regulations, 2014 (RA Regulations) mandated that IAs and RAs maintain a specified deposit with a scheduled bank, marked as a lien in favor of the Investment Adviser Administration and Supervisory Body (IAASB) or Research Analyst Administration and Supervisory Body (RAASB).
Based on industry representations and public consultation, the SEBI Board approved an amendment allowing IAs and RAs to use liquid mutual funds and overnight mutual funds as an alternative to bank deposits for meeting these requirements. The SEBI Research Analysts Amendment Regulations, 2025, and the SEBI Investment Advisers Amendment Regulations, 2025, were notified on August 6 and August 7, 2025, respectively.
IAs and RAs can now maintain the required deposit in the form of units of liquid mutual funds, overnight mutual funds, or a deposit with a scheduled bank, all marked as a lien in favor of the IAASB or RAASB. Compliance with these deposit requirements must be achieved by September 30, 2025.
BSE Limited, IAASB, and RAASB are directed to implement the necessary systems and procedures for this circular's provisions and to inform IAs and RAs accordingly.
This circular is issued under the powers conferred by Section 11(1) of the Securities and Exchange Board of India Act, 1992, read with Regulation 8 of the IA Regulations, 2013, and RA Regulations, 2014, to protect investor interests and regulate the securities market. The circular is effective from the date of issuance and is available on the SEBI website (www.sebi.gov.in) under "Legal Circulars."
For further information, contact Aradhana Verma, General Manager, at 022-26449633 or aradhana@sebi.gov.in.
Key Entities Referenced
Securities and Exchange Board of India (SEBI): The regulatory authority issuing the circular.
Investment Advisers (IAs): Entities registered with SEBI, providing investment advice.
Research Analysts (RAs): Entities registered with SEBI, providing research reports or recommendations.
SEBI Investment Advisers Regulations, 2013: Regulations governing investment advisors.
SEBI Research Analysts Regulations, 2014: Regulations governing research analysts.
Investment Adviser Administration and Supervisory Body (IAASB): Body responsible for administration and supervision of Investment Advisers.
Research Analyst Administration and Supervisory Body (RAASB): Body responsible for administration and supervision of Research Analysts.
BSE Ltd.: Bombay Stock Exchange, directed to implement the circular's provisions.
CIRCULAR
SEBI/HO/MIRSD/ MIRSD-PoD/P/CIR/2025/116 August 12, 2025
To,
All registered Investment Advisers
All registered Research Analysts
BSE Ltd. (Investment Adviser Administration and supervisory body- IAASB and
Research Analyst Administration and Supervisory Body- RAASB)
Sir / Madam,
Sub: Use of liquid mutual funds and overnight mutual funds for compliance with
deposit requirement by Investment Advisers and Research Analysts
1. In terms of regulation 8 of SEBI (Investment Advisers) Regulations, 2013 (‘IA
Regulations’) and SEBI (Research Analysts) Regulations, 2014 (‘RA Regulations’),
Investment Advisers (‘IAs’) and Research Analysts (‘RAs’) are required to maintain
a deposit of such sum as specified by SEBI from time to time. Such deposit was
required to be maintained with a scheduled bank marked as lien in favour of
Investment Adviser Administration and Supervisory body (IAASB) or Research
Analyst Administration and Supervisory body (RAASB), as the case may be.
2. Based on the representations from industry participants and inputs received
through public consultation, SEBI Board in its meeting held in June 2025 has
approved the proposal to allow IAs and RAs to use liquid mutual funds and
overnight mutual funds, as an option to the bank deposit, for compliance with
deposit requirement as specified under IA Regulations and RA Regulations. In this
regard, SEBI (Research Analysts) (Amendment) Regulations, 2025 and SEBI
Page 1 of 2(Investment Advisers) (Amendment) Regulations, 2025 have been notified by SEBI
on August 06 and August 07, 2025 respectively.
3. In order to ensure compliance with the deposit requirements under regulation 8 of
IA Regulations and RA Regulations, IAs and RAs shall now maintain a deposit in
the form of units of liquid mutual fund or an overnight mutual fund or as a deposit
maintained with a scheduled bank. Such deposit shall be marked as lien in favour
of IAASB or RAASB, as the case may be.
4. IAs and RAs shall comply with the deposit requirements latest by September 30,
2025.
5. IAASB/RAASB (BSE Limited) is hereby directed to put in place necessary systems
and procedures for implementation of the provisions of this circular and bring the
same to the notice of IAs/RAs.
6. The provisions of this circular shall come into effect from the date of issuance of
this circular.
7. This circular is issued in exercise of powers conferred under section 11(1) of the
Securities and Exchange Board of India Act, 1992 read with Regulation 8 of SEBI
(Investment Advisers) Regulations, 2013 and SEBI (Research Analysts)
Regulations, 2014 to protect the interests of investors in securities market and to
promote the development of, and to regulate the securities market.
8. This circular is available on the SEBI website at www.sebi.gov.in under the
category "Legal Circulars".
Yours faithfully,
Aradhana Verma
General Manager
Tel. No. 022-26449633
aradhanad@sebi.gov.in
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