Notice No – 20250702-39
Date 02 Jul 2025
Guidelines for Annual Compliance Audit requirement (RAs)
This is with reference to SEBI Circular no. SEBI/HO/MIRSD/ MIRSD-PoD-1/P/CIR/2025/004 dated January 8, 2025, and the Exchange Notice no. 20250110-3 dated January 10, 2025, with respect to Guidelines for Research Analysts.
Point 2(xiv) of the above-mentioned circular details about Annual Compliance Audit requirements:
a) As per regulation 25(3) of the RA Regulations, RA or research entity shall conduct annual audit in respect of compliance with RA Regulations.
b) Annual compliance audit report shall specify each of the provisions of the RA Regulations and the circulars and guidelines issued thereunder upon which compliance is reported.
c) A research analyst or research entity shall –
(i) complete the annual compliance audit within six months from the end of each financial year and submit a compliance audit report to RAASB/SEBI within a period of one month from the date of the audit report.
(ii) submit adverse findings of audit, if any, along with action taken thereof duly approved by the individual RA or management of non-individual RA or research entity to RAASB/SEBI within a period of one month from the date of the audit report but not later than October 31st of each year for the previous financial year; and
(iii) maintain on record an annual certificate from a member of ICAI/ ICSI/ICMAI or from an auditor confirming compliance with client level segregation requirements. Such annual certificate shall form part of the compliance audit.
d) RA/research entity shall publish the status of the compliance audit report on its website and shall also publish the adverse findings of audit, if any, along with the action taken thereof on its website. RA/research entity shall provide the compliance audit report to its clients.
e) RA/research entity shall ensure compliance with the additional audit requirements under this clause starting with for audit report of the financial year ending March 31,2025.
In view of the above, the format for the “Annexure to the audit report” has been attached herewith in which the auditor shall specify compliance against each of the provisions of the RA Regulations and the circulars and guidelines.
It may be noted that portal for uploading the ACR is under development which will facilitate seamless submission of audit report, annexure to audit report, client level segregation certificate and Action taken report for adverse findings during audit by Research Analysts. RAs will have 2 options for submission i.e. by appointing auditor through system or direct submissions by RAs.
The process flow for both the modes is explained in attached flow chart.
Please note that only portal-based submission shall be considered. Submission through email shall not be considered.
Golive date for the ACR module shall be intimated via separate circular. Post which the Research Analysts shall use their existing RA login credentials of the Exchanges used for periodic submission / registration for ACR submission. There is NO need to create new logins for this purpose. In case you are unaware about your login credentials please mark an email on [email protected]
All the Research Analysts are advised to take note and comply.
For and on behalf of BSE Ltd.
Meghana Kulkarni
Deputy Vice President Membership Operations & Membership Compliance
Neeky Subramaniam
Manager Membership Operations & Membership Compliance
