In India, a Research Analyst (RA) publishes research and recommendations for public or client-wide use; they cannot give personalised advice. A Registered Investment Adviser (RIA/IA) gives personalised, fiduciary advice under SEBI’s IA Regulations with capped fees. “Algo providers” are not a separate SEBI-registered category; their tools fall under exchange/SEBI frameworks, and if they provide advice (signals/strategies), they may need IA/RA registration. (Securities and Exchange Board of India, Avantis CDN Storage, NSE India)
What each term means
Research Analyst (RA)
A person or entity registered with SEBI under the SEBI (Research Analysts) Regulations, 2014 to prepare and publish research reports or give public recommendations. RAs must meet education/certification norms (NISM-Series XV) and follow conduct & disclosure rules. They do not provide personalised advice. (NISM, High Court of Tripura)
Registered Investment Adviser (RIA / IA)
An individual or entity registered under the SEBI (Investment Advisers) Regulations, 2013 to provide personalised investment advice for a fee, with mandatory client risk profiling, documentation and a fiduciary duty. Fee caps (for individuals/HUFs) apply under SEBI’s latest guidelines. (Securities and Exchange Board of India, Avantis CDN Storage)
“Algo Provider”
There is no distinct SEBI registration called “Algo Provider.” In practice, this refers to firms or developers offering algorithmic trading tools/APIs/strategies. Their activities are governed by SEBI and exchange circulars on retail algo trading, API enablement, tagging, approvals/thresholds and broker oversight. If they sell signals/strategies as advice, IA/RA registration may be triggered. (NSE India, Economic Laws Practice, Finsec Law Advisors)
Side-by-side comparison (for quick due diligence)
| Lens | Research Analyst (RA) | Registered Investment Adviser (RIA) | “Algo Provider” |
| Governing framework | SEBI RA Regulations, 2014 | SEBI IA Regulations, 2013 (with 2020 & 2025 updates) | SEBI/exchange circulars on API & retail algos; not a separate license |
| Core service | Publish research reports / recommendations (general, not tailored) | Personalised advice after risk-profiling & suitability | Tools/APIs/execution logic; if signals amount to advice → IA/RA may apply |
| Certification | NISM Series-XV (RA) | NISM IA (Level 1 & 2) or equivalent + qualification & experience | No dedicated “algo provider” cert; brokers/exchanges impose tech/ops standards |
| Fees | Typically subscription/retainership; no IA fee caps | Capped for individuals/HUFs: Fixed up to ₹1.51 lakh/year per family or 2.5% AUA | Tool/platform fees; cannot accept client funds/securities for advice unless registered & permitted |
| Conflicts/Conduct | Strong disclosures; trading blackout 30 days before & 5 days after reports | Fiduciary duty; client-level segregation from distribution; documentation & agreement | Broker controls, order tagging, risk disclosures; some algos require exchange registration/limits (e.g., OPS thresholds) |
| Can execute trades? | Not by virtue of RA license | Advice is separate from execution; arm’s-length if group entities distribute | Execution via broker APIs; broker responsible for controls/limits |
(NISM, Securities and Exchange Board of India, Avantis CDN Storage, Vinod Kothari Consultants, NSE India, Finsec Law Advisors)
What each can and cannot do
Research Analyst (RA)
Can:
- Publish equity/debt/sector research, model portfolios (as non-personalised content), and appear in media with appropriate disclosures.
- Charge subscription/retainer for research access. (High Court of Tripura)
Cannot (key restrictions):
- Give personalised advice to a specific client (that is IA territory).
- Trade in securities they cover 30 days before and 5 days after a report; avoid trading contrary to recommendations; IPO participation limits also apply. (Securities and Exchange Board of India, Business Today)
Registered Investment Adviser (RIA)
Can:
- Provide tailored advice post risk profiling and suitability assessment; sign an advisory agreement; maintain records.
- Charge fees under two modes: Fixed (₹1.51 lakh/year) per client family or AUA (2.5% p.a.) for individuals/HUFs. (Avantis CDN Storage)
Cannot (key restrictions):
- Mix advisory and distribution for the same client at the group level (client-level segregation).
- Accept client funds/securities except advisory fees; must act as fiduciary. (Vinod Kothari Consultants, King Stubb & Kasiva)
Algo Provider
Can (subject to broker/exchange rules):
- Offer execution tools/strategies via broker APIs with order-level tagging, logging and controls.
- On certain thresholds (e.g., orders-per-second), algos must be registered/tagged as per implementation standards. (NSE India, Finsec Law Advisors)
Cannot / Must not:
- Market personalised buy/sell calls to paying clients without proper registration (that can be unregistered IA).
- Bypass exchange/SEBI controls—brokers must enforce session logouts, tagging, approvals and client consents under new API standards. (NSE India)
Investor alert: SEBI has taken action against unregistered advisory/tips services (including social media “finfluencers”). If you receive paid, specific “buy this now” calls from a non-registered entity, treat it as unregistered investment advice. (MSEI, Economic Times)
Practical Indian scenarios (so you can decide quickly)
- You want a stock newsletter and model watchlist.
Pick an RA. You get research, disclosure-rich reports and sector notes—not personalised allocation advice. (High Court of Tripura) - You want a family asset-allocation plan (equity/debt/AIFs) with rebalancing and on-call advice.
Pick an RIA. Expect risk profiling, documented suitability and a fee model within ₹1.51 lakh fixed or 2.5% AUA for individuals/HUFs. (Avantis CDN Storage) - You want to automate your strategy on your broker account.
Use an exchange-compliant algo via your broker’s API. Ensure your provider/broker follows tagging, thresholds and logout/controls mandated by NSE’s 2025 standards. If the “algo” also advises you what to buy/sell for a fee, check for IA/RA registration. (NSE India, Finsec Law Advisors)
Compliance checklists (use before engaging)
For RAs
- SEBI RA registration number appears on website/reports.
- NISM XV certification valid; clear disclosures on conflicts/holdings.
- Observe trading blackout rules (30 days before, 5 days after). (NISM, Securities and Exchange Board of India)
For RIAs
- SEBI IA registration number and compliance officer listed.
- Mandatory client agreement, risk profile, suitability notes provided.
- Fee mode within ₹1.51 lakh fixed or 2.5% AUA (individuals/HUFs).
- Confirm client-level segregation from distribution (no commission conflict). (Avantis CDN Storage, Vinod Kothari Consultants)
For Algo Providers/Platforms
- Confirm your broker is enabling API access and tagging algo orders.
- If you exceed defined performance thresholds (e.g., OPS), ensure exchange registration as required.
- Watch for circular-mandated daily session logouts, audit logs and client consents. (Finsec Law Advisors, NSE India)
FAQs
Is a model portfolio behind a paywall “advice”?
If it is generic and the same for all subscribers, it typically falls under RA-style research. Once it is tailored to your profile or specific portfolio, it becomes investment advice, requiring IA registration. (Securities and Exchange Board of India)
What are the latest IA fee caps?
For individuals/HUFs, fixed fees up to ₹1.51 lakh per family per year, or 2.5% AUA—as per SEBI’s 2025 guidelines/master circular. (Avantis CDN Storage)
Do algo tools need SEBI registration?
Tools per se don’t have a separate SEBI license, but their use is regulated via exchange/SEBI circulars; some algos require exchange registration/tagging and must operate through brokers with mandated controls. If the provider also advises, IA/RA registration may be required. (NSE India, Finsec Law Advisors)
Can an RIA also distribute mutual funds to me?
Not for the same client within the group; SEBI mandates client-level segregation between advisory and distribution to avoid conflicts. (Vinod Kothari Consultants)
What qualifies someone as an RA?
SEBI registration + qualifications and NISM Series-XV certification (or equivalent) are required to issue research reports/recommendations. (NISM)
Key takeaways for Indian investors & HNIs
- RAs are for high-quality research and broad recommendations; RIAs are for personalised, fiduciary advice with fee caps and documentation.
- “Algo providers” must operate within strict broker/exchange controls; if they sell advice, they need IA/RA registration.
- Always verify registration numbers, disclosures, fee structures, and operational compliance before you subscribe or connect your account. (Securities and Exchange Board of India, Avantis CDN Storage, NSE India)
Compliance note: Regulations evolve; verify circular numbers and broker implementations before making arrangements.