Investment Advisory

Every serious investment adviser in India has faced the same inflection point: you have the expertise, you have clients counting on your guidance, and you are ready to build a practice. But operating without SEBI registration exposes you to penalties under the SEBI Act 1992, client trust issues, and the risk of a compliance notice that can halt your business overnight. In 2026, as retail and HNI investment volumes expand and SEBI actively scrutinises advisory compliance, unregistered practice is no longer a grey area, it is a liability. SEBI (Investment Advisers) Regulations, 2013, as amended in 2020, governs this space. Under Section 12 of the SEBI Act 1992, any person providing investment advice for securities or mutual funds in exchange for fees, commissions, or any form of consideration must be registered with SEBI as an Investment Adviser. The 2020 amendment tightened net worth requirements, mandated risk profiling under Regulation 19, and introduced audit trail obligations that did not exist before. KAMRIT Financial Services LLP handles the complete SEBI IA registration lifecycle: net worth assessment, NISM Series-V-A certification roadmap, infrastructure and compliance setup, SEBI portal application filing, query response management, and the ongoing quarterly and annual compliance obligations under Regulations 22, 23 and 24. We work with individual advisers, RIAs, portfolio managers seeking dual registration, and financial services firms building advisory desks.

What is Investment Advisory?

Investment Advisory as a regulated activity in India means any person, sole proprietorship, partnership firm, LLP, or company that, for a fee, commission, or any form of consideration, directs or advises a client to buy, sell, or otherwise deal in securities, mutual funds, or market-linked investment products. This definition is drawn directly from Regulation 2(1)(k) of the SEBI (Investment Advisers) Regulations, 2013. It is important to distinguish Investment Advisory from Investment Distribution. An adviser charges a fee directly for advice and must not earn shelf-space or trail commissions from the products recommended under Regulation 23. A distributor earns from product manufacturers and does not need SEBI IA registration. This boundary matters because SEBI has penalised advisers who receive both fees and trails. If your primary revenue model is fees-for-advice, you need SEBI IA registration. The owning regulator is SEBI, operating under the SEBI Act 1992. Registration is granted under Regulation 3 of the SEBI IA Regulations 2013. The owning body for portal filings is SEBI's intermediary portal at sebi.gov.in. Minimum net worth thresholds are set out in Regulation 3(2): ₹10 lakh for individual advisers and ₹50 lakh for non-individual entities. Key thresholds and triggers include the NISM Series-V-A examination or CFP/CWM qualification requirement, the mandatory professional indemnity insurance minimum of ₹50 lakh (individual) or ₹1 crore (non-individual) under Regulation 19(5), and the half-yearly compliance audit obligation under Regulation 23(1).

Who needs this

SEBI sets out specific qualification, net worth, and infrastructure conditions before it will grant Investment Adviser registration. Verify each criterion before beginning the application.

• Indian citizen (for individual advisers) or registered Indian entity (company, LLP, partnership firm) with a permanent account number and valid DIN for directors.
• Individual advisers must demonstrate net worth of not less than ₹10 lakh computed as per Regulation 3(2)(a), excluding personal residence and unmapped assets.
• Non-individual entities (company, LLP, firm) must demonstrate net worth of not less than ₹50 lakh as per Regulation 3(2)(b).
• Individual adviser must hold CFP, CWM, or equivalent SEBI-recognised qualification, or have passed the NISM Series-V-A certification examination.
• At least 50% of directors in a company or designated partners in an LLP must individually satisfy the qualification or NISM examination requirement under Regulation 3(3).
• A dedicated office space with a registered rent agreement and utility bill matching the address on the application is mandatory for infrastructure compliance.
• Professional Indemnity Insurance cover of not less than ₹50 lakh for individual advisers and ₹1 crore for non-individual entities as required under Regulation 19(5).
• A practising Chartered Accountant must be on record for annual net worth certification under Regulation 22.
• A designated Compliance Officer (for non-individual entities) registered with SEBI under Regulation 15.
• A client agreement template compliant with Regulation 19(2) and (3) must be finalised before application submission.

Documents required

The document stack for SEBI IA registration is substantive and must reflect real, verifiable figures. KAMRIT prepares and reviews each document before portal upload to prevent query-triggering gaps.

• PAN card of the applicant or all directors/partners as proof of identity under income tax rules.
• Aadhaar card or passport or voter ID for individual applicants; DIN-validated PAN for company directors.
• Utility bill (electricity or water) or bank statement or rent agreement as address proof, dated within 90 days of submission.
• NISM Series-V-A pass certificate or CFP/CWM qualification certificate as primary evidence of competence.
• Net worth statement in Form 2 certified by a practicing Chartered Accountant with UDIN, listing all assets and liabilities.
• Net worth proof documentation: FMA-attested bank statements for all accounts, demat portfolio holding statement, and registered property valuation report.
• Board resolution (for companies/LLPs) or partnership authority letter authorising the IA registration application.
• Client agreement template compliant with Regulation 19(2) and (3), covering fee structure, risk disclosure, and cooling-off period.
• Professional Indemnity Insurance policy schedule naming the firm and coverage amount, verified against Regulation 19(5) minimums.
• Form 1 or verified declaration as required by SEBI, confirming accuracy of all submitted information.
• Registered office proof: rent agreement, NOC from owner, and utility bill matching the stated address.

How KAMRIT runs it, step by step

The SEBI IA registration process runs from internal readiness assessment through portal filing to post-approval compliance setup. Government-controlled stages carry estimated timelines; KAMRIT manages all applicant-controlled stages.

1. Initial Readiness Assessment. KAMRIT conducts a structured intake call to map the applicant's entity type, revenue model, existing qualifications, net worth position, and infrastructure. We identify whether Regulation 3(2)(a) or 3(2)(b) applies, whether the NISM exam or CFP exemption route is appropriate, and whether the client agreement and PI insurance are already in place. This stage typically runs 3 to 5 working days.
2. NISM Certification and Qualification Roadmap. For advisers without an existing CFP, CWM, or NISM Series-V-A certification, KAMRIT provides an exam preparation roadmap. The NISM Series-V-A exam is conducted by NISM (National Institute of Securities Markets) under SEBI's purview, held quarterly at multiple centres. CFP and CWM holders are exempt under Regulation 3(2)(a). KAMRIT assists with exam registration, study plan, and result tracking. This stage runs concurrently over 4 to 12 weeks depending on exam cycle.
3. Document Preparation and Net Worth Valuation. KAMRIT prepares the complete document pack: identity, address, qualification, net worth, office infrastructure, and insurance. The net worth statement in Form 2 must be certified by a practising CA with UDIN. Property valuations must be from a registered valuer. KAMRIT reviews each document for consistency with portal field entries. This stage typically takes 7 to 15 working days.
4. Client Agreement and Compliance Infrastructure Setup. Before portal submission, KAMRIT prepares a SEBI-compliant client agreement compliant with Regulation 19(2) and (3) including fee disclosure, risk warning, and a minimum 3-day cooling-off period. We also assist in setting up the compliance officer designation and audit trail infrastructure required under Regulation 18. This stage runs 5 to 10 working days.
5. SEBI Portal Application Filing. The completed application is filed through the SEBI intermediary portal at sebi.gov.in. The filing includes the net worth certificate, qualification evidence, PI insurance schedule, client agreement template, office address proof, and the verified declaration in Form 1. SEBI levies a portal processing fee per schedule of filing. KAMRIT handles the complete portal submission and confirmation receipt. This stage takes 3 to 5 working days for KAMRIT to complete.
6. SEBI Review and Query Response. SEBI typically issues an acknowledgement within 15 working days and may raise queries requiring clarification within 30 working days of filing. Common triggers include net worth computation methodology, insurance adequacy, and infrastructure gaps. KAMRIT manages all correspondence and submits revised or supplementary documents. This stage runs 30 to 90 working days and is regulator-controlled.
7. Registration Certificate and Post-Approval Setup. On approval, SEBI issues the Investment Adviser registration certificate. KAMRIT then sets up the ongoing compliance calendar: quarterly compliance report filing, annual net worth recertification under Regulation 22 by April 30, half-yearly compliance audit under Regulation 23(1), and annual return by April 30 each year. This stage runs 5 to 10 working days.