SEBI RIA Registration — Registered Investment Adviser (Form A + Net Worth Certificate)

SEBI (Investment Advisers) Regulations, 2013: Regulation 3 — registration requirement; no person shall act as investment adviser without SEBI registration. Form A: application for registration. Eligibility — individual: postgraduate/CA/CFA/CS + 5 years experience + ₹5 lakh net worth + NISM X-A; non-individual: ₹50 lakh net worth + NISM X-A/X-B for all advisers + compliance officer. SEBI Circular SEBI/HO/IMD/DF1/CIR/P/2020/182 (dated 23 September 2020): enhanced RIA framework — mandatory segregation of advisory and distribution; body corporate requirement for non-individual RIA with > 150 clients; implementation deadline 1 April 2021. NISM Series X-A (Investment Adviser Level 1): mandatory for all RIAs. NISM Series X-B (Investment Adviser Level 2): mandatory for advice to clients with investable surplus > ₹50 lakh. Annual compliance audit by Chartered Accountant: mandatory under the Regulations. GST: advisory fees from RIA are taxable services at 18% under SAC 997159.

A Registered Investment Adviser (RIA) is an entity registered with SEBI under the SEBI (Investment Advisers) Regulations, 2013 to provide investment advice to clients for a fee. With the growing demand for fee-only financial planning and investment advisory services in India, the RIA registration framework has become increasingly relevant for Chartered Accountants, financial planners, and wealth management firms.

The SEBI (Investment Advisers) Regulations, 2013 were substantially amended in 2020 (SEBI/HO/IMD/DF1/CIR/P/2020/182 dated 23 September 2020) and 2021 to introduce the enhanced regulatory framework for RIAs. Key changes include: mandatory segregation of investment advisory and distribution businesses (an RIA cannot simultaneously distribute financial products); enhanced net worth requirements; mandatory body corporate structure for non-individual RIAs managing more than 150 clients; and increased qualification requirements.

The eligibility criteria for SEBI RIA registration are:

For Individual RIAs: Minimum qualification — postgraduate degree in finance, economics, business, law, or related fields (or CA/CFA/CS qualification); minimum experience — 5 years in financial services/advisory; net worth — minimum ₹5 lakh; NISM Series X-A (Investment Adviser Level 1) certification mandatory; NISM Series X-B (Investment Adviser Level 2) mandatory for advisers to clients with investable assets above ₹50 lakh.

For Non-Individual RIAs (companies, LLPs): Net worth — minimum ₹50 lakh (increased from ₹25 lakh); NISM Series X-A + X-B certifications mandatory for all investment advisers employed; mandatory body corporate structure for non-individual RIAs with more than 150 clients; compliance officer mandatory. A CA-certified net worth certificate is a mandatory attachment to the Form A application.

The Chartered Accountant's role in RIA registration: (i) net worth certificate for the RIA entity (individual: ₹5 lakh; non-individual: ₹50 lakh); (ii) annual audit — SEBI requires annual compliance audit by a CA; (iii) advisory on segregation of advisory and distribution businesses (RIAs cannot distribute financial products — advice on structure for segregation); (iv) tax advisory on advisory fee income under GST (18% GST on advisory fees) and income tax; and (v) FEMA advisory if serving NRI clients.