NISM-Series-XV: Research Analyst · Legal and Regulatory Environment (NISM XV)

Research Analyst Code of Conduct and Compliance (SEBI)

Updated 11 October 2026 · Fact-checked

The code of conduct under the SEBI (Research Analysts) Regulations, 2014 sets rules for honesty, disclosure of interests, handling conflicts, trading around reports, record keeping and compliance oversight. To solve questions, identify who acts (analyst or entity), the situation, and the matching rule: disclose, abstain, record, or escalate.

Understand Code of Conduct and Compliance for Research Analysts

A research analyst influences how investors buy and sell. The law therefore asks for fair, independent and transparent conduct. The SEBI (Research Analysts) Regulations, 2014 contain a code of conduct, plus separate duties on disclosure, trading, record keeping and compliance.

There are two kinds of actors. The research analyst is the person who is responsible for the content of a report or recommendation. The research entity is the registered firm or person that issues research. Some duties sit on the individual (such as disclosing own holdings and not trading against a recommendation). Some sit on the entity (such as policies, a compliance officer, audit and record keeping). In questions, check which one the rule is aimed at.

The core idea is conflict of interest. A conflict exists when the analyst, the entity or their associates have a financial or other interest in the company being covered, or earn from it. The law does not ban every interest. It requires you to disclose it, manage it, and keep research separate from other business such as investment banking or dealing. A written policy and separation of activities are expected.

Trading restrictions stop analysts from profiting from their own reports. Research analysts must not deal in the securities of a subject company for 30 days before and 5 days after the publication of a research report on that company. The restriction extends to the analyst's associates in line with the regulations. The research entity's own policies may add further limits. An analyst must also not trade contrary to their own recommendation, apart from limited exigency cases with approval. Check the exact figures and conditions in the current NISM workbook.

Record keeping and the compliance officer make the system checkable. Records of reports, recommendations and their basis must be kept for a minimum of 5 years. The compliance officer monitors adherence and reports issues. An annual audit also tests compliance. Always confirm exact wording against the current NISM workbook, as SEBI amends these rules.

Key formulas to remember

Restricted trading window: 30 days before + 5 days after publication of the research report; Research analysts must not deal in the subject company's securities in this window. The restriction extends to associates in line with the regulations, and the research entity's policies may add further limits. Confirm the figures in the current NISM workbook. Do not reverse the numbers.
Record retention: Minimum 5 years; Keep reports, recommendations and their supporting basis. This is the duty of the research entity.
Contrary trading rule: No trade contrary to own recommendation (limited exigency exceptions); Do not treat the exception as a normal permission. Exceptions need proper approval and documentation.
Disclosure rule: Disclose in the report and at public appearances: financial interest of 1% or more, beneficial ownership of 1% or more, compensation or client relationship with the subject company in the preceding 12 months, and other material conflicts; This is a summary of the main items. It covers the analyst, the research entity and associates. Examples: financial interest or beneficial ownership of 1% or more in the subject company; compensation received from it, or it being a client, in the 12 months before publication; managing or co-managing its public offering in that period; being an officer, director or employee of it. Confirm the full list in the current workbook. The point is transparency, not prohibition.
Who does what: Analyst = personal conduct; Research entity = policies, compliance officer, audit, records; Use this split to eliminate wrong options quickly.

How to solve Code of Conduct and Compliance for Research Analysts questions

Use this method for any question on conduct, disclosure, trading or compliance.

1Read the stem and mark who is acting: the research analyst, an associate, or the research entity.
2Identify the issue: disclosure, conflict, trading, record keeping or compliance oversight.
3Recall the matching rule: disclose, abstain, keep records for 5 years, or escalate to the compliance officer.
4Check numbers and timing: no dealing for 30 days before and 5 days after publication of the report (confirm in the current workbook), and 5 years for records. For disclosure, recall the 1% and 12 months markers.
5Look for words like always, never, only and any. Law questions usually include conditions or exceptions.
6Remove options that contradict the purpose of the rule, such as hiding an interest or trading against own advice.
7Pick the option that discloses, separates or documents, unless the rule clearly bans the act.

Quickest way: Disclose, abstain, record

When to use it: Use when time is short and you must pick from four options quickly.

Ask: is the right action to disclose, abstain from trading, or record and keep?
Recall the anchor numbers as per the workbook: 30 before, 5 after (around publication of the report), 5 years for records, and 1% and 12 months for disclosure.
Reject options that allow undisclosed interests or trading against a recommendation.
Reject options that put a duty on the wrong party (entity versus analyst).
If two options remain, choose the one with the stricter, more transparent action.

Common mistakes in Code of Conduct and Compliance for Research Analysts

Reversing the trading window as 5 days before and 30 days after.
Both numbers look familiar and students memorise them without logic.
Fix: Learn the order as a pair: 30 days before, 5 days after publication. Confirm the figures in the current NISM workbook.
Thinking any interest in the subject company is banned.
Students confuse disclosure with prohibition.
Fix: Conflicts are mainly to be disclosed and managed. Prohibitions apply to specific acts such as trading in the window or against the recommendation.
Mixing up analyst and research entity duties.
The two terms are used loosely in daily talk.
Fix: Link individual conduct to the analyst, and policies, compliance officer, audit and records to the entity.
Remembering record retention as 3 years or 7 years.
Other regulations and the NISM certificate validity (3 years) cause confusion.
Fix: Tie records to 5 years minimum. The 3 years belongs to certificate validity.
Treating the exigency exception as a normal right to trade against a recommendation.
Students read the exception and forget the default rule.
Fix: Default: no contrary trading. The exception is narrow and needs proper approval and records.
Assuming the compliance officer approves research content or guarantees accuracy.
The role name sounds broad.
Fix: The compliance officer monitors and reports on compliance with the regulations and policies. Responsibility for report content remains with the analyst and entity.

Worked examples

Example 1

As per the SEBI research analyst framework and the NISM workbook, a research analyst must not deal in the securities of a subject company during which period around the publication of the analyst's research report?
A. 5 days before and 30 days after
B. 30 days before and 5 days after
C. 15 days before and 15 days after
D. 30 days before and 30 days after

Show the solution

The issue is a trading restriction around publication of the report.
The rule is a window of 30 days before and 5 days after publication, as given in the workbook. The restriction extends to associates in line with the regulations.
Option A reverses the numbers, so reject it.
Options C and D use periods that do not match the rule.
Option B matches.

Answer: B. 30 days before and 5 days after

Example 2

What is the minimum period for which a research entity must keep records of its research reports?
A. 1 year
B. 3 years
C. 5 years
D. 7 years

Show the solution

The issue is record keeping, a duty of the research entity.
The minimum retention period is 5 years.
Options A and B give shorter periods than the minimum. Option B is the certificate validity, a common trap.
Option D gives a longer period than the stated minimum.
Option C matches.

Answer: C. 5 years

Exam tips

Memorise three numbers: 30 days before, 5 days after, and 5 years for records. Examiners build trap options by swapping them.
Always identify whether the question is about the analyst or the research entity before reading the options.
In scenario questions, check whether the correct action is disclose, abstain or document. Most right answers are one of these.
On negative-marking papers, skip a conduct question only if two options both look plausible after elimination. Most can be solved by rule recall.
Rules are amended from time to time. Use the latest NISM workbook wording for exact conditions.

Practice questions from Legal and Regulatory Environment (NISM XV)

Code of Conduct and Compliance for Research Analysts in other exams

The same ground in other exams, if you are preparing for more than one or want another angle on it.

CS ProfessionalGeneral Obligations and Code of Conduct

Code of Conduct and Compliance for Research Analysts: frequently asked questions

What is the research analyst code of conduct in SEBI rules?

It is a set of standards in the SEBI (Research Analysts) Regulations, 2014 requiring honesty, fair dealing, disclosure of interests, management of conflicts, and compliance with law. It applies to analysts and research entities and supports investor protection.

What are the trading restrictions before and after a research report?

Research analysts must not deal in the securities of a subject company for 30 days before and 5 days after publication of a research report on that company. The restriction extends to associates in line with the regulations. An analyst also must not trade contrary to their own recommendation, subject to narrow exigency exceptions. Confirm the figures in the current NISM workbook.

What is the difference between a research analyst and a research entity?

The research analyst is the individual responsible for the content of research. The research entity is the registered person or firm that issues it. Personal conduct duties fall mainly on the analyst, while policies, compliance officer, audit and records fall on the entity.

How long must a research analyst keep records under SEBI rules?

Records must be kept for a minimum of 5 years. This covers reports, recommendations and their supporting basis.

What must a research analyst disclose about conflicts of interest?

The main items are financial interest of 1% or more in the subject company, beneficial ownership of 1% or more, and compensation received from it or its being a client in the preceding 12 months. Other material conflicts, such as being an officer, director or employee of the company, must also be disclosed. This covers the analyst, the entity and associates, in the report and at public appearances. This is a summary, so check the current workbook for the full list.