Research analyst conflicts: disclosures to check
The short answer. SEBI requires disclosure of financial interests and material conflicts involving the company covered by a research report. In plain words, a conflict of interest is an interest or link that could affect how impartial the research is. Read the disclosure section when comparing services.
Published 10 November 2026 · Potoos Research Services
What to look for in a report
SEBI regulation 19 covers the analyst or research firm and specified connected people or entities. Look for these separate disclosures:
- Any financial interest in the company and the nature of that interest.
- Whether actual or beneficial ownership reaches 1% or more of the company's securities, measured at the end of the month before the report is published (or before the public appearance).
- Any other material conflict of interest at the time the report is published or the analyst appears in public.
- Whether the analyst or its associates received compensation from the company in the past twelve months.
- Whether the analyst has been an officer, director or employee of the company.
- Whether the analyst or research firm has been a market maker in the company's securities.
Financial interest means a money-related interest. Beneficial ownership concerns the person entitled to ownership benefits. The 1% test is separate from the rule about any financial interest.
Why a disclosure matters before joining
SEBI's code of conduct requires analysts to address conflicts that may affect impartial research and make suitable disclosures. Its Investor Charter also covers business activity, disciplinary history and conflicts between research and other activities.
Use the disclosure as a reading checklist. Find the company name and report date. Then locate the stated financial interests and business connections. If a section is unclear, seek a written explanation before deciding on the service.
Check the words, not only the heading
A heading called Disclosures is a starting point. Read the statement beneath it and compare it with the categories above. Keep the complete report, including the disclosure pages, for your own reference.
This checklist helps you examine the document. It does not establish the quality of an individual service.
Sources
- SEBI Research Analysts Regulations, amended up to 10 October 2026. 2026-10-10. Pages 17-18, regulation 19; page 36, Third Schedule, item 3.
- SEBI Investor Charter for Research Analysts. 2025-06-02. Page 4, Annexure A, section C, disclosures to clients.
Sources checked on 9 November 2026. Information cutoff: 9 November 2026, 13:40 IST
Common questions
Does the 1% threshold cover every financial interest?
No. Regulation 19 separately requires disclosure of any financial interest and of actual or beneficial ownership at or above 1%.
Where can I check the rule?
Open the SEBI regulations linked in the Sources list above. Regulation 19 is on pages 17 and 18. The conflict provision in the code of conduct is on page 36.
Does SEBI cover other business conflicts too?
Yes. The Investor Charter calls for disclosure of conflicts between research services and the analyst’s other activities.
Potoos Research, SEBI-registered Research Analyst. Registration number INH000027380. SEBI is the Securities and Exchange Board of India.
What the research service includes · About Potoos and the analyst.