Why does a Research Analyst ask for my PAN, KYC and risk profile before I subscribe?

What the rules require at signup, what each step protects, and the two things no analyst should ever ask you for.

Published 3 November 2026 · Potoos Research Services

KYC: the rule behind it

KYC means Know Your Client. It is how a SEBI-registered business confirms who its client is. The SEBI (Research Analysts) Regulations, 2014 list the records an analyst must keep, in regulation 25(1). They include “Know Your Client records of the fee paying client”.

SEBI's Master Circular for Research Analysts, dated 6 February 2026, adds how. The analyst “shall collect, store, upload and check KYC records of the clients with KYC Registration Agency (KRA)”. And the circular makes the duty clear for clients who pay: analysts “are required to follow the KYC procedure for clients paying fees directly for research services.”

Why your PAN in particular

Regulation 25(1)(vi) requires “a register or record containing list of the clients along with client’s PAN”, with the date and nature of the service, the securities covered and the fee charged.

The PAN also does a second job. SEBI does not allow a client to take research services and distribution services from the same analyst's group or family. The master circular says “PAN of each client shall be the control record for identification and client-level segregation.” For an individual, the PAN of every member of the client's family is counted together.

The terms and the Most Important Terms and Conditions

Regulation 24(6) says an analyst must disclose its terms and conditions to you and take your consent. The master circular sets the order: “neither any research service is rendered nor any fee is charged until consent is received from the client on the terms and conditions.” You may sign in person or by any other legally acceptable mode, including Aadhaar-based e-signature through DigiLocker.

Part of those terms is a short standard list called the Most Important Terms and Conditions, or MITC. It was standardised by the Industry Standards Forum in consultation with SEBI and the Research Analyst Administration and Supervisory Body, which is BSE. In plain words, it tells you that:

• the analyst cannot place any trade for you, and you should not let them;
• the fee for individual and Hindu Undivided Family clients has a ceiling, now ₹1,51,000 per family per year, not counting statutory charges;
• fees are paid by cheque, bank transfer, UPI or similar, and cash is not allowed;
• assured or fixed-return schemes are prohibited, and the analyst cannot guarantee returns, profits, accuracy or risk-free investments;
• SEBI registration, BSE enlistment and NISM certification do not guarantee the analyst's performance;
• complaints go first to the analyst, then to SEBI's SCORES portal, then to the Smart ODR portal;
• the analyst shall never ask for the login or OTP of your trading, demat or bank account.

Records of what was said to you

Regulation 25(1)(vii) requires records of communication, including emails and call recordings, with all clients, including people who have not yet signed up. Regulation 25(1)(viii) requires a record of the terms disclosed to you and your consent.

The master circular says these records begin with the first conversation and continue until the service ends. The forms include a record you signed, telephone recordings, email from a registered email ID, SMS records and any other legally verifiable record. A call recording is not needed when the conversation happens over email or another channel that leaves a digital record.

How long? Regulation 25(2) says all records are preserved “for a minimum period of five years”. If you raise a dispute, the circular says they are kept until it is resolved.

This protects you. SEBI explains that the purpose of these records is “to document the interaction to cater to potential client grievances”. If you ever complain, there is a record of what you were told.

And the risk profile?

This one is different. A Research Analyst publishes research and recommendations on securities. The research is the same for every subscriber. Advice built around your own goals, income and risk profile is the work of a separate registration, the Investment Adviser. Our page Research Analyst or Investment Adviser explains the difference.

We read the SEBI (Research Analysts) Regulations, 2014, as amended up to 10 October 2026, and the 6 February 2026 master circular. Neither sets out a step-by-step risk profiling procedure for Research Analysts. They do require something close to it: the analyst must give “clear guidance and adequate caution notice to clients when providing recommendations for dealing in complex and high-risk financial products/services”.

So when an analyst asks risk questions at signup, it is usually the analyst's own process. Ask them what the answers are used for.

What KYC never includes

• Your login or OTP. No KYC step needs the password or OTP of your trading, demat or bank account. The MITC says an analyst shall never ask for them. If anyone does, stop.
• Money for the analyst to invest. The investor charter says: “Do not provide funds for investment to the Research Analyst.” You pay a fee. Your trading money stays in your own account.

How to check this yourself

1. Check the registration before you share anything

   Your PAN is personal. Give it only to an analyst you have checked on SEBI's register. Our guide How to check that a Research Analyst is actually registered shows each click.

2. Share KYC details only through the analyst's own signup

   Use the signup form on the website or app that the analyst's registered details point to. Do not send photos of your PAN card to an unknown number in a chat.

3. Look for the terms screen and the MITC

   Before you pay, you should see the terms and the Most Important Terms and Conditions, and be asked to accept them. Read the fee line and the complaint steps. If there is no such screen, ask for it before paying.

4. Keep a copy

   Save or screenshot the terms you accepted and your payment receipt. If a dispute ever comes up, these are your own record, alongside the analyst's.

How signup works at Potoos Research Services

This page is published by Potoos Research Services about itself.

Potoos Research Services is a SEBI-registered Research Analyst, Vinoth Kumar S, INH000027380, Chennai. Our investor charter lists the two onboarding steps SEBI sets: sharing the terms and conditions of the research services, and completing KYC of fee-paying clients. The full terms are shown at signup, and you agree there to the Most Important Terms and Conditions before the subscription starts. Risk profiling is listed in every plan. See the plans.

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