The Securities and Exchange Board of India (SEBI), the guardian of regulatory frameworks in India's securities markets, has announced a significant extension in compliance deadlines for investment advisers (IAs). This move offers a welcome reprieve for those struggling to meet regulatory requirements following recent amendments.
In 2020, SEBI amended Regulation 7 of the SEBI (Investment Advisers) Regulations, 2013, raising the bar for qualifications and experience for individual IAs, principal officers of non-individual IAs, and associated personnel.
These revised norms originally mandated full compliance by September 30, 2023.
However, industry stakeholders—including advisory firms, professional bodies, and market participants—highlighted several practical challenges: limited training capacity, conservative hiring timelines, and disruptions due to the pandemic.
Acknowledging these concerns, SEBI issued a circular in October 2023, extending the compliance deadline to September 30, 2025.
Under Regulation 7(1), the requirements include:
Qualification
A relevant graduate degree or postgraduate diploma in finance-related fields (commerce, economics, actuarial science, etc.).
Passing the NISM certification exam as specified by SEBI.
Experience
Prior to the 2020 amendment: at least 5 years of relevant work experience in financial products or advisory roles.
Post-amendment: SEBI has eased certain experience requirements for persons associated with investment advice.
NISM Exams
Investment advisers (and key personnel) need to clear specified modules to ensure a standardized level of knowledge and professionalism.
Individual Investment Advisers: Solo practitioners registered with SEBI.
Principal Officers: Head-level executives of non-individual IAs (e.g., firms, corporates).
Associated Persons: Those providing investment recommendations under an IA’s registration.
SEBI considers the responsibilities of a role, not just the title, when enforcing compliance.
Several factors influenced SEBI’s decision:
The COVID-19 pandemic strained training schedules and exam availability.
Smaller firms reported difficulty meeting both qualification and experience thresholds within the original timeframe.
There was significant industry feedback, urging for a more realistic deadline—SEBI responded by balancing rigor with practicality.
SEBI’s Circular issued in October 2023 affirms:
“...the timeline to comply with the enhanced qualification and experience requirements under regulation 7(1) is extended to September 30, 2025.”
It also directs BSE Administration & Supervision Limited (BASL)—the oversight body for registered IAs—to communicate this extension to its members and make the circular publicly available.
More Time to Upgrade
IAs can now carefully plan to complete any pending qualifications, exams, or documentation by the new deadline.
This provides flexibility in managing costs and time.
NISM Exam Prep
With additional time, advisers can register for and complete NISM modules.
SEBI expects certification to be current and valid at all times.
Organizational Readiness
Firms can focus on hiring qualified individuals or promoting existing employees into compliance roles, such as Principal Officers.
They can also document experience records properly.
BASL Notifications
Advisers should track BASL announcements for implementation details or deadlines.
Regular communication via email or portals is advised.
Improved Compliance Management
This extension helps firms avoid penalties or risk exposure due to technical non-compliance.
It also allows smoother transitions for professionals shifting roles within advisory firms.
| Aspect | Original Deadline | Extended Deadline |
|---|---|---|
| Regulation 7 Compliance | 30 Sept 2023 | 30 Sept 2025 |
The deadline for enhanced qualifications and experience is no longer 2023, but extended by two years.
The decision is not a permanent rollback, but a temporary cushion to ensure quality and investor protection remain intact.
SEBI reiterates its commitment to safeguarding investors while supporting sector growth and maturity.
SEBI has also introduced other timeline extensions recently, such as:
AIF managers: Extended deadline for NISM certification to July 31, 2025.
Mutual funds & portfolio managers: Offsite-data submissions revamped—from 10 to 15 calendar days —improving ease of doing business.
These changes show SEBI’s balancing act: maintaining robustness while responding to real-world constraints.
SEBI’s shift to September 30, 2025 provides both relief and clarity:
✅ Relief: More time for professionals to complete certifications and meet experience requirements.
✅ Clarity: A firm deadline avoids ongoing uncertainty and helps firms focus on sustainable compliance.
For advisers, this means:
Actionable steps now: Enroll in or complete NISM exams.
Track progress: Keep qualification and experience documentation well-organized.
Stay informed: Monitor BASL updates and SEBI communications.
Plan ahead: Use the additional time to hire or train staff appropriately.
In essence, SEBI’s extension is a thoughtful gesture—acknowledging the challenges while keeping investor interests at the center of regulation.