SEBI Relaxes Certification Requirements for Non-Advisory Personnel of Investment Advisers

As part of its continuing ease of doing business initiatives, SEBI has rationalised the certification framework applicable to Persons Associated with Investment Advice (PAIA) by introducing a differentiated compliance regime based on the nature of functions performed.

Revised Certification Framework

Non-Advisory Personnel

Under the revised framework, individuals engaged exclusively in sales and other non-core activities—such as relationship managers and client servicing personnel who do not render investment advice—will now be required to obtain only the newly introduced NISM Series XXV-B certification.

Advisory Personnel

Personnel involved in providing investment advice will continue to be required to possess both the NISM Series X-A (Level 1) and Series X-B (Level 2) certifications prescribed under the SEBI (Investment Advisers) Regulations, 2013.

Transitional Arrangements for Existing Certifications

SEBI has also clarified the transitional position for existing certified personnel. Individuals who already hold the existing Level 1 and Level 2 certifications will not be required to immediately obtain the new certification and may do so upon expiry of their current certifications.

Effective Date and Next Steps

The circular takes immediate effect. The Investment Adviser Administration and Supervisory Body (IAASB) has been directed to amend its bye-laws and communicate the revised requirements to all registered Investment Advisers.

Why It Matters

The revised framework adopts a more functional approach to competency requirements by distinguishing advisory personnel from employees performing purely commercial or client-facing roles.

Investment Advisers should take the following steps to ensure compliance with the revised regulatory framework while reducing unnecessary certification burdens for non-advisory staff:

• Review employee classifications to distinguish advisory from non-advisory roles
• Audit certification records against the new requirements
• Update training programmes to align with the differentiated regime

Last Updated on 20 July, 2026