- The short — what’s changing and when
- Who must deposit and how much (bands)
- Cyber hygiene & liability ring-fence
- Cost math for solo advisers vs platforms
- Issuer/investor impact & FAQs
The short
- Purpose: Create a first-loss buffer for investor redressal and tighten cyber/operational discipline for Research/Investment Advisers.
- Coverage: Platform IAs, RA firms, and certain individual IAs exceeding client/fee thresholds must maintain deposits with exchanges/clearing members or approved banks.
- Form: Cash, bank guarantee, or fixed deposit lien; periodic top-ups required after audits or breaches.
- Timeline: Staged adoption through FY26 with interim quarterly attestations.
Who must deposit (illustrative bands)
| Entity type | Trigger | Deposit band (₹) | Top-up cadence |
|---|---|---|---|
| Individual IA (basic) | ≤ 150 active clients | 1–5 lakh | Semi-annual or post-breach |
| Individual IA (extended) | > 150 active clients | 5–15 lakh | Quarterly + event-based |
| RA boutique | Paid subscribers > 5,000 | 25–50 lakh | Quarterly |
| Platform IA / Marketplace | Multi-lakh user base | 1–5 crore | Monthly MIS + quarterly audit |
Note: Bands are policy-consistent illustrations to plan liquidity; your exchange/CM may specify exact slabs.
Cyber hygiene — minimum viable controls
- Device posture enforcement (EDR/MFA) for every research and advisory endpoint.
- Secrets handling: no client PII in plaintext docs; encrypt databases at rest and in transit.
- Breach playbook: 24h incident notify, isolate, rotate keys, and client reach-out template.
- Pen-test + VAPT: at least annual; fix windows defined by severity.
Liability ring-fence
- Segregate advisory revenue and client money flows; no commingling with prop accounts.
- Maintain cyber-insurance with social engineering and BEC riders.
- Appoint a grievance officer with TAT SLAs; publish dashboards quarterly.
Cost math — solo vs platform
| Line item | Solo IA (₹/yr) | Platform IA (₹/yr) | Notes |
|---|---|---|---|
| Deposit carry cost | 12,000–36,000 | 6–18 lakh | Assumes 8% opp. cost on deposit band mid-point |
| Cyber tooling | 60,000–1,20,000 | 25–60 lakh | EDR, SIEM/SOAR, WAF, backups |
| Audit & legal | 50,000–1,00,000 | 8–20 lakh | VAPT, policy drafting, attestations |
| Insurance | 40,000–90,000 | 10–25 lakh | Cyber + professional indemnity |
Tip Spread deposit across cash + BG to lower carry cost; negotiate BG pricing with relationship banks.
Investor impact
- Better disclosure of track record, model portfolios, and conflict policies.
- Faster grievance resolution from escrowed deposit usage where applicable.
- Small fee uptick likely in marketplace plans as platforms pass along compliance cost.
FAQ
- Can I substitute insurance for deposit? No—insurance complements but doesn’t replace the deposit.
- What triggers top-ups? Audit findings, breach losses, or user restitution that dips below the floor.
- Who holds the deposit? Exchange/CM or scheduled bank under lien with defined invocation rules.