NISM-Series-XXV-A tests whether you can operate inside a research organisation without being the analyst who writes the reports. The core concept, role-boundary reasoning, demands two decisions for every rule: whose role it attaches to, and what changes when you are the one speaking to the client. The same conduct — quoting a target price, passing on a company comment, accepting a gift — carries different consequences depending on whether it comes from the registered analyst or from sales and other non-core staff. Build a role-rule map, drill scenarios where a salesperson touches a research report, and check yourself against the rubric in this guide.
Core Analyst Versus Non-Core Personnel: Which Rules Attach to Which Role
The examination covers persons associated with research services in sales and other non-core capacities, so the foundational skill is separating obligations that attach to the registered research analyst from obligations that reach everyone working around the research function.
The registered research analyst is the person who prepares, owns, and publishes research: forming coverage opinions, setting ratings and target figures, and signing off on disclosures. Core obligations cluster around the report itself — independence of opinion, disclosure of interests in covered securities, and trading discipline tied to published views. When you read a syllabus statement, first check whether it describes the production of research or the movement of research through the firm.
Sales and other non-core associated persons typically do not author recommendations, but they transmit them, answer questions about them, and manage the client relationship. Their obligations concentrate on how research is communicated, how conflicts are avoided, and how unpublished or confidential material is handled. Practise scenarios that place you in exactly this position: a report exists, and a non-core person must decide what may be said, repeated, promised, or escalated.
| Dimension | Registered research analyst (core) | Sales and other non-core associated person |
|---|---|---|
| Primary function | Prepares and publishes research and recommendations | Distributes, explains, and supports the research function |
| Central duty | Independence and integrity of the published opinion | Faithful communication of the published opinion |
| Changing a view | May revise the rating through the firm's process | Must route view changes back to the analyst or compliance |
| Trading discipline | Personal trading windows tied to published recommendations | Expected to follow the entity's controls and avoid trading on unpublished or confidential information |
| Client-facing limit | Communicates the firm's own published research | Communicates within the scope of the report; no personal assurances |
How the SEBI Research Analyst Framework Reaches the Sales Desk
Research services in India operate under the SEBI research analyst regulatory framework, which imposes registration and conduct obligations on the analyst and the entity, and conduct expectations on persons associated with the research function.
Trace the chain deliberately. SEBI's framework requires research analysts to be registered and sets conduct standards the registered entity must enforce across its research activity. Those entity-level obligations — independence, disclosure, conflict management, record-keeping — then translate into internal policies that bind every person who touches research, including staff whose job is distribution or client service. Understanding this chain explains why a salesperson can be examinable at all.
In study terms, classify every rule you meet into three layers: rules on the analyst's registration and qualifications, rules on the entity's systems and controls, and conduct rules for associated persons acting on research. Build a three-layer sorting exercise from your workbook: label each rule by layer, then write one scenario where the third layer applies — for example, a client ask that only the analyst or compliance can lawfully satisfy. Naming the layer before answering makes the correct action follow naturally.
Conflict of Interest Scenario: When Incentives Touch a Specific Recommendation
The research framework treats conflicts between the firm's commercial interests and the independence of published recommendations as a core hazard. Compensation or benefits linked to a specific recommendation is the classic example to reason through.
Scenario: a salesperson learns that the team's incentive plan for the quarter increases when clients act on one particular 'buy' recommendation. The mistaken reasoning is that conflict rules belong to the analyst who wrote the report, so the salesperson says nothing. The better decision is to flag the arrangement to compliance, because an incentive tied to acting on a specific recommendation undermines the independence the framework protects, and associated persons who participate in such structures are inside the conflict, not outside it. Why it matters: research value depends on the opinion being free of commercial steering, and every person around the report shares responsibility for keeping it that way.
Build a habit of enumerating conflict sources rather than memorising a single definition. Typical sources include compensation linked to specific recommendations or transactions, inducements or benefits from companies covered or from parties interested in a view, pressure from investment banking or other business lines, and personal positions of staff. For each source, rehearse the same two-step: identify who is exposed, then identify the control — disclosure, separation, refusal, or escalation — that the framework expects. Drill the two-step until it is your default response, because it resolves unfamiliar cases even when a definition escapes you.
Client Communication Scenario: Quoting a Report Without Exceeding It
A non-core person communicates published research faithfully — rating, rationale, risks, and required disclosures — and must not add personal assurances, alter the view, or invent certainty the report does not contain.
Scenario: a client asks whether a 'buy' rating means the stock is guaranteed to rise to the target price. The mistaken response is to agree enthusiastically, saying something like 'our team is confident, it will get there.' The better response restates exactly what the report says: the rating, the reasoning, the risks the analyst flagged, and any mandated disclosures, while making clear that the report is the firm's published opinion, not a personal guarantee. Why it matters: the non-core person's authority comes entirely from the published report; anything beyond it is unauthorised commentary that misrepresents the research.
Extend the same logic to pressure cases. If a client demands a different view, a faster target revision, or an off-report opinion, the faithful action is to note the request and route it to the analyst or the firm's process — never to improvise a view. Practise writing two-line responses to common client prompts: what the report says, what you cannot do. This habit trains the precise boundary between explaining published research and giving independent advice.
Unpublished Information and Personal Trading Discipline Around Research
Persons around the research function must not act on unpublished or confidential research or material non-public information, and the framework imposes trading discipline around published recommendations that the entity's policies apply across staff.
Two information states matter. Published research is generally communicable within your role's limits; unpublished drafts, upcoming rating changes, and material non-public information learned from company interactions are not. If a salesperson overhears that a downgrade is scheduled, acting on it — personally or by tipping clients — treats confidential information as a trading opportunity. The safe pattern is to keep unpublished material inside the firm's controlled process and to follow internal pre-clearance and restricted-list procedures rather than personal judgement.
For personal trading, the framework attaches discipline to the window around published recommendations for the analyst and persons subject to the entity's policies. Rather than memorising a single number, learn the structure: there is a period before publication during which trading in a security about to be recommended is restricted, and a period after publication during which trading on the recommendation is restricted. The reasoning is that the restriction exists to prevent staff from front-running the firm's own published view. Check the current figure in the official workbook rather than relying on memory of older versions.
Disclosures, Records, and Complaints: What Must Exist on Paper
The framework expects research entities to maintain disclosures about interests and conflicts, retain records of research and communications, and operate a complaint-handling process that associated persons must route cases into correctly.
Disclosure obligations concentrate on interests: the analyst's and the entity's positions in covered securities, compensation or other connections that could bear on a view, and any mandated statements that must accompany published research. For a non-core person, the practical duty is to ensure the disclosure set travels with the research when it is shared — sending a report onward without its required disclosures breaks the chain the entity is obligated to maintain.
Record-keeping and complaints are the operational half of the syllabus. Communications with clients about research, the reports themselves, and evidence of the entity's controls need to be retained per policy so that the firm can demonstrate compliance later. When a client complains about a recommendation or a sales interaction, the correct action is timely escalation into the firm's complaint process, not informal settlement or deletion of correspondence. Rehearse scenarios where the tempting shortcut — an undocumented promise, an off-system chat, a quietly refunded fee — is the wrong answer precisely because it leaves no compliant record.
A Two-Week Role-Map Exercise, Preparation Sequence, and Readiness Checks
Spend the first week building a role-rule map across the syllabus topics, the second week drilling scenarios and timed practice, and finish with the rubric below. Treat any self-check score as a learning milestone, not a prediction of the exam result.
Exercise: take twenty short statements drawn from the six syllabus topics — for example, 'accepting a festival gift from a covered company' or 'revising a target price after a client call' — and classify each as analyst-only, both roles, or non-core-relevant, then write the expected action in one line. Expected observations: conflict and communication items cluster in the 'both roles' bucket with different actions per role, and report-authorship items stay analyst-only. Rubric for self-checking: at least eight of ten classifications correct, each action line names a concrete step (disclose, escalate, refuse, route), and no answer relies on 'it depends' without naming the deciding factor.
An adaptable sequence: days one to three, map the regulatory framework and the core/non-core distinction; days four to six, drill conflicts, disclosures, and the trading-window structure; days seven to nine, practise client-communication scenarios and record-keeping cases; days ten to twelve, cover operational procedures, risk management, and recent regulatory developments using your workbook's current edition; days thirteen to fourteen, take timed practice sets, log every error by topic, and re-run the role-map exercise on your logged errors. If your organisation has internal research compliance policies, mapping exam concepts onto them deepens the role-first habit without replacing the workbook.
- Readiness check one: you can state, in two sentences each, the difference between the analyst's publication duties and the non-core person's communication duties.
- Readiness check two: given any scenario, you name the conflict source and the expected control before choosing an action.
- Readiness check three: you can describe the before-and-after structure of trading restrictions around a recommendation and say where to verify the exact durations.
- Readiness check four: you can identify when a client request must be routed to the analyst, compliance, or the complaint process.
- Readiness check five: your error log from practice sets shows no topic with repeat errors across two consecutive attempts.
References and further reading
Use these references to explore the concepts and check the latest information from the relevant organizations.
