The rule, in SEBI's words
SEBI's guidelines for Research Analysts, issued in January 2025, put a ceiling on fees: ₹1,51,000 per annum per family of client, for all research services of the RA together. The limit does not include statutory charges, so GST sits on top of it, not inside it. It applies to individual and HUF clients; it does not apply to non-individual clients or accredited investors. The same sentence now appears in the Most Important Terms and Conditions every client reads before paying, so your clients know the number as well as you do. SEBI can revise the figure; the one in the current MITC is the one to work from.
One limit across everything a client buys from you
The usual mistake is to check each plan on its own. A ₹60,000 equity plan and a ₹50,000 derivatives plan are each comfortably inside the limit. A client who holds both and then adds a ₹45,000 model portfolio is not: together that is ₹1,55,000. Because the ceiling covers all research services, the question at a sale is never "is this plan under ₹1,51,000?" It is "what has this client already paid me this year, and what does this purchase add?" That is a running total, kept per client rather than per product, and it changes with every payment and every refund.
What goes into the total
Three details decide whether the total is right. First, GST: the limit is on the fee, so a GST-inclusive collection has to be converted at your own GST rate, and an RA who does not charge GST has nothing to take out. Assuming 18% for everyone understates what a non-registered RA's client has used. Second, money actually received: a payment a client says they made, but which you never confirmed, should not use up their limit. Third, refunds: a fee returned to the client was not, in the end, charged. Where your own practice raises a harder question, such as how to treat a partly delivered plan, settle it with your compliance adviser once and apply the answer consistently.
Per family: the part software cannot see
SEBI writes the limit per family of client. A PAN identifies one person; whether two people are one family is something only the client can tell you. A check keyed on PAN is the right foundation, because it catches the cases that happen most: one person with two logins, or one person buying from two different pages of your site. It is not the whole rule. When a husband and wife, or a parent and a dependent child, subscribe separately, their payments to you may belong in one total. The practical answer is to ask at onboarding whether any family member is also your client, note it, and look at those accounts together before a large sale.
Advance fees, refunds and how fees are paid
The guidelines let an RA take fees in advance if the client agrees, for no longer than the period SEBI sets; presently that is one year. The trap is the early renewal. A client with eight months left who buys another annual plan is paying today for access that runs twenty months out. Measured from today the purchase looks like a year; measured from where their current access ends, it goes past the horizon. If the service ends early, whoever ends it, the client is entitled to a refund of the proportionate fee for the unexpired period. Fees are paid by cheque, bank transfer, UPI and similar modes, never in cash, and a client may choose to pay through CeFCoM, the centralised fee collection mechanism run by BSE.
Check at the moment of payment, not at audit
A breach found at audit costs a refund, an explanation and a record that says the control failed. The same breach found at checkout costs one polite message. Timing matters for a plainer reason too: once a payment gateway has taken the money, refusing the purchase means sending it back. So the check belongs at the moment the client presses pay, and the message should say how much they can still buy, not just refuse. A client told "you can buy up to ₹31,000 more this year" can choose a smaller plan; a client told "error" calls you.
How OptumFlex does this
OptumFlex keeps the running total for you. Before the payment gateway opens, it adds up every approved payment that client's PAN has made to your firm in the last 365 days, across every login that PAN holds, subtracts refunds, takes GST out at your own rate (or not at all if you do not charge it), and adds the cart. A purchase that would take the client over ₹1,51,000 is refused, with the amount they can still buy. Each firm's limit is its own, so a client of two RAs is never measured against the other's sales. The fee limit and the advance-fee terms are in the MITC each client reads and signs before paying. What the platform cannot know is who belongs to one family; that answer still comes from your client.