Investment Adviser Client Records: Written, Email, Call and Digital Evidence Explained
- August 18, 2026
- Posted by: Kunal Singla
- Category: advisory
Investment adviser client records may be maintained in written, email, telephone recording, SMS or any other format that creates a retrievable record of the interaction. SEBI guidance specifies tha…
Quick Answer
Investment adviser client records can be maintained in multiple formats depending on the communication channel through which advice was delivered and the client interaction occurred. SEBI’s guidance on record-keeping is format-inclusive — it specifies that records must be retrievable, verifiable and preserved for the required period, but permits multiple evidence formats including written documents, email threads, telephone call recordings, SMS records and digital platform logs.
Understanding the range of acceptable investment adviser client records formats helps registered IAs implement practical record-keeping systems that match their communication channels and helps investors understand what types of evidence support their advisory relationship documentation.
This guide explains the investment adviser client records taxonomy, what SEBI’s guidance specifies about acceptable formats and how each format should be managed.
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Written Documentary Records
Written documents are the most traditional form of investment adviser client records. These include the signed client agreement, risk profiling questionnaire, written risk profile communicated to the client, written advice notes, written research reports accompanying recommendations and written complaint correspondence. Physical signed documents must be maintained securely and in accessible storage for the retention period. Scanned digital copies of signed physical documents are acceptable as digital records if the scan is clear, complete and stored securely.
Email Records
Email is an acceptable and widely used form of investment adviser client records. Advisory emails including research reports, recommendation alerts, risk profile communications and client query responses should be archived in a retrievable email system. The email archive must preserve the sender, recipient, timestamp and full message content including attachments. Individual adviser email accounts should be backed up at the entity level so that email records are not lost when staff members leave.
| Record Format | Management Requirement | Retention Period |
|---|---|---|
| Written/signed documents | Secure physical or scanned digital storage | Minimum 5 years |
| Email records | Entity-level archive, sender/recipient/timestamp preserved | Minimum 5 years |
| Telephone recordings | Secure digital storage, accessible for audit | Minimum 5 years |
| SMS records | Official number records maintained at entity level | Minimum 5 years |
| Digital platform logs | Platform-maintained logs with advisory interaction detail | Minimum 5 years |
Telephone Recordings and SMS
SEBI’s guidance explicitly recognises telephone recordings as an acceptable form of investment adviser client records. Advisory calls where investment advice is delivered should be recorded and preserved. The recording must be accessible for retrieval in the event of a dispute or audit. SMS records from official registered numbers are also acceptable — these are entity-level records when maintained through official advisory communication channels, not personal device SMS.
Digital Platform Logs
For IAs operating through digital platforms, the platform’s internal logs of advisory interactions — recommendation delivery timestamps, client access logs, alert delivery confirmations — constitute investment adviser client records under the digital evidence framework. Platform logs should be securely backed up and retrievable for the retention period. When an IA transitions to a new platform, logs from the previous system must be migrated or archived in a retrievable format.
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Access Advisory Records Through the Official Univest Platform — Documented and Retrievable
Download the Univest iOS App or Univest Android App to track advisory interactions through official documented channels on the SEBI-registered Univest platform.
Conclusion
Investment adviser client records may be maintained in written documents, email archives, telephone call recordings, SMS records from official numbers and digital platform interaction logs. All formats must be retrievable, verifiable and preserved for at least five years. Entity-level archiving for email and call records is essential to prevent loss when staff members change. Digital platform logs are explicitly acceptable and should be backed up and migrated when platforms change.
Disclaimer: Data and figures in this article are sourced from publicly available information. These may or may not be accurate. Please verify all data with official sources before making any investment decision. Investments in securities are subject to market risk. This content is for educational purposes only and is not investment advice by Univest (SEBI RA INH000013776).
Frequently Asked Questions
What formats are acceptable for investment adviser client records?
Ans. SEBI guidance accepts multiple formats for investment adviser client records: written and signed documents (agreements, risk profiles), email records archived at the entity level, telephone call recordings, SMS from official registered numbers and digital platform interaction logs. All formats must be retrievable and preserved for at least five years.
Are telephone call recordings mandatory or just acceptable?
Ans. Telephone recordings are explicitly listed as an acceptable form of investment adviser client record for calls in which investment advice is delivered. Whether recordings are mandatory for all advisory calls depends on the IA’s communication practices and the applicable SEBI guidance at the time. IAs that conduct advisory calls should implement call recording as a standard practice to create complete records.
How should email records be preserved?
Ans. Email records should be archived at the entity level with the full message content including attachments, sender, recipient and timestamp preserved. Entity-level archiving ensures records are not lost when individual staff members leave. Personal email accounts that are not backed up at the entity level create fragmented, potentially inaccessible records.
Are WhatsApp Business records acceptable as client records?
Ans. WhatsApp Business communications from an official IA-registered account create a digital record of the interaction. Whether this format meets SEBI’s record-keeping requirements depends on whether the records can be retrieved, verified and preserved for the applicable retention period at the entity level. Personal WhatsApp accounts do not create entity-level records and are not appropriate for advisory communications.
What must be captured in a digital platform advisory interaction log?
Ans. Digital platform logs should capture at minimum: the specific recommendation or advice delivered with timestamp, the channel of delivery, the client access or acknowledgement record where applicable, and any subsequent updates or revisions to the recommendation. The log should enable reconstruction of the advisory interaction at a later date for audit or dispute purposes.
What happens to digital records if the IA changes its platform?
Ans. Records from the previous platform must be migrated to a retrievable format or archived separately for the remainder of the applicable retention period. Discontinuing a platform does not extinguish the record-keeping obligation. Registered IAs should plan platform transitions with explicit data migration and archiving steps to preserve historical investment adviser client records.
