SEBI Investment Adviser Fee Limit and How to Fight Overcharging

Your adviser sent a bill for ₹2,40,000 a year and called it a “standard planning fee”. That is not legal. A SEBI registered Investment Adviser cannot charge more than ₹1,51,000 a year per family under the fixed fee mode, or 2.5 percent of your assets under advice per year per family under the AUA mode. One mode applies at a time, and the cap binds across every service the adviser gives you.

These limits come from SEBI, the market regulator. They protect ordinary investors from being talked into open ended advisory fees that quietly eat your returns. If you have been billed above the cap, you do not have to argue alone. You can complain to SEBI through the SCORES portal and seek a refund.

A Registered Investment Adviser, or RIA, must pick one of two fee modes for you. The adviser may switch your mode later, but the overall yearly cap still binds. The adviser cannot stack both modes to charge more.

The “family” here means your family unit, not each person separately. So one adviser cannot bill you ₹1,51,000 and your spouse another ₹1,51,000 for the same advisory relationship. The fixed fee figure of ₹1,51,000 is reviewed once every three years by the Investment Adviser Administration and Supervisory Body, known as the IAASB, which is run by BSE Limited, in consultation with SEBI, so the number can change at the next revision.

These caps apply only to advisers who are actually registered with SEBI as Investment Advisers. A registered adviser must give you a Most Important Terms and Conditions document, called the MITC, which spells out the fee, the mode and your rights before you pay anything.

To check that the person advising you is genuinely registered:

1. Ask for their SEBI registration number, which starts with INA.
2. Verify that number on the SEBI website list of registered Investment Advisers.
3. Confirm the fee mode and amount written in your signed agreement and in the MITC.
4. Be cautious of anyone promising guaranteed or “assured” returns. A genuine RIA never does that.

If the person is not registered with SEBI at all, the fee cap is not your only problem. Unregistered advice and stock tips can be illegal in themselves.

If your bill crosses the cap, or the adviser charges in a mode you never agreed to, act in this order.

1. Raise it in writing with the adviser first. Email them, quote the SEBI fee cap of ₹1,51,000 or 2.5 percent of AUA, attach your agreement and the MITC, and ask for a written correction and refund of the excess.
2. Give a short deadline. Ask for a reply within 15 to 30 days and keep the email as proof.
3. File a complaint on SCORES if they refuse or ignore you. Go to the SEBI SCORES portal at scores.sebi.gov.in, register, and lodge a complaint against the adviser with your documents attached.
4. Escalate inside SCORES. If the first response does not satisfy you, SCORES lets you ask for a review, which pushes the complaint to a higher level at SEBI.
5. Use online dispute resolution. SEBI also runs an online dispute resolution mechanism called SMART ODR for market disputes, which you can use to seek a structured settlement or refund.

Your complaint is only as strong as your paperwork. Keep these from day one:

• The signed advisory agreement showing the agreed fee and mode.
• The Most Important Terms and Conditions, the MITC document.
• Every invoice and fee receipt, with dates and amounts.
• Bank or card statements proving what you actually paid.
• The adviser SEBI registration number starting with INA.
• All emails and messages about the fee, especially any promise of returns.

• Paying without the MITC. If you never received the Most Important Terms and Conditions, you are already outside the rules. Demand it before paying.
• Treating both modes as additive. An adviser cannot charge a fixed fee and an AUA percentage on top. Only one mode applies, and it is capped.
• Assuming the cap is per person. It is per family per year, so combined family billing above the cap is not a workaround.
• Ignoring “minimum fee” tricks. A minimum fee under the AUA mode that effectively becomes a flat charge is treated as fixed fee and is still bound by the ₹1,51,000 limit.
• Not verifying registration. Caps protect you only with a genuine SEBI registered adviser. Check the INA number first.

Under the fixed fee mode the cap is ₹1,51,000 a year per family across all services. Under the AUA mode it is 2.5 percent of your Assets under Advice a year per family. The adviser uses one mode, not both, and the cap binds across every service.

No. The two modes are mutually exclusive for a given client. The adviser cannot add an AUA percentage on top of a fixed fee. If a minimum AUA fee effectively becomes a flat charge, it is treated as fixed fee and is still capped at ₹1,51,000.

It is per family per year, across all the advisory services the adviser provides. An adviser cannot bill each family member separately to get around the limit.

First raise it in writing with the adviser and ask for a refund of the excess. If that fails, file a complaint on the SEBI SCORES portal at scores.sebi.gov.in, and if needed use SEBI's online dispute resolution mechanism, SMART ODR.

It can. The IAASB, run by BSE Limited, reviews the fixed fee limit periodically, in consultation with SEBI. Always check the current figure before signing.

SEBI is not an ordinary public authority for routine commercial grievances, so the right tool against your adviser is a SCORES complaint, not an RTI. But if your dispute involves records held by a government body or public authority, you can file an RTI for those records. The AI RTI Drafter below helps you frame such a request.

• SEBI circular, Guidelines for Investment Advisers, SEBI/HO/MIRSD/MIRSD-PoD-1/P/CIR/2025/003, dated 8 January 2025, which revised the fixed fee cap to ₹1,51,000. See sebi.gov.in.
• SEBI Master Circular for Investment Advisers dated 27 June 2025, which consolidates the framework including the AUA cap of 2.5 percent and the MITC requirement. See sebi.gov.in.
• SEBI FAQs for Investment Advisers, confirming the fee modes, the family of client basis, the IAASB role and the SCORES grievance route. See sebi.gov.in.

• The RTI Playbook
• AI RTI Drafter
• Mutual fund and demat grievances on SCORES and SMART ODR
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