India’s securities regulator has moved to redraw the lines for credit rating agencies (CRAs) that rate instruments supervised by authorities other than SEBI. The latest circular sets out operational firewalls, disclosure standards, and client-handling norms aimed at preventing regulatory confusion and protecting investors who might assume SEBI safeguards apply to every rating.
At the heart of the directive is a simple concern: CRAs increasingly rate products governed by banking, insurance, or housing regulators, yet investors often treat those ratings as if they fall under SEBI’s protective umbrella. The new framework forces agencies to clearly separate these activities—digitally, financially, and contractually.
Operational Separation Becomes Mandatory
CRAs must now create distinct channels for grievances. The circular states that agencies “shall handle grievances related to SEBI regulated activities and grievances related to activities under the purview of other FSR(s) through distinct and separate email IDs” and must maintain “separate webpages or sections on their website for disclosures” . Shared infrastructure is permitted, but communication lines must be unambiguously divided.
Financial safeguards have also been strengthened. Any rating work for other regulators cannot dilute SEBI’s net-worth requirements. Agencies must ensure that external mandates do not erode the capital buffer prescribed under SEBI regulations, and any additional net-worth conditions imposed by other regulators will be over and above SEBI norms.
Sharper Labelling in Rating Reports
Perhaps the most visible change will appear in rating rationales and press releases. Every report must now name the regulator overseeing the instrument and explicitly warn that SEBI’s investor-protection mechanisms do not apply. Where a single document covers both SEBI and non-SEBI products, the CRA must provide “a clear segregation and labelling of SEBI regulated instruments and instruments falling under the regulatory purview of other FSR(s).”
Marketing material faces similar restrictions. Advertisements for non-SEBI activities must be distinct, carrying a prominent disclaimer that SEBI’s grievance redressal framework will not be available.
Tighter Client Engagement
Before starting any non-SEBI assignment, CRAs must give clients written disclosure explaining the regulatory status and obtain confirmation that the client understands the associated risks. Existing clients are to receive similar intimation, and agencies must certify compliance to SEBI. Internal audits will need to carry a board-approved undertaking confirming adherence to these conditions.
Most provisions will apply after 60 days, while the segregation of grievance channels and communication with legacy clients has a 12-month transition.
What This Means for Investors
The changes are less about credit quality and more about regulatory clarity. Investors frequently assume that every rating issued by a SEBI-registered CRA enjoys identical oversight. That assumption will no longer be tenable.
Better Transparency, Fewer Misunderstandings
Investors will see explicit labels identifying which regulator governs a particular instrument. This reduces the risk of buying a product under the mistaken belief that SEBI’s dispute-resolution mechanisms apply.Due Diligence Becomes Crucial
For bonds or instruments rated under the purview of other regulators, investors must evaluate grievance avenues, compensation frameworks, and supervisory standards separately. The rating symbol may be familiar, but the investor protections may differ materially.Lower Reputational Spillovers
By ring-fencing operations, the move prevents problems in non-SEBI segments from contaminating the credibility of SEBI-regulated ratings. That should strengthen confidence in mainstream corporate bond markets.Short-Term Friction, Long-Term Trust
Agencies will incur compliance costs and operational restructuring. In the near term, this could slow issuance of hybrid or specialised instruments. Over time, clearer rules should improve pricing discipline and investor trust.
The message is unmistakable: a rating is not a universal passport. Investors must read the fine print on who regulates the product behind the grade.
Source: This article is based on the SEBI circular dated February 10, 2026 titled “Obligations on CRAs while undertaking rating of financial instruments falling under the purview of any other Financial Sector Regulator.”
— To read the full circularclick here.

