On November 06, 2025., the Securities and Exchange Board of India (“SEBI”) issued a consultation paper inviting public comments on proposed amendments to the SEBI (Certification of Associated Persons in the Securities Markets) Regulations, 2007 (“CAPSM Regulations”). The proposed amendments seek to update, streamline, and align the certification framework administered through the National Institute of Securities Markets (NISM) with evolving market practices and technological advancements (“Consultation Paper”).[1]
1. Objective:
The Consultation Paper seeks public views, comments, and suggestions on proposed revisions to the CAPSM Regulations, particularly in relation to:
1.1. Review and expansion of the definition of ‘Associated Persons’;
1.2. The manner of obtaining NISM certification;
1.3. Inclusion of electronic modes for participation in Continuing Professional Education (“CPE”) programs; and
1.4. Review of existing exemption criteria for certification based on ‘Principal’, ‘Age’, and ‘Experience’
2. Background
2.1. Under the existing CAPSM Regulations, SEBI may mandate that ‘Associated Persons’, individuals engaged or employed by intermediaries regulated by SEBI, obtain the requisite certification from NISM.
2.2. The CAPSM Regulations specify the process for obtaining and renewing NISM certificates, which currently require candidates to pass the relevant certification examination, valid for a period of 3 (three) years, and to meet CPE requirements for renewal.
2.3. When first notified in 2007, the Regulations provided specific exemptions for certain categories, including:
- Persons designated as ‘Principal’;
- Persons aged 50 (fifty) years or above as of the date of notification of the relevant Regulations; and
- Persons with more than 10 (ten) years of experience in the securities market as on the date of such notification.
2.4. In view of the significant evolution of the Indian securities markets and to enhance the robustness, clarity, and relevance of the certification framework, SEBI has proposed a comprehensive review of the CAPSM Regulations.
3. Key Proposals
SEBI has sought stakeholder feedback on the following specific proposals:
3.1. Review/Expansion of ‘Associated Persons’ to align the definition with current market roles and functions (para 3.1.1).
3.2. Alternative Modes of Certification – to include long-term or long-duration NISM programs as an alternative method for obtaining NISM certification and fulfilling CPE requirements (paras 3.2.1 and 3.4.1(e)).
3.3. Electronic Participation in CPE to formally recognise electronic / online delivery modes for CPE programs (para 3.3.1).
3.4. Revised Exemption Criteria, to replace individual exemptions (for Principal, Age, and Experience) in Regulations 4(2) and 4(3) with a combined exemption based on both age and experience (para 3.4.1).
3.5. Date of Calculation of Age and Experience, to link the cut-off date for determining a candidate’s age and experience to the date of examination or CPE (para 3.4.1(b)).
4. Public Consultation Process
4.1. SEBI has invited public comments on the above proposals, supported by appropriate rationale, to be submitted on or before November 27, 2025, through the web-based form accessible at:
https://www.sebi.gov.in/sebiweb/publiccommentv2/PublicCommentAction.do?doPublicComments=yes
4.2. Stakeholders are advised to carefully review the instructions provided on the SEBI portal prior to submission.
4.3. In case of any technical difficulty in submitting comments via the online form, stakeholders may write to nismdivision@sebi.gov.in with the subject line:
“Issues in submitting comments on Consultation Paper on Amendments to SEBI (CAPSM) Regulations, 2007.”
[1] https://www.sebi.gov.in/reports-and-statistics/reports/nov-2025/consultation-paper-on-amendments-to-sebi-certification-of-associated-persons-in-the-securities-markets-regulations-2007_97657.html