SEBI Draft Circular: Participation of Retail Investors in Algorithmic Trading

Hello everyone,

SEBI has recently released a draft circular to gather public comments on enabling retail investors to participate in algorithmic trading (algo trading). Till now, there hasn’t been any specific regulation regarding retail participation via algo and algo trading has traditionally been the domain of institutional investors. This proposal aims to bring it within reach of retail participants under a structured framework.

Here’s a summary of the key highlights:

  • Expanded Access for Retail Investors
    Retail investors may soon gain access to algo trading under a regulatory framework designed to ensure transparency, security, and fairness.

  • Stakeholder Responsibilities

    • Brokers: Will ensure that all algo trading activities are compliant, including registering algorithms and providing secure API access.
    • Algo Providers: Must meet eligibility criteria and register with exchanges to offer their services.
    • Exchanges: Will oversee compliance, provide unique identifiers for algorithms, and ensure audit trails.
  • Algo Classification

    • White-box Algos: Transparent and replicable, where the logic is disclosed to the user.
    • Black-box Algos: Non-transparent algos requiring registration as Research Analysts and maintenance of detailed research reports.
  • APIs and Security
    APIs will require secure mechanisms like two-factor authentication, unique identifiers, and whitelisting to ensure traceability and prevent misuse - Only OAuth login mechanism to be allowed

  • Implementation Timeline
    The proposed framework is expected to roll out in 2025, subject to feedback and final approval from SEBI.

But there are a lot of small details in there too:

  • Point 5 (II) c aimed at Individual Algo traders who build their own code

    Algos developed by tech-savvy retail investors themselves, using programming knowledge, shall also be registered with the Exchange through their broker. Further, the same registered algo shall be permitted to be used by such retail investors for their family. ‘Family’ for this purpose would mean self, spouse, dependent children and dependent parents.

  • Point 5 (II) d suggesting Open APIs to be replaced by closed APIs where verification of end use and user is important

    Brokers shall not permit open APIs and allow access only through unique vendor client specific API key and static IP whitelisted by broker to ensure identification and traceability of the vendor and end user

  • All Algos will have to be registered at Exchanges This means both category of algos: Individual use for algo traders (which will happen via the Broker) and Redistribution Algos - only permitted by Research Analysts where necessary reporting needs to be maintained and fresh algo approval needs to be taken.

These are just the broader points of the discussion paper. There are more such details outlines in this paper.

It is great to know that SEBI recognizes the growing interest among retail investors in leveraging algorithms to automate trading strategies. The circular builds on existing algo trading guidelines and proposes safeguards to ensure responsible usage and market stability.
This is in continuation to their initial discussion paper which was dated 9th December 2021 - here.

What This Means for Us

This is a draft circular, meaning no decisions have been finalized yet. SEBI is seeking input from stakeholders, including brokers, algo providers, and retail investors. As a regulated entity, we are committed to implementing whatever mode SEBI finalizes, ensuring full compliance and seamless integration for our users.

We would love to hear your thoughts on the same, so feel free to drop comment below with your thoughts on the proposed framework and any questions that you might have for us.

Here is the link to draft circular: Participation of Retail Investors in Algorithmic Trading - SEBI Draft Circular

1 Like

It’s over!

So all algos/plans have to be leaked to brokers and exchanges including all python code n config files? :joy:

I don’t think it’s “great”…

I can understand the commercial algo providers being regulated. That is ok. But a retail guy accessing the API shouldn’t be burdened with all the compliance cost and other hassles. All retail orders go through broker OMS and RMS where there is sufficient throttling. If the regulator wants to specify tight throttling limits, so be it. But such orders are not going to cause any systemic risks. If it can then it can be caused by manual orders also.

In an era where HFT algos are running in exchange premises, retail is simply being burdened more by raising the entry barrier.

4 Likes

This is disastrous and quite impractical. Of the top of my head, here are some key concerns:

  1. Loss of IP - rather lack of IP protection
  2. Additional cost and overhead- Cost and time taken for auditing might make some strategies useless
  3. Impractical - parametric changes or minor code changes will require recertification which will really make this impractical
  4. Simple execution using APIs/ webhooks using alerts will become practically impossible.
  5. Third party platforms like Tradingview may not be able to offer 2FA making execution complicated and slow.
    Really concerned with this paper.
6 Likes