Based on the SEBI regulatory framework—including the SEBI Algorithmic Trading Circular you don't need SEBI IA or RA registration provided you maintain neutrality. 

Under SEBI (Investment Advisers) Regulations, 2013 and SEBI (Research Analyst) Regulations, 2014, registration is triggered when you provide opinions, recommendations, buy/sell calls, or price targets concerning securities, because your platform is built as a purely technical utility tool.

The 2026 SEBI Algo Framework do not to you because you do not execute or route orders.. Since  your app stops entirely at sending a Telegram notification and does not connect to a broker API to place the trade, you do not fall under the definition of an "Algo Provider" executing market orders.

Even though you are a free tech platform, SEBI actively scans for unregulated tech tools that "mimic" advisors. To protect your platform from being flagged as an unauthorized advisory or execution service, you should prominently display a legal disclaimer on your website, sign-up flow, and inside the Telegram alerts. You may also add that the developers/owners of this platform are not registered with SEBI as Investment Advisers (IA) or Research Analysts (RA). Consult a qualified financial advisor before making any investment decisions.” Ensure that the Telegram alert text sent to the user reads like a mathematical factual trigger, not an instruction.

your tool acts strictly as an interactive calculator and utility platform rather than an advisory or execution setup, it sits outside these specific licensing requirements. However, operating in the Indian capital markets space requires absolute transparency to remain safe from regulatory scrutiny

2) you are not investment advisor or research analyst .you do not give any buy / sell calls 

3) The user defines the rules, mathematically inputs parameters, and creates custom combinations.

4) Your servers do not hold API keys, manage credentials, or send orders to broker APIs.

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  No Subjective Opinion: You do not recommend specific stocks, sectors, or entry points.
  
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  User-Driven Actions: The user consciously selects the indicators, adjusts the mathematical parameters, and triggers the logic.
  
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  Fully Disclosed Logic: Open-logic ("White Box") systems do not hide the underlying strategy parameters. SEBI's RA mandate primarily targets opaque "Black Box" or ready-made strategy providers. 
  

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  Zero Execution Capability: You do not process, route, or execute any transactional commands.
  
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  Information-Only Output: A private Telegram alert is legally classified as an informational notification, not an algorithmic order stream. 
  

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  No Pre-Packaged Strategies: Do not offer default configurations with titles like "Our Best Scalping Settings" or "Premium Intraday Strategy." Every setup must require manual input or choice by the user. [
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  No Shared Public Channels: Telegram alerts must exclusively go to a private, 1-on-1 chat with the specific user who configured that indicator. Sending the same alert to a group channel constitutes public research distribution. 
  
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  No Direct Broker Integration (Webhooks): Do not add buttons or features (like webhooks) that allow users to automatically forward that Telegram alert to a broker's API to execute a trade. Once your system connects directly to execution software, it triggers exchange empanelment and broker infrastructure compliance. 
  

Yes it’s important to put disclaimers to avoid frivolous unwanted litigation 

Dear Sir/Madam,

On the facts stated, SEBI RA/IA registration may not be required if your app is only a neutral charting/indicator tool, gives no stock-specific tips/advice, no personalised recommendation, no return assurance, and does not execute or route orders.

The algo framework generally becomes relevant where orders are generated/routed/executed through broker/API systems.

However, if your alerts practically amount to buy/sell recommendations, SEBI may view it differently.

Use clear disclaimers: “for educational/tool use only”, “not investment advice/research recommendation”, “past backtest is not future return”, and “user trades at own risk”.

Take a written compliance opinion after showing the exact app flow, screenshots and alert wording.

Advocate Saurabh Agrawal

Dear Client, Even though your platform does not execute orders or provide public buy or sell calls the legal landscape in India is very strict regarding investment advice and automated signals SEBI’s 2026 regulations focus on substance over form If your app provides trade in signals based on pre- defined logic. SEBI may classify these as actionable investment advice Even if the user sets their own parameters providing a tool that triggers alerts based on specific security analysis could be viewed as providing unregistered investment advisory or unregistered Research Services to operate legally you would likely need to register as a research analyst or investment advisor if the platform is deemed to be influencing investment decisions.

The Algo framework primarily regulates systems that automatically place modify or cancel orders via broker Apps since your app only sends an alert to Telegram and leaves the actual trade execution to the user you may technically fall outside the algorithm execution definition. However, if your alert system is based to trigger orders on a broker platform it would be pulled into the regulatory framework, to stay safe you must avoid any black box signaling if you provide a platform where users build their own custom strategies ensure you are not hosting or prompting pre built ready- made strategies as the later may strictly be regulated and often required the provider to be SEBI registered entity.

Finally, while a disclaimer is mandatory it does not provide legal immunity against SEBI if the service is found to be non- compliant. Your platform must include clear prominent disclaimer stating that the alerts are for informational purposes only do not constitute investment advice and the user is solely responsible for their trading decisions you should explicitly state that you are not a SEBI registered advisor and that your tools are for educational purposes only. I hope this answer helps, if you have any further query kindly do not hesitate to contact us. Thankyou