SEBI registration for algo trading

Dear Sir,

We would like to have your thoughts in relation to our below query:

Background:

  • A company provides algorithms for trading to its clients;

  • The broad contours of the underlying strategy (e.g. Selling Nifty options, Buying Nifty options, etc) is disclosed to the client at the time of the subscription. However, the finer details (e.g. additional filters for entering the trade, stop loss parameters, etc) of the strategy are confidential and not disclosed;

  • Clients subscribe to the alogs and opt to run the algos by activating them through their broker accounts every morning. Clients choose whether or not they want to run the strategy on any given day, the amount of funds to be deployed in the strategy, etc;

  • The service provider only provides technical and execution support for the algo and charges only a fixed fee per month;

Query:

  • Whether providing algos by the company would require the service provider to be registered with SEBI under SEBI (Investment Adviser) or any other regulations?

Looking forward to hearing from you.

Thanks and regards,

Team Uno