In short
- Since 29 Aug 2024, SEBI-regulated firms and their agents cannot associate, directly or indirectly, with anyone who gives securities advice without registration or claims returns without permission.
- 'Association' means money or money's worth, referral of a client, interaction of IT systems or anything similar. A fee, a per-signup payout or shared leads all count.
- Marketing with a creator is allowed if the creator does neither banned thing. Education is allowed, and since 8 May 2026 the price-data look-back is 30 days, not three months.
- An agency does not break the chain. SEBI's FAQ says advertising or lead generation through a marketing agency is a violation if it ends up linking you to a prohibited person.
SEBI's rule on finfluencers does not license creators. It sits on the brand side: persons regulated by SEBI, and their agents, may not have any direct or indirect association with anyone who gives securities advice without registration or permission, or who claims returns or performance without permission. The rule has applied since 29 August 2024, and SEBI explained it in a circular of 22 October 2024 and a FAQ circular of 29 January 2025.
Our page on fintech influencer marketing sets out the rule and the first campaign decisions. This post goes deeper into the FAQs, because that is where the answers brand teams need are: who counts as an agent, what counts as association, what an agency changes, and where education ends and advice begins. For the wider channel, see our complete guide to influencer marketing in India.
The timeline
| Date | What happened |
|---|---|
| 26 Aug 2024 | SEBI notified the amendments to the Intermediaries, Stock Exchanges and Clearing Corporations, and Depositories and Participants regulations |
| 29 Aug 2024 | Published in the Official Gazette, and in force from that date, per SEBI's FAQ |
| 22 Oct 2024 | Circular SEBI/HO/MIRSD/MIRSD-PoD-1/P/CIR/2024/143: regulated persons and agents to end existing contracts with such persons within three months |
| 29 Jan 2025 | FAQ circular SEBI/HO/MIRSD/MIRSD-PoD-1/P/CIR/2025/11 |
| 8 May 2026 | Education-versus-advice FAQ revised: look-back changed from the preceding three months to the preceding thirty days |
We read both circulars in full on SEBI's site. They are primary sources, so our confidence in what they say is high. Whether SEBI has acted against any named creator is outside what we reviewed.
Who is covered
The FAQ defines a "person regulated by the Board" as a person registered under section 12 of the SEBI Act, an asset management company of a mutual fund, the investment manager of a registered alternative investment fund or infrastructure investment trust, or the manager of a real estate investment trust. Stock exchanges, clearing corporations and depositories, which SEBI calls market infrastructure institutions, have parallel provisions.
The rule also covers agents. The FAQ uses the Indian Contract Act's idea of an agent, says it depends on the facts, and gives examples: employees, mutual fund distributors and authorised persons of stock brokers. It adds that mutual fund distributors, authorised persons, PMS distributors and AIF distributors are agents of asset management companies, stock brokers, portfolio managers and AIF managers, and those principals must ensure their agents comply. If you run a finance app that is an authorised person of a broker, a creator deal you sign is also the broker's problem.
The two banned activities
SEBI's wording is the same in both circulars. A regulated person or agent may not associate with someone who:
- gives advice or a recommendation, directly or indirectly, about a security or securities, unless registered with or permitted by SEBI to do so; or
- makes any claim of returns or performance, expressly or impliedly, about a security or securities, unless SEBI has permitted the claim.
The restriction attaches to the person, not to the sponsored post. That is the point most brand teams miss. A clean, compliant sponsored Reel does not help if the same creator posts stock tips on another channel, because the association is with a person who is engaged in a prohibited activity "directly or indirectly".
What counts as association
SEBI's FAQ defines association as a transaction involving money or money's worth, referral of a client, interaction of information technology systems, or any other association of a similar nature, by whatever name. It says sharing client information is similar to referring a client. Applied to a campaign:
| Campaign element | Association under the FAQ? | Basis |
|---|---|---|
| Flat fee to a creator | Yes, it is a transaction involving money | The FAQ's money limb |
| Per-signup or per-lead payout | Yes, it is money and a client referral | Money and referral limbs |
| Sharing leads, client lists or contact data with a creator | Yes | The FAQ treats sharing client information as like a referral |
| Integrating a creator's tracking link or tool with your systems | Likely, through the IT-systems limb | Our reading |
| Free product, trip or event access | Likely, as money's worth | Our reading |
| A creator posting about your app without any payment or link | Not by the definition, but check the creator's wider activity | Our reading |
Marketing is allowed, with conditions
Do not read the rule as a ban on finance creators. The FAQ says regulated persons and agents may associate for branding, marketing and promotional activities with another person, provided that person is not engaged in either prohibited activity, directly or indirectly. Investor education is not one of the banned activities either.
The FAQ also covers channels:
- Marketing agencies. Advertising, branding or lead generation through a marketing agency is a violation if the regulated person or agent indirectly ends up associated with an entity engaged in a prohibited activity. An agency's creator roster is your association. Ask the agency which finance creators it uses, and check them yourself. Our guide to choosing an influencer marketing agency lists questions to ask.
- Digital platforms you control. Where the regulated person has control over where its ads or content appear, it is not a violation as long as it does not end up associated with a prohibited person, because it can prevent that.
- Digital platforms you do not control. If the firm has no control over the content or entity it ends up next to, and it indirectly ends up associated with a prohibited entity, it is a violation.
- Non-SEBI products. The FAQ says a broker that associates with a person promoting insurance, who is engaged in a prohibited activity, still violates SEBI's regulations.
The October 2024 circular also referred to association through a "specified digital platform" as outside the rule, with the platform criteria to be specified separately. We did not find a platform specified in the sources we read, so do not assume any platform qualifies.
Education versus advice
SEBI's FAQ says a person engaged solely in education is one who does neither banned activity. It adds a test for market data: such a person should not use market price data of the preceding thirty days to speak about or display the name of any security, including a code name, in a way indicating future price, advice or recommendation. On 8 May 2026 SEBI changed that window from three months to thirty days. NISM can use data with a one-day lag for its simulation lab.
In practice, a creator explaining what a price-to-earnings ratio is, with a chart from a year ago, is on safer ground than one naming a stock with last week's prices and a view on where it goes. That example is our reading, not SEBI's. Treat any script that names a security as a compliance review item, whatever the label says.
Consequences for the regulated firm
The FAQ says SEBI may take such action as it deems fit for a breach, including enquiry, adjudication and orders under section 11B of the SEBI Act. It lists penalty, suspension or cancellation of registration, and debarment as potential actions. These sit on regulated persons and agents. Nothing in the circulars we read sets a penalty for the creator, and we do not cover SEBI's separate powers over advisers.
The creator-facing rule: ASCI's Addendum II
The creator-facing rule is ASCI's. Its Addendum II (6 March 2025) says influencers who give advice on stocks or investments should be registered with SEBI, with the registration number stated along with their name and qualifications. For other financial advice, it expects suitable qualifications such as an IRDAI licence, CA or CS. The qualifications go on screen upfront, in the opening remark of a video, at the top of a text post, or at the start of audio. A 28 April 2025 update limited this to technical advice, so generic content does not need them. See our ASCI guide.
What brands and creators can and cannot do
| Can | Cannot | |
|---|---|---|
| SEBI-regulated brand or its agent | Pay a creator who does no advice and makes no return claims, anywhere | Pay, refer clients to, or share data with a tipster |
| Run education and app walkthrough content, with compliance sign-off | Use an agency to reach a creator you could not contract with directly | |
| Work with a registered adviser or analyst whose permissions cover the content | Keep an old contract with a prohibited person, now that the three months have passed | |
| Finance app that is not SEBI-regulated | Run creator campaigns under ASCI and consumer rules | Ignore flow-down terms from a regulated partner, if you are its agent |
| Creator | Explain concepts, product features, fees and risks without advice or returns | Recommend securities, or promise or imply returns, without registration or permission |
| State qualifications and registration upfront if you advise | Take a broker's referral payout while giving unregistered tips |
A vetting routine
- Ask what the creator does. Education, advice, or neither? Get it in writing.
- Check registration. Collect the number and category, and check it against SEBI's own published lists. Save a dated copy.
- Read 90 days back. Look for tips, return claims, tip-channel links and betting promotions. ASCI's FY2025-26 report found illegal betting was 54 percent of influencer violations, so a finance creator with betting posts is a double red flag.
- Read the whole feed, not the brief. The rule attaches to the person.
- Script review. Compliance signs off any script that names a security, shows a price or mentions returns.
- Monitor during the campaign. Re-check the feed mid-way and at the end.
Our performance influencer marketing page explains per-signup deals. For a regulated brand, get legal advice before any link between pay and sign-ups.
Contract clauses to add
These are illustrative. Have a lawyer adapt them.
Warranty. The Creator confirms that they do not provide securities advice or recommendations without registration, and do not claim returns or performance, in any content on any channel, and shall tell the Brand immediately if that changes.
Termination. The Brand may pause content and terminate this agreement without further payment if the Creator breaches the warranty.
No referral payments. No fee under this agreement is linked to clients referred or to client information shared, unless the Brand's compliance team has approved the arrangement in writing.
More clauses are in our guide to influencer contracts in India, and our post on Consumer Affairs endorsement guidelines covers due diligence on claims.
How sure we are
| Point | Confidence | Note |
|---|---|---|
| Content of the 22 Oct 2024 circular and 29 Jan 2025 FAQ | High | Read in full on SEBI's site |
| In-force date of 29 Aug 2024 | High | From SEBI's FAQ |
| 8 May 2026 revision to the education FAQ | High | Footnote in the FAQ |
| Our readings in the tables (marked "our reading") | Low to medium | Ask your compliance team |
| Any platform treated as a "specified digital platform" | Not established | Not found in the sources we read |
Compliance teams at regulated firms should read both circulars in full before briefing a finance creator. For help casting registered and education-led finance creators, see how we work or send us a brief.
This is general information, not legal advice.
Sources
- Association of persons regulated by the Board and their agents with certain persons (SEBI/HO/MIRSD/MIRSD-PoD-1/P/CIR/2024/143), SEBI (22 Oct 2024)
- Details and clarifications on association with persons engaged in prohibited activities (SEBI/HO/MIRSD/MIRSD-PoD-1/P/CIR/2025/11), SEBI (29 Jan 2025, updated 8 May 2026)
- The ASCI Code and guidelines page: Addendum II for health and financial influencers (6 Mar 2025), ASCI (undated page, accessed 31 Oct 2026)
- Press release: update to the influencer guidelines, ASCI (28 Apr 2025)
- Annual Complaints Report 2025-26, ASCI (28 May 2026 (date per press coverage))
Frequently asked questions
What are SEBI's rules on finfluencers?
SEBI's regulations, in force from 29 August 2024, bar regulated persons and their agents from any direct or indirect association with someone who gives securities advice without registration or permission, or who claims returns or performance without permission. SEBI's circulars of 22 October 2024 and 29 January 2025 explain them. See our fintech influencer marketing page for campaign planning.
Can a stockbroker pay a finfluencer to promote its app?
Only if the creator does neither banned activity, anywhere. SEBI's FAQ allows branding and promotional association with a person who is not engaged in unregistered advice or return claims. Payment is a form of association, so paying a creator who gives tips elsewhere would breach the rule even if the sponsored post is clean.
Can a creator talk about stock returns in a sponsored post?
Not if the brand is SEBI-regulated and the creator has no permission to make return or performance claims, because that is one of the two banned activities. ASCI's Addendum II separately expects creators who advise on investments to hold SEBI registration and show the number. Brief on product features, fees, process and risk instead.
Does the SEBI rule apply to a fintech that is not SEBI-regulated?
Not directly, since it binds persons regulated by SEBI, exchanges, clearing corporations, depositories and their agents. A fintech that acts as an authorised person or distributor for a regulated firm may be an agent, and the principal must ensure its compliance. ASCI's finance rules and consumer law apply to everyone.
What is the difference between investor education and advice?
SEBI says education is not one of the banned activities, provided the person does not advise or claim returns. Its FAQ says a person engaged solely in education should not use market price data of the preceding thirty days to talk about or display a security in a way that indicates future price, advice or recommendation. The window was three months until 8 May 2026.
What can happen to a regulated firm that breaks the rule?
SEBI's FAQ says it may take such action as it deems fit, including enquiry, adjudication and orders under section 11B of the SEBI Act. It lists potential actions as penalty, suspension or cancellation of registration, and debarment. The circulars describe consequences for regulated entities and agents, and we have not covered SEBI's other powers.
How do I check a finance creator's SEBI registration?
Ask for the registration number and the category it is held in, then check it against SEBI's own published listings, not a screenshot. Note ASCI's Addendum II expects the number to be stated with the creator's name and qualifications in the content. Keep a dated copy of the check in the campaign file.