Advertising Past Performance After PaRRVA: What Changes for RAs
The Advertisement Code says what you can claim. PaRRVA now checks whether the claim is true. Both rules apply at the same time, and neither one replaces the other.
Note: This describes how two SEBI frameworks interact, in general terms. It is not a substitute for reading the current Advertisement Code and PaRRVA circulars, both of which continue to be updated.
Two separate SEBI rules now govern any performance claim a Research Analyst makes: the Advertisement Code, which sets what you can say and how, and PaRRVA, which checks whether what you said is accurate. Confusing the two, or assuming one covers the other, is the mistake to avoid.
Free download
PaRRVA Enrolment Readiness Checklist
- An 11-point checklist covering who must enrol, what to read, and what to verify before the deadline
- The full Dec 2025 to Sep 2026 timeline in one place
- A one-page printable reference to keep next to your compliance calendar
What the Advertisement Code still requires
Nothing in PaRRVA changes the underlying disclosure obligations: the full universe of recommendations, not a curated subset; the standard disclaimer that past performance does not guarantee future results; clear methodology behind any hit rate or return figure. An RA whose performance page complies with the Advertisement Code today has not done extra, unnecessary work once PaRRVA is added, that groundwork is exactly what a verification process needs to check against.
What PaRRVA adds on top
PaRRVA does not evaluate whether your disclosure language is compliant. It checks whether the number itself, the 42% return or the 61% hit rate, matches the underlying trade and price data an independent agency can verify. A performance claim can be Advertisement Code-compliant in its framing and still fail PaRRVA verification if the underlying figure is wrong, and the reverse: a verified figure still needs Advertisement Code-compliant framing around it. Neither one is sufficient alone.
The practical sequence
Get the underlying data right first. That means every recommendation timestamped, every action logged, and the calculation methodology documented, exactly what recommendation performance tracking already covers. Then enrol with PaRRVA before the current deadline, detailed in the enrolment guide. An RA who has clean, structured performance data going into enrolment has a much shorter path through verification than one reconstructing history from scratch.
FAQ
Does PaRRVA replace the SEBI Advertisement Code?
No. The Advertisement Code still governs what an RA can say and how, including the requirement to disclose the full universe of recommendations rather than a curated subset. PaRRVA adds a separate, independent verification step on top of that: it checks whether the specific numbers being advertised are accurate.
Can I still show performance figures if I have not enrolled with PaRRVA yet?
During the enrolment window, yes, subject to the Advertisement Code as before. After the enrolment deadline, SEBI's framework ties continued sharing of past risk-and-return data to PaRRVA verification, so an unenrolled RA is in a materially weaker position to keep presenting those figures. See the enrolment guide for the current deadline.
Does a verified figure still need the standard disclaimers?
Yes. Verification confirms the number matches the underlying data; it does not remove the disclosure obligations SEBI already requires around risk, the fact that past performance does not guarantee future results, and the methodology behind the figure.