Diwali Offers for SEBI Research Analysts: What You Can Advertise
Muhurat trading is on Sunday, 8 November. Every RA's WhatsApp is about to fill with festive banners. Here is how to run an offer that does not end up in an inspection report.
Short answer: a festive fee is fine. Urgency, free picks, last year's returns, gifts and superlatives are not. Run the offer like any other ad: your registration details, the standard lines, and prior approval before it goes out.
What SEBI tells your clients about offers
The investor charter every RA displays has a list of Don'ts for clients. Two of them read:
Don’t fall prey to luring advertisements or market rumors.
Do not get attracted to limited period discount or other incentive, gifts, etc. offered by Research Analyst.
Your own charter tells clients to be wary of exactly the "limited period" festive push most marketing playbooks recommend. An offer that leans on a deadline and a gift is working against the document on your website.
Six festive ad lines, and what to say instead
| The line | The problem | Instead |
|---|---|---|
| "Diwali dhamaka! 50% off, only 3 hours left" | Urgency and fear-of-missing-out language | Annual plan at the festive fee until 15 November. Plan terms on our website. |
| "Free Muhurat picks for everyone who signs up" | Free research used as an inducement | Promote the service and what it covers, not free calls |
| "Last Diwali our picks returned 38%" | Past performance without PaRRVA verification | Drop it. No return figure of any kind |
| "Join today, win a silver coin" | Gifts, prizes and contests | Drop it |
| "Samvat 2083 sure-shot multibagger" | Implied assured returns and "multibagger" language | Describe your research process and coverage |
| "India’s No.1 Research Analyst" | Superlative with no independent basis | Your registration details and years in practice, stated plainly |
A dated offer is not the same as urgency. "Festive fee until 15 November" states a fact. "Only 3 hours left!" with a ticking timer is pressure.
Muhurat picks are research first
Sending Samvat 2083 ideas to paying clients is your normal service. It follows your normal process: the basis on record, your disclosures on the report, and the recommendation archived. Posting the same picks publicly to pull in sign-ups turns them into promotion as well, which brings in the ad code. Most RAs are better off promoting the service and keeping the picks for clients.
Before a festive ad goes out
- Your name as registered with SEBI, registration number and RAASB enlistment number on the ad
- The standard warning and the registration line, word for word
- A link to your website on short formats (WhatsApp status, SMS, social posts) where the details do not fit
- The festive fee also shown on your website and consistent with your client agreement
- No return figure, testimonial, prize or "free" research
- Prior approval from the supervisory body before the ad goes out
The registration line, word for word:
Registration granted by SEBI, enlistment with BSE and certification from NISM in no way guarantee performance of the intermediary or provide any assurance of returns to investors.
Timing: prior approval takes time. Submit the festive creative now, not on Dhanteras. If it is not cleared before the session, do not run it.
Checking festive copy in Aktai
Aktai's ad pre-check is an AI check of promotional copy against the RA ad code, with your approve or reject on record. Paste the banner text in before you submit it for approval, and it flags the urgency line or the return figure while there is still time to change it. Fee plans are checked against the SEBI limit, on the amount the client pays, before you send them. See the features page for the rest.
Questions RAs ask
Can a SEBI Research Analyst offer a Diwali discount?
Nothing in the RA rules bans a lower fee. What gets flagged is how the offer is sold: urgency language, free research as a hook, gifts, contests and any return figure. A plain, dated offer with your registration details and the standard lines is a different thing from a countdown banner.
Can I post my Muhurat trading picks publicly?
A public post with stock picks is research and promotion at once. It carries your research disclosures and the ad-code checks, and it needs the same prior approval as any other ad. Many RAs keep Muhurat research for paying clients and promote the service, not the picks.
Can I mention how last year’s Diwali picks did?
No, not in an ad. Past performance of any kind is off limits in RA advertising unless it is verified through a PaRRVA. "Our Samvat 2082 picks returned 31%" is a performance claim, however true.
Does a festive annual plan change the fee rules?
No. The SEBI fee limit for individual and HUF clients still applies, you can collect at most a year in advance, and the plan has to match your client agreement and the fees shown on your website.
Do festive ads need approval before they go out?
Yes. RA advertisements need prior approval from the SEBI-recognised supervisory body before they are issued. Plan for that: a banner drafted on Dhanteras is unlikely to be cleared in time for the Muhurat session.
General guidance for SEBI-registered Research Analysts in India, not legal advice. Aktai is software; you, the registered RA, remain responsible for your advertisements. Check the current Master Circular and your supervisory body's process before relying on any point here.