Compliance · Regulatory explainer
SEBI's January 2025 circular, explained: education, advice, and the data lag that just changed
The short answer
The SEBI circular of 29 January 2025 (number SEBI/HO/MIRSD/MIRSD-PoD-1/P/CIR/2025/11) told every SEBI-regulated intermediary and market institution to cut ties with anyone doing two things without permission: giving securities advice or claiming a return. It defined "association" widely, money, referrals, client data, shared branding, and carved out a clean exception for genuine investor education. It also capped what educators may show: no security named on recent price data in a way that signals a future price. That lag began at three months, but a SEBI circular of 8 May 2026 replaced it with a uniform 30-day lag for both sharing and use of price data, effective 1 July 2026.
This is a rule about a line, not a ban. It does not outlaw teaching, it does not license education, and it does not stop anyone from learning the markets. What it does is decide who a regulated firm may stand next to, and what an educator may put on screen. Read it as a boundary being enforced, and the parts that matter become clear: the two prohibited activities, the width of "association", the education carve-out, and the price-data lag that was three months and is now thirty days.
What's covered
- What the circular is, precisely
- Why it exists: the structure it closes
- The two prohibited activities
- What "association" actually means
- The education versus advice line
- The data lag: three months, now thirty days
- The timeline, and what was superseded
- How to evaluate any content provider
- Where a pure-educational publisher sits
1. What the circular is, precisely
The document is not a new law and not a new licence. It is a clarifying circular, issued on 29 January 2025 and titled, in full, "details and clarifications on provisions related to association of persons regulated by the Board, MIIs, and their agents with persons engaged in prohibited activities." Its job is to operationalise a change made a few months earlier. In August 2024 SEBI notified a set of amendments, to the intermediary regulations and to the companion rules governing stock exchanges, clearing corporations and depositories, that inserted a new duty: a regulated person must not associate with anyone engaged in specified prohibited activities. The circular fills in the operating detail the amendments left open: what association means, what the exceptions are, and what conduct falls inside the prohibition.
Two terms recur and are worth fixing. A person regulated by the Board is any SEBI-registered intermediary: a stock broker, a portfolio manager, a registered investment adviser, a registered research analyst, a mutual-fund distributor, and so on. An MII is a market infrastructure institution, the exchanges, clearing corporations and depositories that form the plumbing of the market. The obligation to keep clear of prohibited activity sits on both groups and on their agents. It does not, by its own force, register or license the educator on the other side of the line; it constrains the educator only through what the regulated firms may do with them and through a separate rule on price data.
2. Why it exists: the structure it closes
For years a particular business shape was common in Indian retail markets. A public-facing "education" brand absorbed the cost of acquiring an audience, while the actual revenue ran through an adjacent operation, often a broadcast channel or a premium tier, that in substance handed subscribers specific trades to place or claimed a track record on past calls. Kept legally separate on paper, the two halves let an unregistered advice business borrow the respectability of education and, frequently, the distribution muscle of a registered intermediary through referral or revenue-share arrangements.
The backdrop that made the regulator act is not in dispute and does not need embellishing. SEBI's own study of individual trading in the equity derivatives segment for FY25, published in July 2025, found that 91 percent of individual traders lost money, a net loss of ₹1,05,603 crore across them. An earlier SEBI study, released in September 2024, put the figure at 93 percent making losses across FY22 to FY24, with aggregate losses above ₹1.8 lakh crore and only around one percent of traders clearing more than ₹1 lakh in profit after costs. Against that base rate, unregistered actors monetising the flow, through tips presented as lessons and returns presented as facts, was the exact conduct the amendments were built to reach.
The circular does not try to inspect every operator. It reshapes the incentives at the chokepoint the regulator can actually control: the registered firm. If a broker or adviser cannot pay, refer to, or share clients with an unregistered advice-giver, the structure loses its distribution and its veneer of legitimacy in one stroke.
3. The two prohibited activities
Everything in the circular pivots on two specific activities, drawn from the August 2024 amendments. A regulated person may not associate with anyone who does either of them without SEBI's leave.
The first prohibited activity is advising on or recommending the purchase, sale or holding of securities to any person, while not being registered with or otherwise permitted by SEBI to do so. This is the classic unregistered-adviser problem: giving somebody an actionable position in a named instrument without holding the registration that regulates that activity.
The second prohibited activity is making a claim, express or implied, of a return or a performance in connection with a security, unless SEBI permits that claim. A "we delivered 90 percent accuracy last quarter" banner is the archetype. The reason a claim is regulated at all is that it is the single most powerful lever for selling an advice product, and an unverifiable one where the maker keeps no audited record.
Note what is not on the list. Teaching how an indicator is computed, explaining a chart pattern, walking through the arithmetic of position sizing, none of that is a prohibited activity, because none of it points a specific person at a specific live trade or claims a return. That is why education survives the rule intact.
4. What "association" actually means
The force of the circular comes from how broadly it reads "association". If the term meant only formal partnership, the structure it targets would simply move to informal arrangements. So the definition is deliberately wide, and it is worth seeing the mechanism as a set of channels that are each closed.
Two practical consequences follow. First, a registered firm carries a due-diligence duty: it is expected to take reasonable steps to ensure the people it associates with are not doing prohibited activity, and to unwind arrangements that offend the rule. Reporting from the period noted that regulated entities were expected to terminate offending contracts on a defined timeline. Second, the education carve-out is not a loophole to be gamed; it protects a person engaged solely in investor education, which means the moment that person also gives live calls or claims returns, the protection evaporates and the association becomes prohibited.
5. The education versus advice line
Because the whole framework turns on a distinction, it helps to make the distinction operational rather than rhetorical. The regulator draws the line on substance: what the activity does to a specific person, not what it is called. Five dimensions separate the two in practice.
| Dimension | Education | Advice or recommendation |
|---|---|---|
| Object | Principles, methods, history, general market knowledge | A specific security to buy, sell or hold |
| Audience | A general audience, not tailored to one person | Directed at, or acted on by, a specific person |
| Specificity | Categorical: how a setup behaves in general | Case-specific: an actionable position, now |
| Return claims | None on live calls | May claim performance, only if SEBI-permitted |
| Registration | Not required for education alone | Requires SEBI registration to be lawful |
The test cuts through the marketing. A channel that says "breakouts on rising volume follow through more often than breakouts without it" is teaching a general tendency; a channel that says "buy this name at this price for this target" is advising, and if unregistered, doing a prohibited activity, no matter how the message is captioned. Understanding why a level matters, rather than being handed the level, is exactly the difference between being taught and being told, and building that judgement is what the method we teach is organised around. The circular, in effect, protects the first activity and regulates the second.
6. The data lag: three months, now thirty days
Alongside the association rule, the January 2025 circular constrained what an educator may put on screen. A person engaged solely in education was told not to use market price data of the preceding three months to name a security, including by code name, in a talk, video, ticker or screen share, in any way that indicated a future price, an opinion or a recommendation. The logic is direct: recent, named price data is the raw material of a live tip, so lagging it strips the "education" of its ability to double as a real-time call.
That figure has since changed, and this is the single point where older explainers are now wrong. The framework had grown untidy: a SEBI circular of 24 May 2024 had already barred exchanges, depositories and intermediaries from sharing real-time price data with third parties and allowed a one-day lag for education, while the January 2025 circular set a three-month lag for using data in education. Two different clocks governed the same data. After a consultation paper in January 2026, SEBI harmonised them. A circular dated 8 May 2026 replaced both with a single uniform 30-day lag for the sharing and the use of price data for educational purposes, effective 1 July 2026. The regulator's own securities-markets education institute was granted a one-day lag exclusively for its simulation lab, which is about as close as a regulator comes to endorsing simulation as a teaching tool.
7. The timeline, and what was superseded
The rule most people call "the January 2025 circular" is one step in a sequence that runs from 2024 into 2026. Seeing the sequence is the fastest way to avoid quoting a superseded number.
| Provision | What it requires | Current status |
|---|---|---|
| No prohibited association | Regulated persons and MIIs must not associate with anyone giving unregistered securities advice or making unpermitted return claims | In force |
| Definition of association | Covers money, referrals, client-data sharing, and shared digital platform or branding | In force |
| Education carve-out | Association is permitted with a person engaged solely in genuine investor education | In force |
| Educator price-data lag | Educators must lag named-security price data; originally three months | Revised: uniform 30-day lag from 1 Jul 2026 |
| Data-sharing lag | MIIs may share price data for education only with a lag; originally one day | Unified with the above at 30 days |
| Education institute lab | A one-day lag for a supervised simulation lab | Retained as a narrow exception |
The practical read for a learner is that the two things that changed are both about data timing, not about the substance of the education-advice boundary. The boundary itself, and the duty on regulated firms to respect it, is exactly as it was.
8. How to evaluate any trading content provider
If you are deciding whether to trust a paid course, a free channel or a subscription group, the circular hands you a clean test. Three questions resolve most cases.
- Is a specific security being pointed at for live action? If yes, and the provider is not SEBI-registered as an investment adviser or research analyst, you are receiving advice from an unregistered source. The legal exposure sits on the provider; the financial exposure sits on you.
- Are return, accuracy or win-rate claims being made on live calls? If yes, without registration and audited records, the claims are not verifiable in any regulatory sense, and making them is itself a prohibited activity.
- Is the provider candid about which side of the line it sits on? A serious educator states its educational scope plainly and declines to give advice. A serious adviser displays its SEBI registration. A provider that blurs the two is usually doing so on purpose.
A "yes" to the first or second question without registration is the signal to look elsewhere, not because the teaching is necessarily poor, but because the regulatory risk on that provider is real, and its consequences, an abrupt shutdown, a refund dispute, a channel that vanishes, tend to land on the people who paid. A short, structured way to work through this is set out in how to evaluate a trading academy, and the deeper question of why so many retail participants lose in the first place is covered in why retail traders lose money. For the regulator's remit itself, see what SEBI does.
9. Where a pure-educational publisher sits
A publisher built to stay on the education side of this line has a straightforward posture, and the circular is precisely the document that describes it. In practical terms that means no specific security is named for a buy, sell or hold decision; examples are anonymised, a stock near a round number, a broad index, and price data is presented at or beyond the required lag rather than live. It means no live signal channel exists to be misused, no return or accuracy figure is claimed on any real-time output, and any tutoring stays on method and discipline rather than case-specific calls.
The structural point is that this stance strengthens as the framework tightens. Operators who lean on advisory framing without registration face rising pressure as the association rule and the data lag are enforced. Operators who are educational in substance have nothing in that machinery to fear, because the rule was written to preserve exactly what they do. Our own compliance posture and the reasoning behind it are documented in full on the compliance page, and the specific choice never to seek registration is explained in why we will never be SEBI-registered.
For the everyday reader, the circular changes nothing you must do and quite a lot about which providers are worth your time. It pushes the market toward teaching that competes on the depth of its curriculum rather than the noise of a tip channel, which is good news for anyone who actually wants to learn.
Frequently asked questions
What did the SEBI circular of 29 January 2025 actually do?
+It clarified how a SEBI-regulated intermediary or market infrastructure institution must keep its distance from anyone engaged in two prohibited activities: giving advice or recommendations on securities without registration, and claiming a return or performance on securities without authorisation. The circular, numbered SEBI/HO/MIRSD/MIRSD-PoD-1/P/CIR/2025/11, defined what counts as association, money, referrals, client-information sharing or shared branding, and carved out an exception for persons engaged solely in genuine investor education. It also set a price-data lag for educators, originally three months.
Is the three-month data lag for educators still in force?
+No. The three-month figure was the original rule from the January 2025 circular, but it has been superseded. A SEBI circular dated 8 May 2026 replaced the split regime, a one-day lag for sharing data and a three-month lag for using it, with a single uniform 30-day lag for both sharing and use of price data in education. The uniform 30-day rule takes effect from 1 July 2026. Any source still quoting three months is describing a regime that no longer applies.
What is the difference between education and advice under the circular?
+Education teaches principles, methods and history to a general audience without pointing at a specific security to buy, sell or hold, and without claiming a return. Advice, in substance, gives a specific person an actionable position in a specific instrument, or claims a performance outcome. The line is drawn on substance, not on labels. Calling a buy call an educational case study does not change its classification, and a genuine explainer does not become advice merely because it names a concept.
What are the two prohibited activities the circular targets?
+First, advising on or recommending securities to any person while not registered or otherwise permitted by SEBI to do so. Second, making an express or implied claim about returns or performance in connection with a security, unless permitted by SEBI to make such a claim. The framework flows from amendments to the intermediary and related regulations notified in August 2024, which inserted these two categories. A regulated entity must ensure it does not associate with anyone doing either.
What counts as association under the SEBI framework?
+Association is defined broadly. It includes any monetary transaction, making or receiving a payment, and it includes referrals and the sharing of client information with, or receiving it from, a person engaged in the prohibited activities. It also covers association through digital platforms and shared branding. The width is deliberate: it closes the structure where a registered brand quietly funnelled clients or fees to an unregistered tip operation while keeping the two legally separate on paper.
Does the circular ban educational content on the stock market?
+No. Genuine investor education is expressly preserved. The circular carves out an exception so that a SEBI-regulated entity may still associate with a person engaged solely in investor education, provided that person does not slip into the prohibited activities. What education may not do is discuss a named security using very recent price data in a way that signals a future price, an opinion or a recommendation. With the 2026 revision, education must use price data lagged by at least 30 days.
Who does the circular bind, the educator or the intermediary?
+Primarily the SEBI-regulated side. The obligation to sever ties sits on persons regulated by SEBI, brokers, portfolio managers, investment advisers, research analysts, and on market infrastructure institutions and their agents. They must ensure their associates are not doing prohibited activities. Unregistered educators and influencers are constrained indirectly: the price-data lag governs what they may show, and losing the ability to partner with regulated platforms removes a distribution and revenue channel.
How should I evaluate a trading content provider against this circular?
+Ask three questions. Is a specific security being pointed at for live action, and if so is the provider SEBI-registered as an investment adviser or research analyst. Are return, accuracy or win-rate claims being made on live calls without registration. And is the provider clear in its own words about which side of the education-advice line it sits on. A provider that gives actionable calls or makes return claims without registration carries real regulatory risk, and the downstream consequences of that risk tend to reach subscribers.
Where can I read the original SEBI circulars?
+The January 2025 circular is published on the SEBI website under legal circulars for January 2025, titled details and clarifications on the association of persons regulated by the Board, MIIs and their agents with persons engaged in prohibited activities, with the number SEBI/HO/MIRSD/MIRSD-PoD-1/P/CIR/2025/11. The May 2024 data-sharing circular and the May 2026 revision that set the uniform 30-day lag are also on sebi.gov.in. Always confirm the current text on the regulator's own site, since operational specifics continue to be refined.
Sources
- SEBI circular of 29 January 2025. SEBI/HO/MIRSD/MIRSD-PoD-1/P/CIR/2025/11, details and clarifications on provisions related to the association of persons regulated by the Board, MIIs and their agents with persons engaged in prohibited activities: defines the two prohibited activities, the width of association, the education carve-out and the original three-month educator data lag. sebi.gov.in
- SEBI data-sharing circular of 24 May 2024. SEBI/HO/MRD/MRD-PoD-3/P/CIR/2024/56, norms for sharing of real-time price data to third parties: barred sharing except for market functioning or regulation, and permitted a lagged feed for education. sebi.gov.in
- SEBI circular of 8 May 2026. Revised norms for sharing and usage of price data for educational purposes: replaced the split one-day and three-month lags with a uniform 30-day lag for both sharing and use, effective 1 July 2026, following the January 2026 consultation paper. Confirm the current text on the regulator's site.
- Parent amendments, August 2024. SEBI (Intermediaries) (Amendment) Regulations 2024 and the companion amendments to the exchange, clearing-corporation and depository rules, notified in August 2024, which inserted the prohibited-association duty the January 2025 circular clarifies.
- SEBI studies on individual derivatives trading. The FY25 study published July 2025 (91 percent of individual traders in losses, net ₹1,05,603 crore) and the September 2024 study (93 percent in losses across FY22 to FY24, over ₹1.8 lakh crore), which frame the conduct the reform targets. sebi.gov.in
Related guides
Continue with what SEBI does, how to evaluate a trading academy, what is paper trading (which covers the same 30-day data rule from the learner's side), and why we will never be SEBI-registered.