The worst decline in a record is a draw, and a longer record has a deeper one by construction
The short answer
Maximum drawdown is the largest member of a set of declines, which makes it an extreme value statistic, and extremes grow with the size of the set. Simulating one unchanging process, the median worst decline runs 1.08 annual volatilities over a one year record and 3.55 over a ten year record, roughly tracking the square root of the length. The spread at any single length is wide: at three years the middle half alone runs 1.43 to 2.58. Two identical processes, one tracked for three years and one for ten, produce the verdict that the longer tracked one is riskier 86 per cent of the time. On the real Indian index, the same exposure reports a worst decline of 38.4 per cent from a 2013 start and 17.2 per cent from a 2021 start. The exposure did not change. The window did.
Every figure below is computed from a stated simulation or measured from a stated daily price series. None is quoted.
What the number actually is, and why that settles most of the argument
At every point in an equity curve, measure how far it sits below the highest level it has previously reached. That is the drawdown series, and it has one entry per day in the record. Maximum drawdown is a single number pulled out of it: the largest entry.
That sentence places the statistic in a specific family. It is not an average, a spread or a ratio. It is a maximum, and maxima behave unlike every other summary in common use. An average of more data is a better average. A maximum of more data is a larger maximum.
The consequence needs no assumption about markets. A maximum over ten years of a record includes every decline in the first three years of it, plus everything after. The largest member of a set cannot be smaller than the largest member of a subset. Extending a record can only hold the reported figure where it is or push it deeper. It can never pull it back. A longer record has a deeper maximum drawdown by construction.
One process, nothing changing, six record lengths
Remove every competing explanation: independent daily returns from one fixed distribution, no drift, no volatility clustering, no regime shift, nothing that could make one stretch genuinely riskier than another. Generate 20,000 runs of twenty years with a fixed seed and read the maximum drawdown at six checkpoints, in units of the process's own annual volatility.
| Years | 25th pc | Median | 75th pc | 90th pc | 95th pc |
|---|---|---|---|---|---|
| 1 | 0.79 | 1.08 | 1.46 | 1.89 | 2.17 |
| 2 | 1.15 | 1.55 | 2.09 | 2.70 | 3.10 |
| 3 | 1.43 | 1.92 | 2.58 | 3.34 | 3.81 |
| 5 | 1.87 | 2.49 | 3.37 | 4.33 | 4.95 |
| 10 | 2.67 | 3.55 | 4.78 | 6.14 | 7.01 |
| 20 | 3.82 | 5.08 | 6.78 | 8.71 | 9.95 |
The median goes from 1.08 annual volatilities at one year to 3.55 at ten and 5.08 at twenty, with nothing in the generating process differing between those rows. The growth has a shape, and it is the same one that governs the uncertainty of an average.
| Years | Median relative to one year, no drift | Square root of the length | Same, with drift |
|---|---|---|---|
| 1 | 1.00 | 1.00 | 1.00 |
| 2 | 1.43 | 1.41 | 1.35 |
| 3 | 1.78 | 1.73 | 1.61 |
| 5 | 2.31 | 2.24 | 1.96 |
| 10 | 3.30 | 3.16 | 2.50 |
| 20 | 4.72 | 4.47 | 3.13 |
The simulated column and the square root column sit close enough that the mechanism is not in doubt. Quadruple the record and the typical worst decline roughly doubles. To put one illustrative scale on it, at an annual volatility of 15 per cent those medians are declines of about 15 per cent over a year and 41 per cent over ten.
Width is the other half, and it is the half that gets forgotten
At any single length the answer is spread over a wide range, so one observed value is a draw rather than a reading. A three year record of this process lands between 1.43 and 2.58 annual volatilities across the middle half of runs, and reaches 3.81 at the ninety fifth percentile. Same process, same length, a spread of nearly three to one, and nothing in the number itself says where in that band it fell.
So neighbouring lengths overlap. The ninetieth percentile of a three year record, 3.34, sits well above the tenth percentile of a ten year record, 2.12, and a short record beats a long one outright 14 per cent of the time.
The single run above shows the nested version. Its worst decline within three years was one number; within ten it was 3.6 times deeper, arriving after year five. Across all 20,000 runs, the worst of the first three years failed to survive as the worst of the first ten in 91 per cent of them. At one year against ten it fails 99 per cent of the time.
Comparing two records of different lengths is not a comparison
Two strategies are placed side by side, one reports a shallower worst decline, and it is read as the safer one. That reading is available only if the records are the same length, and they almost never are. A newer fund has a shorter record, a strategy rebuilt after a rule change has a shorter record, and a backtest has whatever length the data somebody happened to hold had.
The simulation prices the error. Take two runs of the identical process, track one for three years and the other for ten, and compare the figures as though they were comparable. The ten year record is judged riskier 86 per cent of the time; at one year against five, 92 per cent. There is no difference between the processes. The comparison is measuring the window, with a strong and predictable bias against whichever record is longer.
That bias runs opposite to the one most people guard against. A short record hides risk, which is understood. It also wins the comparison, so the strategy with less history looks better on the risk measure precisely because there is less of it. A track record is penalised for existing.
The repair is complete and unglamorous. Truncate the longer record to the length of the shorter, measure both over that common window, and state the window. Anything else compares sample sizes in the costume of a risk comparison. The same discipline governs what a result is benchmarked against, where the alternative is a free choice and the choice decides the answer.
The same effect, measured on the real Indian record
In real data, where declines are not independent and volatility clusters, the effect is starker. What follows is measured on the daily close of the broad Indian equity index across 3,385 trading days, 2013-01-01 to 2026-09-18, read from the exchange's own daily index file.
| Record begins | Years | Reported maximum drawdown, per cent |
|---|---|---|
| 2013-01-01 | 13.7 | 38.4 |
| 2014-01-01 | 12.7 | 38.4 |
| 2015-01-01 | 11.7 | 38.4 |
| 2016-01-01 | 10.7 | 38.4 |
| 2017-01-02 | 9.7 | 38.4 |
| 2018-01-01 | 8.7 | 38.4 |
| 2019-01-01 | 7.7 | 38.4 |
| 2020-01-01 | 6.7 | 38.4 |
| 2021-01-01 | 5.7 | 17.2 |
| 2022-01-03 | 4.7 | 16.5 |
| 2023-01-02 | 3.7 | 15.8 |
| 2024-01-01 | 2.7 | 15.8 |
| 2025-01-01 | 1.7 | 15.2 |
8 of the 13 rows report exactly 38.4 per cent, because every one of them contains the same episode. The rest report between 15.2 and 17.2 per cent. The asset is identical in every row. A fund holding this exposure since 2021 would truthfully report 17.2 per cent and one holding precisely the same thing since 2013 would truthfully report 38.4 per cent, and a reader comparing them would conclude something about the managers that is an artefact of the launch dates.
Now the spread across records of equal length: each calendar year is a fresh one year record, with the reference peak reset each January.
Across 14 such years the deepest within year decline ranges from 4.1 per cent in 2017 to 38.4 per cent in 2020, a spread of 9.4 times, median 12.0 per cent. Any one of those figures, quoted alone as the risk of holding this exposure for a year, is one draw from that row presented as a property.
The point at which the number stops being a statistic at all
Rolling the window across the record exposes something sharper.
| Years | Windows | Shallowest | Median | Deepest | Share at the record maximum, per cent |
|---|---|---|---|---|---|
| 1 | 3,140 | 4.1 | 11.7 | 38.4 | 6 |
| 2 | 2,894 | 9.9 | 15.8 | 38.4 | 15 |
| 3 | 2,648 | 14.1 | 19.3 | 38.4 | 26 |
| 5 | 2,156 | 17.2 | 38.4 | 38.4 | 55 |
| 10 | 926 | 38.4 | 38.4 | 38.4 | 100 |
All 926 ten year windows in this record report the same number, 38.4 per cent, to the last decimal. So do 55 per cent of the five year windows. Over a long window the maximum drawdown of this record is not a summary of the record. It is the size of one episode, the fall from 2020-01-14 to 2020-03-23, restated once for every window long enough to contain it.
That is what an extreme value statistic degenerates into on a finite record: a sample size of one. The other 3,384 daily observations contributed nothing beyond establishing the peak it fell from. More history cannot make it more reliable, because history does not add information to a maximum. It adds opportunities for the maximum to be exceeded.
Which direction the bias runs, and by how much
The statistic is used to anticipate what a holding period will feel like, so the question is whether it misleads in a direction. Simulate a record, then the period that follows it from the same unchanged process, and count how often the future is worse than the past said. Here the process carries a positive drift, set so its annualised mean is 0.5 times its annualised volatility, stated as a parameter rather than claimed about any market.
| Record, then holding period | Holding period is deeper, per cent | Median depth relative to the record |
|---|---|---|
| 3 year record, then held 3 years | 49.5 | 1.00 |
| 3 year record, then held 5 years | 64.6 | 1.22 |
| 3 year record, then held 10 years | 80.7 | 1.56 |
| 5 year record, then held 10 years | 68.8 | 1.28 |
| 10 year record, then held 10 years | 50.1 | 1.00 |
The first and last rows are the instrument checking itself: when record and holding period are the same length and drawn from the same process, the probability that the second is deeper must be exactly one half by symmetry, and the simulation returns 49.5 per cent. That row is also the best case, and it is already uncomfortable. Even when the future is exactly as long as the record, the record's worst decline is beaten half the time. It is not a ceiling or a worst case. It is a median.
Every other row is worse, because holding periods are normally longer than the records used to justify them. A three year record followed by a ten year holding period is exceeded 81 per cent of the time, at typically 1.56 times the depth the record showed. As an estimate of what is coming, the observed maximum is too shallow, and it gets worse the longer you intend to stay. That is also why a small edge is hard to hold on to at all, the subject of how much data it takes to tell an edge from luck.
A real drift does not exempt a method from this
| Years | 25th pc | Median | 90th pc | 95th pc |
|---|---|---|---|---|
| 1 | 0.68 | 0.90 | 1.58 | 1.83 |
| 2 | 0.94 | 1.22 | 2.11 | 2.43 |
| 3 | 1.12 | 1.45 | 2.45 | 2.85 |
| 5 | 1.39 | 1.76 | 2.95 | 3.40 |
| 10 | 1.80 | 2.25 | 3.65 | 4.20 |
| 20 | 2.30 | 2.82 | 4.37 | 5.00 |
Drift helps. The ten year median falls from 3.55 annual volatilities to 2.25 and the growth rate flattens below the square root law, visible in the right hand column of the growth table. It still grows at every step, and the comparison error survives: two identical runs of this process, tracked for three years and for ten, still produce the verdict that the longer one is riskier 81 per cent of the time.
The reason is structural. Drift shortens the expected time to recover from a decline but puts no ceiling on how deep one can go, so the maximum keeps getting fresh chances to be exceeded for as long as the record runs. A better method has a shallower distribution of drawdowns. It does not have a stationary maximum, because no method does.
What survives the record length problem
Three summaries of the drawdown series do not collapse onto a single observation.
The distribution rather than its largest member. The series has one entry per day. Its median, upper quartile and ninety fifth percentile use all of them, and each converges as the record lengthens.
Time under water, as a share of the record. Time below a prior peak is the part of a decline people actually experience, and the share form of it is stable where the maximum is not.
| Years | Median share of days below a prior peak, per cent | 10th to 90th pc across windows |
|---|---|---|
| 1 | 86 | 74 to 95 |
| 2 | 87 | 82 to 93 |
| 3 | 88 | 85 to 92 |
| 5 | 89 | 86 to 91 |
| 10 | 89 | 89 to 90 |
On the real record it sits between 86 and 89 per cent at every window length from one year to ten, and the spread across windows narrows as the window grows, which is how a usable statistic behaves. Over the same lengths the measured maximum drawdown roughly tripled. One of these numbers is about the asset and the other is about your window.
The recovery question. Depth and duration rank episodes differently. The deepest episode here fell 38.4 per cent from 2020-01-14 to 2020-03-23, taking 48 trading days down and 158 to regain the old peak. The longest stretch below a prior peak ran 500 trading days, about 2.0 years, from 2015-03-04 to 2017-03-10, and was shallower. Falling hard and recovering in months is a different experience from drifting below a peak for two years, and maximum drawdown scores the first as the worse of the two.
| Years | Median | 90th pc | Median as a share of the record, per cent |
|---|---|---|---|
| 1 | 121 | 228 | 49 |
| 2 | 220 | 438 | 45 |
| 3 | 306 | 630 | 41 |
| 5 | 456 | 960 | 37 |
| 10 | 746 | 1,588 | 30 |
| 20 | 1,169 | 2,388 | 24 |
The absolute duration grows with the record while the share falls and steadies, the same contrast the real data shows. Wherever a quantity can be stated as a share of the record rather than a running total, it should be, because that is the form that stops the record length from doing the talking.
What India actually requires anyone to be told
By circular SEBI/HO/IMD/IMD-PoD-2/P/CIR/2025/6 of 17 January 2025, the Securities and Exchange Board of India made disclosure of a risk adjusted return measure compulsory for equity oriented mutual fund schemes for the first time. The measure is the Information Ratio, defined in the circular as the portfolio rate of return less the benchmark rate of return, divided by the standard deviation of that excess return, against the scheme's Tier 1 benchmark, with the standard deviation computed from daily return values. It must be published on the asset manager's website alongside performance every day, and the industry body must carry the same figures in a comparable, downloadable, machine readable format. The provisions came into force within three months of issuance.
The choice of statistic is the point. The risk term India mandated is a standard deviation, which uses every observation and settles down as the record lengthens, so two schemes with different histories can be compared without the histories deciding the answer. No drawdown figure appears in that circular, and none is required elsewhere in the mandated retail disclosure set. The stress test disclosures for certain fund categories report how long a portfolio would take to sell down, a liquidity exercise and not a drawdown measure either.
| Statistic | Observations it uses | As the record lengthens | Comparable across unequal records |
|---|---|---|---|
| Maximum drawdown | One, the single deepest | Grows without limit | No |
| Longest time under water | One episode | Grows without limit | No |
| Standard deviation of returns | All of them | Converges | Broadly, yes |
| Median or upper quartile drawdown | All of them | Converges | Broadly, yes |
| Share of days below a prior peak | All of them | Converges | Broadly, yes |
The two rows that rest on one observation are the two that must carry a record length attached every time they are quoted.
The tolerance you set, and the draw you get
The sequence is familiar. A method is tested over whatever history was available and reports a worst decline. The person sizes their position, or picks the product, against that figure: they could sit through that much and no more. The number has become a psychological contract.
Everything above says it was one draw from a wide distribution, over a window shorter than the one they are about to live through, and that it will be beaten 81 per cent of the time by a ten year hold. So the most likely single outcome is not that the method fails. It is that the method performs exactly as expected and the person still passes through a decline they had explicitly decided they would not tolerate, at which point the evidence in front of them is indistinguishable from evidence that the method has broken.
The repair is a change of habit. Set tolerance against the distribution of drawdowns over the horizon you intend to hold, not the single worst figure in a shorter record. Assume before committing that the deepest decline ahead is worse than the deepest already seen, because for any holding period longer than the test that is the probable case rather than the pessimistic one. And size the position so being wrong about the depth is survivable, which is the only part of this a person fully controls.
None of that needs better data or a cleverer statistic. It needs treating one number as what it is: the largest value in a list whose length somebody else chose.
Frequently asked questions
What does it mean to call maximum drawdown a sample statistic?
It is a property of the record you looked at, not of the thing that produced the record. The number is the largest member of a set of declines, and the set grows as the record grows. Two honest analysts measuring the same unchanged process over different windows get different answers, and neither is wrong.
Why does a longer record have a deeper maximum by construction?
A maximum over a longer stretch includes every decline the shorter stretch contained, plus more, and the largest member of a set cannot be smaller than the largest member of a subset. Extending a record can only hold the reported figure where it is or push it deeper.
How fast does it grow?
With no drift, the simulation here shows the median roughly tracking the square root of the record length, so quadrupling the record deepens the typical worst decline by about a factor of two. A positive drift slows the growth without stopping it, which matters because a good strategy is often assumed to be exempt and is not.
Is it valid to compare two strategies on maximum drawdown?
Only if the records are the same length, which they almost never are. Two identical simulated processes tracked for three years and for ten produce the verdict that the ten year one is riskier about 86 per cent of the time, purely from the difference in length. A comparison that does not fix the window is measuring the window.
Which way is the observed maximum biased?
Low, as an estimate of what the method can produce over a longer future, and the bias widens as the holding period runs past the record. A simulated three year record followed by ten years of holding is beaten about 81 per cent of the time, at roughly 1.56 times the depth. Over an equal length future the split is a coin flip, which is the best case rather than the usual one.
What should be used instead of the single worst number?
The distribution of declines rather than its largest member, the time spent below a prior peak as a share of the record, and how long recovery took. The first two are stable as the record lengthens. On the real index measured here, the share of days below a prior peak sits near 89 per cent whether the window is one year or ten, while the maximum triples.
Is the deepest decline also the longest one?
Not necessarily, and on the record measured here it was not. The deepest episode ran 206 trading days from peak to recovery. The longest stretch below a prior peak ran 500 trading days, about 2.0 years, and was shallower. Depth and duration rank episodes differently, which is one reason depth alone is a poor summary.
Does Indian regulation require a fund to disclose its maximum drawdown?
No. The risk adjusted return measure made compulsory for equity oriented mutual fund schemes by the SEBI circular of January 2025 is the Information Ratio: excess return over the Tier 1 benchmark divided by the standard deviation of that excess return, from daily returns, published daily. A standard deviation uses every observation. No drawdown figure appears in that circular, and none is required elsewhere in the mandated retail disclosure set.
If the number is this unreliable, why does everybody quote it?
Because it is the one risk statistic that corresponds to something a person actually lived through, which gives it an authority the arithmetic does not support. The fix is not to stop looking at it. It is to attach the record length every time it is quoted, treat it as one draw from a wide distribution, and refuse to compare two of them unless the windows match.
How these numbers were produced. Simulated figures: 20,000 runs of independent daily returns from one fixed distribution of standard deviation 1, from the PCG64 generator seeded at 20260919, over twenty years of 246 trading days each, with the running maximum drawdown recorded at six checkpoints. Two processes were run, one with zero drift and one with a per day mean set so the annualised mean is 0.5 times the annualised volatility. Drawdown is the distance of the cumulative return path below its running peak, reported in units of the process's own annual volatility, being the daily standard deviation times the square root of 246, so no volatility figure has to be assumed. The forward looking rows simulate a record and the period following it as two adjacent stretches of the same unchanged process, seeded at 20260920; as a check on the harness, the row where record and holding period are of equal length must return exactly fifty per cent by symmetry, and returns 49.5 per cent. All simulated figures are illustrative of the structure of the problem, not a measurement of or a prediction about any strategy or market. Measured figures: the daily closing level of the broad Indian equity index over 3,385 trading days, with maximum drawdown taken as the largest percentage fall from a running peak inside the stated window, and rolling windows using every available start date, so they overlap and are not independent observations. The file is the exchange's daily index close file for every session from 2013-01-01 to 2026-09-18 that its archive holds: 3,385 sessions, including fourteen weekend special sessions (budget days, muhurat trading and disaster-recovery drills), which are real sessions and are kept. The archive holds no file for twelve weekday sessions between 2013-10-09 and 2016-06-20, each found because the next file's own reported change does not match the previous close. A drawdown is read from closing levels, so no change is computed across a gap, and the eight missing sessions inside the longest stretch below a prior peak are counted in its length. The file for 2023-03-13 reports its change against the wrong prior session, and that column is used for nothing else here. Record lengths in years are calendar lengths. The one conversion from volatility units to a percentage uses 15 per cent annual volatility to make the scale concrete and is not a measurement of any index.
The position is stated as at September 2026. Disclosure requirements change and index records extend; confirm the current circular and recompute any measured figure for the period you care about before relying on it, and take advice on your own circumstances.
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