Compliance whitepaper · v2.2

Educational Publisher Posture & Operational Controls

Canonical statement of Bharath Shiksha's operating posture under the SEBI January 2025 educational-publisher framework. Editorial guardrails, operational controls, Edge Terminal compliance posture, and self-audit matrix.

1. Executive summary

Bharath Shiksha operates as an educational publisher in technical analysis and trading-process discipline. Structurally absent: buy/sell calls, live signals, return claims, portfolio-management overlays, SEBI-registered IA or RA capacity.

Posture is enforced by operational controls — 30-day data lag on every example, weekly forbidden-language pattern scan, curriculum-team review of every public publication, disclaimer blocks on every page, quarterly public compliance report. Document reviewed quarterly and after material SEBI framework changes.

2. The SEBI January 2025 framework

In January 2025 SEBI issued a circular distinguishing investor education from investment advisory for the digital-content economy. The two categories:

Investment advisory (regulated, requires registration)

• Personalised advice on what to buy, sell, or hold in specific securities.
• Real-time signals or alerts directing clients to act on specific securities at specific times.
• Performance claims, accuracy statistics, or return projections backed by track records.
• Portfolio construction or rebalancing services delivered to identifiable clients.
• Research-analyst output on specific securities offered as advice.

Activities of this kind require SEBI registration as an Investment Adviser (under SEBI IA Regulations 2013) or Research Analyst (under SEBI RA Regulations 2014), with capital adequacy, qualification, dispute-resolution, and audit obligations.

Investor education (permitted without IA/RA registration)

• Teaching frameworks, methodologies, and concepts in technical analysis, risk management, and quantitative methods.
• Analysis of historical data with the benefit of hindsight, with at least 30-day data lag, anonymised, and framed as illustration of methodology.
• Curriculum delivery via written, video, cohort, or interactive formats.
• Tutor channels that answer methodology questions, not specific-security questions.
• Tools and calculators that compute generic outputs from user inputs without prescribing actions.

One-sentence boundary: educational publishing teaches how to think; investment advisory tells what to do. Bharath Shiksha sits on the educational-publishing side.

3. What we do

3.1 The structured curriculum

The Bharath Shiksha curriculum spans six stages: Foundation (Stage 1), Systematic (Stage 2), Professional (Stage 3), Mastery I — Quantitative (Stage 4), Mastery II — Systems Architect (Stage 5), and Mastery III — Institutional Elite (Stage 6). Across the six stages we cover technical analysis from the first candlestick to the operational discipline of an institutional trading desk.

Each stage delivers a printed curriculum book, video lessons, structured exercises, gate quizzes, a trade-journal template, weekly review rituals, a tutor channel for methodology questions, and (cohort-mode only) live discussion threads with peer accountability.

3.2 The methodology encyclopedia

The encyclopedia documents 1,308 trading methodologies across 35 volumes in seven scanner categories: Bullish (200), Bearish (200), Intraday (200), Crossovers (200), Volume Profile (250), Range Breakout (150), Candlestick (108). Each methodology is described with formulae, parameters, signal criteria, common mistakes, anonymised historical examples with 30-day data lag, and recommended timeframes. Reference work, not a trading playbook.

3.3 Articles and lead-magnet content

Long-form articles cover Indian retail trading topics — F&O loss patterns, position sizing, behavioural biases, regime detection, intermarket relationships, taxation, broker selection, AIF Cat-III operations. Each article is reviewed before publication for compliance posture and re-scanned automatically every Tuesday by the compliance-scan cron.

3.4 Calculators

Browser-side calculators (risk of ruin, expectancy, position sizing, Kelly criterion, drawdown, compound returns, journal grader). All calculators run entirely in the browser with no network access for their core function — user inputs do not transit to our servers.

3.5 Cohort instruction

Cohort enrolment delivers the same curriculum content as solo path, plus structured weekly discussion threads, monthly live Q&A sessions with curriculum staff, and peer-pair journal review. Cohort sessions are educational; cohort threads are moderated for tip-sharing and other policy violations described in section 6.

3.6 The tutor channel

An asynchronous tutor channel where students can ask methodology questions and receive curriculum-staff responses within published SLAs. The tutor channel does not answer questions of the form "should I buy X" or "is now a good time to enter Y" — those are explicitly redirected, as documented in section 5.5.

3.7 Edge Terminal (the educational-analytics layer)

Edge Terminal is a six-module browser-based analytics layer (Visualiser, Watchlist, Backtester, Trade Journal, Risk-Literacy Dashboard, Methodology Library) that lets students apply the curriculum's methodologies to historical, anonymised, ≥30-day-lagged Indian market data. It is the practice room for the curriculum, not a market-intelligence product. Included with Bharath Shiksha enrolment and served at /terminal/ (public overview at /edge-terminal) since May 2026. Its compliance posture is documented in full in section 8.

The Methodology Library at /terminal/library/ catalogues 700 trading methodologies across all six Bharath Shiksha stages and nine scanner categories — distinct from the 1,308-methodology paid encyclopedia documented in section 3.2 (the encyclopedia is the depth-reference work; the Library is the operationally-codified subset used inside the practice tools). 70 of the 700 are mechanically codified into the Backtester rule engine; 81 render as Visualiser overlays. Every module ships with a sticky educational-tool banner, per-overlay and per-result disclaimers, and explicit ILLUSTRATIVE · HISTORICAL · DELAYED labelling. Edge Terminal is structurally incapable of producing buy/sell calls, real-time signals, or accuracy claims — the four V0-prototype features that could have crossed the SEBI advisory line (signal cards, AI-MATCH news-to-instrument mapper, prediction markets, real-time data feeds) were explicitly rejected as a moat decision and are not implemented.

4. What we do not do

The following activities are structurally outside Bharath Shiksha. Operational controls prevent these from being added:

The platform contains no payment surface for any of the listed activities. No "subscribe to signals" SKU, no advisory tier, no upsell to any SEBI-registered service.

5. Editorial guardrails

The operational rules every writer, editor, instructor, moderator, and AI tutor follows. Full version: /compliance/02-editorial-guardrails.md.

5.1 The 30-day data lag rule

Every chart, price reference, named-security illustration, or specific-event mention in published content must reference data at least 30 calendar days old at the time of publication. The rule applies to articles, videos, cohort sessions, encyclopedia methodology examples, and AI-tutor responses. The 30-day lag prevents any educational illustration from operating as a real-time recommendation.

5.2 Anonymisation

Specific-security references in trade examples are anonymised by default. When a real ticker is used (for pedagogical clarity), it is framed as an example of methodology applied historically — never as a present recommendation.

5.3 Forbidden language patterns

The following patterns are prohibited in any public-facing content. The list is enforced by the weekly automated `compliance-scan` cron and by manual review at publication time.

5.4 Pre-publication compliance review

Every public publication — article, video script, encyclopedia volume, marketing copy, email — passes a compliance review before going live. The review checks:

• Educational framing throughout, no imperative trade directions.
• Compliance disclaimer present where required.
• 30-day data lag honoured.
• No forbidden patterns from section 5.3.
• Performance language audited (no implicit accuracy or return claims).
• Citations and historical references properly contextualised.

5.5 The compliance-scan cron

A scheduled function runs every Tuesday at 08:30 IST against the live deployed site. It scans all HTML for the forbidden patterns in section 5.3 plus an allowlist of pages that intentionally reference forbidden language for educational purposes (e.g., the article titled "Why Bharath Shiksha will never be SEBI-registered" deliberately quotes regulatory language). Any new violation triggers a Postmark email to the curriculum team and a written entry in the public quarterly compliance report.

6. Community moderation

6.1 The cohort thread

Cohort discussion threads are educational forums for students to discuss methodology, share trade-journal observations on historical data, and ask curriculum-staff questions. They are explicitly not tip-sharing channels. The following rules are enforced:

• No real-time market predictions or recommendations. Posts of the form "X is breaking out, who else is in?" are removed and the poster warned. Repeat violations end cohort participation per the refund policy.
• No performance bragging. Posts advertising specific returns achieved by individual students are removed. Generic discussion of methodology results in R-multiples for educational illustration is permitted.
• No commercial solicitation. Cohort threads cannot be used to promote any external service, including SEBI-registered or unregistered.
• Civil discussion. Personal attacks, harassment, and abusive language end participation.

6.2 Tutor channel response policy

The tutor channel is staffed by curriculum-team members with explicit response policies:

• Methodology questions are answered. "How do I compute expectancy on this dataset?" or "Why does the regime filter exclude this period?" — answered.
• Specific-security questions are redirected. "Should I enter Reliance now?" or "Is HDFC at this price a good buy?" — politely declined; pointed at SEBI-registered RAs/IAs for that question; offered to discuss the methodology that would frame the question.
• Personal portfolio questions are redirected. "I have ₹X — how should I deploy it?" — politely declined; pointed at SEBI-registered IAs.

7. Operational controls

7.1 Pre-trade exercise framework

The Foundation curriculum's pre-trade checklist is an exercise the student fills out for hypothetical or paper-trading scenarios. It is not a service we operate against the student's real positions. The framework teaches the student to ask the questions; we do not answer them on the student's behalf.

7.2 Stage 5 algorithmic curriculum

Stage 5 (Mastery II) covers live deployment of student-built algorithmic systems against student-owned broker APIs. The curriculum content covers SEBI's January 2025 algo-trading circular requirements, kill-switch design, monitoring, and audit logging. Bharath Shiksha does not host or operate any student's algorithm; the deployment is to the student's own infrastructure.

7.3 Stage 6 AIF curriculum

Stage 6 (Mastery III) covers AIF Category III operations — fund structure, capital raising, the SEBI AIF Regulations 2012 framework, IA/RA registration walkthrough — as a curriculum subject for students whose intended path is fund management. We do not manage AIFs, do not assist students in raising capital, and do not facilitate any registration on the student's behalf. Students who wish to pursue AIF operations engage qualified legal and compliance advisers separately.

7.4 The Razorpay payment flow

All payments flow through Razorpay (PCI-DSS compliant). We never see card numbers, CVV, or stored payment instruments. Payment data is held by Razorpay; we receive only the transaction confirmation, amount, and method type.

7.5 Identity and access

Student access is gated through Netlify Identity (passwords hashed). Stage access is provisioned via the Razorpay webhook. Account credentials are the student's responsibility; sharing is grounds for termination per the Acceptable Use section of the Terms of Service.

8. Edge Terminal — educational-analytics layer (Q2 2026)

Edge Terminal is the educational-analytics layer of Bharath Shiksha, included with enrolment and served at /terminal/ (public overview at /edge-terminal) since May 2026. It is a browser-based six-module practice environment that lets students apply curriculum methodologies to historical and ≥30-day-lagged Indian market data. The terminal exists for one purpose: to make the curriculum interactive without crossing the SEBI educational-vs-advisory boundary.

This section documents the compliance posture of Edge Terminal in full: what each module does, why each is educational rather than advisory, the four V0-prototype features explicitly rejected as a moat decision, the data sources and processors, the retention windows, and the conditions under which a future revision of this section would be triggered. The full product specification is documented at EDGE_TERMINAL_V2_SPEC.md; the five-role compliance advisory that catalysed the moat decisions is documented at EDGE_TERMINAL_ROUNDTABLE.md; the build reports are at EDGE_TERMINAL_BUILD_REPORT.md and EDGE_TERMINAL_PHASE2_BUILD_REPORT.md.

8.1 The six modules

Module 01 — Methodology Visualiser

Loads any of 50 anonymised or large-cap Indian instruments (broad indices, sector indices, NIFTY 50 large-caps) on daily / weekly / monthly historical OHLC, and auto-draws methodology overlays from the curriculum: EMAs (20/50/200), support and resistance, Fibonacci retracement, VWAP with bands, candlestick patterns (twelve named rules), market structure (HH/HL/LH/LL with Break-of-Structure detection), RSI with divergence, and Volume Profile with point-of-control. Each overlay opens a side-panel card explaining the methodology in two paragraphs of curriculum-grounded educational copy, with a deep link back to the curriculum lesson that teaches it. Education-first: the Visualiser teaches the student to see a methodology applied historically. It does not produce trade entries, exits, or directional calls. Implementation: /terminal/index.html, /terminal/visualiser.js, /terminal/overlays.js, /terminal/methodology-content.js.

Module 02 — Watchlist

A personal browser-local list of up to 25 instruments the student is studying. Each row shows ticker, name, last close, 1-day / 5-day / 30-day deltas, 52-week high and low, and an editable 240-character note. CSV export supported. Pure utility. No alerts (alerts would be tantamount to entry signals), no ranking, no "your watchlist is bullish" framing, no auto-generated commentary. Data persists in browser localStorage; nothing transits to our servers. Implementation: /terminal/watchlist.html, /terminal/watchlist.js.

Module 03 — Backtester

Twelve curriculum methodologies codified as mechanical entry-stop-target rules, runnable against five-plus years of historical data on any instrument in the universe. The student selects methodology, instrument, position-sizing rule (0.5% / 1% / 2% fractional), R-multiple target, maximum holding period, and a realistic transaction-cost stack (FY-26 NSE retail brokerage + STT + GST + slippage). The engine walks the data bar-by-bar with next-bar-open entry to prevent look-ahead bias, then renders eight key performance indicators, an equity curve, a drawdown profile, an R-multiple histogram, a monthly returns heatmap, and a full sortable trade log with CSV export. Every panel carries an ILLUSTRATIVE · HISTORICAL label and a past-performance disclaimer block. Implementation: /terminal/backtester.html, /terminal/backtester.js, /terminal/backtester-methodologies.js.

Module 04 — Trade Journal

A personal post-execution journal. The student logs their own trades after they have closed them — ticker as free text (the journal does not validate, execute, or route), direction, entry, stop, exit, methodology used (chosen from a preset list of 18 plus a free-text "other"), thesis, and notes. R-multiple is computed from the student's inputs. Aggregate dashboard shows eight KPIs (total trades, win rate, average R, average win R, average loss R, expectancy, profit factor, cumulative R) and a behavioural-insights engine that links observed patterns — loss-aversion skew, profit-factor below 1.2, methodology concentration, rolling-window edge stability — to specific curriculum modules. CSV export supported. Browser-local localStorage only at V1; cross-device sync via Netlify Identity is a Phase 2.5 follow-up, disclosed in section 8.6. Implementation: /terminal/trade-journal.html, /terminal/trade-journal.js.

Module 05 — Risk-Literacy Dashboard

An educational view of macro market conditions on a ≥30-day data lag. Six indicator cards (India VIX, NIFTY 50, BANK NIFTY, USD/INR, MCX Gold, MCX Crude) each show last close and 1-day / 5-day / 30-day deltas accompanied by three-to-five-sentence curriculum-grounded explainers of what each indicator measures and what it does not tell a student. A nine-sector breadth heatmap surfaces 30-day moves across NSE sector indices, framed in language about regime context, not directional implication. A twenty-session FII / DII flow chart (deterministic-synthetic at V1, clearly flagged as illustrative) is paired with educational copy on the difference between context and signal. Every indicator carries a DELAYED label; every panel disclaims past patterns as no guarantee of future behaviour. Implementation: /terminal/risk-literacy.html, /terminal/risk-literacy.js.

8.2 The methodology library — the curriculum-Backtester moat

The Bharath Shiksha methodology encyclopedia documents 1,308 trading methodologies across 35 volumes in seven scanner categories — Intraday (200), Candlestick (108), Range Breakout (150), Bullish (200), Bearish (200), Crossovers (200), Volume Profile (250). The full catalogue is reference work: formulae, parameters, signal criteria, common mistakes, anonymised historical examples with 30-day lag, recommended timeframes.

Of the 1,308 catalogued methodologies, approximately 50 to 100 are mechanically codifiable as Backtester rules — i.e., they reduce to a deterministic entry signal, a deterministic stop placement, and a deterministic target or exit condition. The remaining ~1,200 methodologies are multi-factor frameworks, composite scorers, or qualitative reads that are surfaced as documentation in the curriculum and the Visualiser, but are not directly executable as Backtester strategies. At V1 launch (May 2026), twelve methodologies are codified as Backtester rules; the codified library is intended to grow toward ~50-100 over subsequent quarterly releases, gated to the stage that the methodology belongs to (a Stage 2 methodology is unlocked only for students enrolled in Stage 2 or above; the implementation is in /terminal/backtester-methodologies.js with a stage tag on each rule).

Three compliance consequences follow from this architecture:

• Backtester outputs are historical illustrations, not strategy recommendations. The student is testing a methodology they are learning, on data they could have studied themselves with sufficient time. The terminal accelerates that study; it does not replace the student's judgement on whether to use the methodology in a real account. The student's separate decision to deploy any methodology to a live account is theirs alone and falls outside the scope of any Bharath Shiksha service.
• The Backtester does not screen or scan the live market. The student selects an instrument; the engine then runs the chosen methodology against that instrument's historical bars and returns the historical outcome. There is no "show me which instruments today are setting up this methodology" feature, and there will not be one — that surface would constitute a screener with directional output, which the SEBI January 2025 framework treats as research-analyst output.
• No accuracy claims, no aggregate statistics published. Backtester results live in the student's session only. We do not publish "the Bullish Engulfing rule produced an expectancy of X over the last decade." Aggregate performance claims of that kind would invite the inference that we are operating signal systems with stated accuracy, which we are not.

8.3 The four V0-prototype features explicitly rejected (the moat decision)

The Edge Terminal V0 prototype, brainstormed in CodeSandbox fn9t7k in early May 2026, contained four features which a five-role advisory roundtable (Legal & Compliance, CEO, CFO, CMO, CRO) reviewed on 2026-05-11 and unanimously recommended for elimination before any public deployment. The full roundtable record is preserved at EDGE_TERMINAL_ROUNDTABLE.md. The decisions are documented here because the discipline of what we choose not to build is the strongest evidence of the educational positioning. Each of the four would have crossed a regulatory line; each was therefore not built.

The four rejections are not a temporary scope cut. They are a permanent moat decision. The terminal's value proposition is precisely the discipline that distinguishes an academy from a signal channel: the student practises methodology on historical data, develops judgement, and bears the responsibility for their own positions. Each of the four rejected features would have shortcut that discipline, and would have created the operational temptation — and the regulatory obligation — to deliver advice. The educational-publisher posture and the four rejections are inseparable.

8.4 Compliance posture, surface by surface

Every Edge Terminal page implements the following compliance surfaces. The implementation is verified at the HTML level across /terminal/index.html, /terminal/watchlist.html, /terminal/backtester.html, /terminal/trade-journal.html, and /terminal/risk-literacy.html, with corresponding logic in the JavaScript modules.

8.5 Data sources and processors

Edge Terminal adds no new third-party processors beyond Bharath Shiksha's existing list (Netlify for hosting and serverless compute, Postmark for email, Razorpay for payments). The data pipeline is deliberately lean and lives entirely inside Netlify infrastructure already disclosed in the Privacy Policy v2.

Specifically: Edge Terminal does not introduce any AI/ML inference provider, any third-party analytics service beyond what is already disclosed in Privacy v2, any market-data vendor beyond NSE Bhavcopy, any payment processor beyond Razorpay, or any cloud-storage provider beyond Netlify. The terminal is, deliberately, a thin layer over the existing Bharath Shiksha infrastructure.

8.6 Retention windows for Edge Terminal data

The lean storage profile is intentional: by holding Watchlist and Trade-Journal data only in the browser at V1, the academy minimises the personal-data surface under the Digital Personal Data Protection Act 2023 and reduces the load on Data Principal rights workflows. The trade-off is the loss of cross-device sync, which is a deliberate Phase 2.5 deferral.

8.7 What is on the Edge Terminal Phase 2.5 / Phase 3 roadmap

The following items are planned but not built at V1 release. Each is documented here because adding any of them will require a corresponding amendment to this whitepaper and to Privacy Policy v3.

• Cross-device sync for Watchlist and Trade Journal (Phase 2.5). Optional Netlify Identity-gated mirror of localStorage to Netlify Blobs, so a logged-in student can use the same Watchlist and Trade Journal across their laptop and phone. Will require disclosure of Netlify Identity as a processor (already disclosed for the course-access flow), expanded retention disclosure (Trade-Journal entries would move from indefinite-browser-local to a defined server-side window), and DPDPA Data Principal rights (export and deletion) wired to the new store. Estimated build: ~4 hours; whitepaper amendment alongside Privacy v3.
• Site-wide nav integration. Adding the Terminal link to the primary navigation across all 140+ Bharath Shiksha site pages. Compliance-neutral change; no whitepaper amendment required.
• Real EOD FII/DII flow data. The Risk-Literacy FII/DII chart is deterministic-synthetic at V1 (clearly flagged). Phase 2.5 may add an EOD scrape of the publicly-published NSE FII/DII CSV. Compliance-neutral change; the framing remains "context, not signal" and the data remains end-of-day.
• Expansion of the codified Backtester library from 12 toward ~50-100 methodologies. Each addition follows the same compliance pattern as the existing 12: mechanical entry-stop-target rule, ILLUSTRATIVE · HISTORICAL labelling, past-performance disclaimer, stage-gating. Compliance-neutral change; no whitepaper amendment required per addition, but the section 8.2 figure will be updated when the library crosses the 50- and 100-rule milestones.

8.8 What will NEVER be added to Edge Terminal

The following are explicitly outside the scope of Edge Terminal and the Bharath Shiksha operating model. Adding any one of them would require, at minimum, a fresh five-role advisory review of the kind documented at EDGE_TERMINAL_ROUNDTABLE.md, a fresh legal opinion, and a full rewrite of this section. The position is restated here because clarity on what we will not build is the strongest evidence of the educational positioning.

• Real-time NSE / BSE / MCX data feeds. Not planned. The data-licensing exposure and the regulatory ambiguity are well-documented. The educational utility is zero.
• AI-generated buy/sell signals, signal cards, target prices, or confidence scores. Not planned. This is the V0 surface that was rejected; the rejection is permanent.
• AI-driven news-to-instrument mappers or recommendation engines. Not planned. Same rationale as signal cards.
• Prediction markets or probability boards on financial outcomes. Not planned. Both the SEBI angle (unregistered forecasting publication) and the Public Gambling Act 1867 + state-gaming-law angle make this an existential risk; we are not in this category and will not be.
• Live screeners with directional output. A "today's setups" screen that lists instruments meeting any methodology's entry condition would convert Edge Terminal from an educational practice room into a signal channel. Not planned.
• Cohort-wide live signal feeds. A push-notification stream that alerts cohort students to "today's setup" is structurally identical to a tip channel. Not planned. Cohort threads remain asynchronous educational discussion governed by section 6.
• Portfolio-level personalised allocation advice. Not planned. The Trade Journal computes statistics on what the student has done; it does not advise on what the student should do next.
• ML-driven personalisation of the curriculum. Not planned at V1. If introduced, it would surface curriculum content based on the student's logged learning patterns — not market positions — and would carry its own DPDPA disclosures.

9. Refunds, grievance, privacy

Three companion documents:

• Refund Policy — full terms in the linked document.
• Grievance Redressal Policy — internal escalation path plus reference to external avenues (National Consumer Helpline, Karnataka State Consumer Commission, SEBI SCORES where applicable).
• Privacy Policy v2 — DPDP Act 2023 compliant: data classification, retention windows, third-party processors, Data Principal rights.

10. Quarterly public reporting

At the end of each quarter, Bharath Shiksha publishes a public compliance report covering the previous three months. The report is generated by the `compliance-report-quarterly` scheduled function and published at /compliance/q<n>-<year>-report.pdf within ten working days of quarter-end.

Each quarterly report contains:

• Aggregate enrolment numbers (no individual identifying data).
• Refund volume and reason histogram.
• Grievance ticket count, SLA performance, and resolution-pattern summary.
• Compliance-scan results: any violations detected and the corrective action taken.
• Editorial review summary: pieces published, pieces revised pre-publication, allowlist additions.
• Material policy changes during the quarter.

The most recent report is available at /compliance/q1-2026-report.pdf.

11. AI tutor disclosure

The Bharath Shiksha tutor channel uses an AI assistant (system-prompted via the rules in /compliance/04-ai-tutor-system-prompt.md) to provide first-line responses on methodology questions. The AI tutor:

• Answers methodology questions. Concept explanations, definitional clarifications, walkthroughs of curriculum-content questions.
• Defers specific-security questions. Returns the same redirect language as a human tutor; will not answer "should I buy X."
• Defers personal portfolio questions. Will not advise on capital allocation.
• Cites curriculum content. Responses reference the lesson, volume, or article that supports the answer.
• Escalates to human staff. Questions that fall outside the AI's confidence band are routed to curriculum staff with documented SLAs.

Every AI tutor response carries a footer disclosing that the response is from an automated assistant and that the underlying curriculum is the canonical source.

12. Affiliate & testimonial compliance

12.1 Affiliate program

The affiliate program pays commissions for qualifying enrolments referred via tracked links. Affiliates are bound by:

• Mandatory disclosure of the affiliate relationship in every promotional post.
• Prohibition on return claims, accuracy claims, or any language contradicting our SEBI educational-publisher posture.
• Genuine recommendation requirement — cold-traffic arbitrage and undisclosed paid traffic are program violations.
• No self-referrals on stages the affiliate is not already enrolled in.
• Refunded enrolments reverse the commission for that referral.

Affiliates who violate the compliance posture are removed from the program without payout of accrued commissions.

12.2 Testimonials

Testimonial submissions are reviewed and published only when they:

• Describe the learning experience, not investment outcomes.
• Contain no return percentages, profit claims, or "guaranteed/sure-shot" language.
• Carry explicit consent for publication and identity attribution.
• Are honestly representative of the actual student experience.

Performance-claim testimonials are auto-rejected per the editorial guardrails. The rejection is structural, not editorial.

13. Self-audit matrix

The matrix below maps each operational practice to the regulation or framework it aligns with. It is the single page that answers the question "how do you stay on the right side of the line?"

14. How we differ from tip-channel operators

The Indian retail trading-content economy contains a category of operators who sell access to "tips," "signals," "calls," or "alerts" — often via Telegram, WhatsApp, or paid YouTube/Instagram channels — and who structurally cross the SEBI advisory line without registration. We are not in this category, and the differences are operational, not branding.

Differences are operational, not branding. Students who want tips are not the audience.

15. Why we will never become SEBI-registered

A reasonable question: if we operate in the trading-education space, why not register as an Investment Adviser or Research Analyst and provide advice within the regulated framework? The answer has three components:

1. Mandate alignment. Our mandate is education, not advice. Education compounds across thousands of students at low marginal cost; advice scales linearly with adviser-hours and is structurally constrained. A registered IA serving thousands of clients with personalised advice violates IA capacity norms; a registered IA serving education-quality content is operating outside the IA mandate. The two structures don't combine well.
2. Conflict-of-interest separation. An educational publisher has no positional incentive to direct a student toward any specific security or to time markets for them. The moment we register as an IA/RA, we acquire the operational temptation (and obligation) to deliver advice. Keeping the advisory and education functions separate organisations is the institutional norm globally.
3. Student protection. The single best protection a student of trading methodology has is a curriculum that explicitly does not tell them what to do. The student learns to think; the student bears the responsibility for their own positions. SEBI registration adds a regulated counterparty whose role is to advise; we believe the educational-publisher posture is structurally safer for serious students who intend to become competent traders rather than passive consumers of a signal feed.

The position is not an interim choice. We have no roadmap to register as an IA or RA. The educational-publisher posture is the durable product, and it is structurally simpler to maintain than to transition out of.

16. Forward-looking — what triggers a future update

This whitepaper is reviewed quarterly and after material framework changes. The following triggers will prompt a specific amendment to the document, even outside the quarterly cycle, because they touch the compliance perimeter directly. The list is exhaustive: anything not on it is a routine documentation update handled at the next quarterly review.

17. Version history