SEBI Research Analyst Social Media Compliance

SEBI Research Analyst Social Media Compliance. Social media has become a communication and marketing tool for SEBI-registered Research Analysts in India. Through platforms such as YouTube, Instagram, LinkedIn, Facebook, X, Telegram and WhatsApp, analysts can share market updates, educational content, research views, stock analysis, webinar information and details of subscription-based services. These platforms help analysts reach a wider audience, but they also increase the risk of misleading claims, incomplete disclosures and unverified recommendations.
For this reason, social media activity must be treated as regulated communication rather than casual online content. Depending on its wording and purpose, a post may be considered a research report, recommendation, public appearance, client communication or advertisement. Research Analysts must therefore follow the SEBI (Research Analysts) Regulations, 2014, the Advertisement Code and supervisory guidelines. Proper compliance includes displaying registration details, disclosing conflicts of interest, avoiding guaranteed returns or exaggerated claims, maintaining supporting research records and obtaining required approvals before publishing promotional material.
Understanding Social Media Compliance for Research Analysts
Social media compliance for a Research Analyst can generally be understood at three levels. The first level relates to the disclosure of the Research Analyst’s registered name and SEBI registration number. These details help investors identify whether the person or entity publishing securities-related content is actually registered with SEBI. The second level relates to research recommendations and public appearances. Whenever a Research Analyst discusses or recommends a particular security, the recommendation should be supported by proper research and relevant conflicts of interest must be disclosed. The analyst must not publish unsupported market calls merely for gaining views, followers or subscribers.
The third level relates to advertising and promotion. Whenever social media content promotes a paid research service, subscription package, premium group, webinar, membership plan or commercial service, the content may be treated as an advertisement and must comply with the applicable Advertisement Code. A single social media post may fall under more than one category. For example, a YouTube video that recommends a stock and simultaneously asks viewers to purchase a premium subscription would contain both a research recommendation and an advertisement. The Research Analyst would therefore need to comply with the requirements applicable to research communications as well as promotional content.
Meaning and Scope of Social Media Platforms
For compliance purposes, social media should be understood broadly. It includes public platforms such as YouTube, Instagram, LinkedIn, Facebook, X, Threads and Reddit. It also includes messaging platforms and closed communities such as Telegram channels, WhatsApp groups, private subscriber groups and paid discussion forums. A Research Analyst cannot avoid regulatory responsibility by claiming that a recommendation was shared only in a private group.
If the communication relates to securities, investments or research services, the applicable SEBI requirements may still apply regardless of whether the group is publicly accessible or restricted to paying members. The form of the content is also not important. Compliance requirements may apply to videos, reels, stories, live sessions, text posts, captions, podcasts, webinars, voice notes, infographics, community posts and forwarded messages. The substance and purpose of the communication are more important than the format in which it is published.
Mandatory Disclosure of Registered Name and Registration Number
A SEBI-registered Research Analyst should prominently disclose the registered name and SEBI registration number on every social media profile used for securities-market-related activities. This disclosure helps investors verify the identity and regulatory status of the person or entity publishing the content. The registered name should be the legal or registered name appearing in SEBI and supervisory body records. A brand name, social media username or abbreviated name should not be used as a substitute for the registered name.
For example, the profile may state:
ABC Research Services Private Limited
 SEBI Registered Research Analyst
 SEBI Registration No.: INH0000XXXXX
The information should be displayed clearly on the main profile page, biography, description or other prominent section. It should not be hidden in an unrelated website link or placed in a manner that makes it difficult for users to locate.
Disclosure at the Beginning of Social Media Content
In addition to profile-level disclosure, the registered name and registration number should also be disclosed at the beginning of securities-market-related content. For a video, reel or short-form clip, the details may be shown on the opening screen. The analyst may also verbally state the registered name and registration number at the start of the video. The disclosure should remain visible for a sufficient period so that viewers can read and understand it.
For a text post, caption or messaging-platform communication, the registration details should appear near the beginning of the message. Placing them only at the bottom after long promotional content or multiple hashtags may not provide adequate visibility. The purpose of this requirement is to ensure that investors know from the beginning that the content is being issued by a regulated Research Analyst. It also helps distinguish registered professionals from unregistered tip providers and social media influencers.
Entities Holding Multiple SEBI Registrations
Some entities may be registered with SEBI in more than one capacity. For example, an entity may operate as a Research Analyst, Investment Adviser, Stock Broker or Portfolio Manager. In such cases, the entity should clearly identify the capacity in which a particular social media communication is being issued. If the post relates to research recommendations, the Research Analyst registration details should be disclosed.
Registration obtained for another activity should not be presented as though it authorises research services. The social media profile may provide a link to a page containing all relevant SEBI registrations. However, the registration applicable to the particular content should still be prominently identified at the beginning of the post or video.
When Social Media Content Becomes an Advertisement
Not every social media post published by a Research Analyst is automatically an advertisement. A genuine research report, market analysis or educational communication may not be considered promotional merely because it is published online. However, content may become an advertisement when it directly or indirectly promotes the Research Analyst’s products, services, subscriptions, commercial standing or ability to generate investment results.
For example, a post announcing a paid research subscription, premium Telegram channel, investment webinar, membership plan or discounted service package is likely to be treated as an advertisement. Similarly, content that repeatedly highlights the supposed success, expertise or superiority of the analyst for attracting clients may also fall within the advertisement basis. A research report can also become promotional if it contains repeated calls to purchase a subscription, join a paid group or contact the analyst for personalised services. Research Analysts should therefore carefully separate objective research from marketing communication.
Information Required in Social Media Advertisements
An advertisement issued by or on behalf of a Research Analyst should contain accurate and complete information about the registered entity. This generally includes the registered name, SEBI registration number, registered office address, trade name and corporate identity number, wherever applicable. The information must be presented clearly and should not be false, exaggerated, incomplete or ambiguous.
The Research Analyst should not create an impression that SEBI has approved, guaranteed or endorsed the quality of the analyst’s recommendations. The wording of the advertisement should be simple enough for an ordinary investor to understand. Technical language should not be used in a manner that hides risks or exaggerates the benefits of the service.
Mandatory Market-Risk Warning
Advertisements relating to research services should prominently include the prescribed market-risk warning:
“Investment in securities market are subject to market risks. Read all the related documents carefully before investing.” The wording of the prescribed warning should not be unnecessarily altered. It should be displayed in a readable size and should not be hidden among lengthy disclaimers or placed against a background that makes it difficult to read.
In video advertisements, the warning should generally be shown visually and communicated through a clear voice-over. It should remain on screen for a reasonable period so that viewers can understand it. Where the advertisement is issued in Hindi or another regional language, the warning may also be translated accurately into that language. However, the translated version should communicate the same meaning and should not dilute the nature of the risk.
Use of Website Links in Short Social Media Posts
Social media platforms sometimes impose character limits or restrict the amount of information that can be placed in a post. In such cases, a Research Analyst may provide a link to the official website containing complete regulatory disclosures, terms and conditions and risk warnings. However, the link should be used only as an additional source of information.
Important identity disclosures such as the registered name and SEBI registration number should still be directly visible on the profile and at the beginning of the relevant social media content. The website should be updated and accessible. A broken link, outdated disclosure page or link leading only to promotional material may not satisfy the objective of transparent disclosure.
Securities Displayed Only for Illustration
Sometimes a Research Analyst may display the name of a security only to explain a general concept. For example, a company’s share price chart may be used to explain technical analysis, valuation or market volatility without recommending the security.
In such cases, the analyst may include the disclaimer:
“The securities quoted are for illustration only and are not recommendatory.” However, merely inserting this disclaimer will not convert an actual recommendation into educational content. If the post includes a clear buy, sell or hold opinion, price target, entry point or future-return expectation, it may still be treated as a recommendation. Regulators will examine the actual substance of the communication rather than relying only on the disclaimer used by the Research Analyst.
Registration Does Not Guarantee Performance
SEBI registration confirms that the Research Analyst is registered to provide regulated research services, subject to compliance with the prescribed requirements. It does not guarantee that every recommendation will be profitable or accurate. Research Analysts should therefore clearly communicate that SEBI registration and NISM certification do not assure performance or returns.
They should not use the registration number as a promotional badge suggesting that SEBI endorses their recommendations. The SEBI logo should not be used in a social media advertisement in a manner that implies regulatory approval or partnership. The registration details should be stated factually without exaggerating their significance.
Prohibited and Misleading Claims on Social Media
Research Analysts are required to maintain fairness, honesty and transparency in all communications. A statement may be misleading not only because of what it expressly says but also because of what it implies or intentionally fails to disclose. An analyst should therefore review captions, thumbnails, video titles, advertisements, testimonials and promotional messages carefully before publishing them.
Assured, Guaranteed or Risk-Free Returns
A Research Analyst must not promise assured returns, fixed profits, minimum returns or risk-free investment outcomes. The securities market is inherently exposed to price movements, economic conditions, company-specific developments and other risks. Expressions such as “guaranteed profit,” “sure-shot call,” “no-loss strategy,” “fixed monthly income,” “100% target achievement” or “capital protection guaranteed” should not be used. The prohibition also applies to indirect assurances. For example, repeatedly stating that subscribers always make profits or that losses will be completely recovered may create the same misleading impression as an express guarantee.
Percentage Accuracy and Target-Based Claims
Claims regarding the percentage accuracy of recommendations should be avoided. Statements such as “95% accurate calls,” “90% success rate” or “every target achieved” may mislead investors into believing that the analyst’s future recommendations are almost certain to succeed. A disclaimer stating that market investments are risky may not cure an advertisement that is primarily built around an exaggerated accuracy claim. Research Analysts should also avoid offering services until a particular return or target is achieved. Such offers may suggest that the analyst can control market outcomes or guarantee a specific financial result.
Past-Performance Claims
Research Analysts should not use past performance as a promotional tool in advertisements. Social media posts displaying previous successful calls, profit screenshots, target-achievement cards or monthly return reports may create a misleading impression.
Such content often highlights only successful recommendations while ignoring losses, withdrawn calls, price movements that did not meet the target or recommendations that remained open. Even where past figures are genuine, their selective presentation may influence investors unfairly. A statement that past performance does not guarantee future results may not automatically make prohibited promotional content acceptable.
Superlative and Ranking Claims
Research Analysts should not describe themselves as the “best,” “number one,” “top-rated,” “most trusted” or “leading” analyst unless the claim is based on an independently verifiable and legally acceptable basis. Self-created awards, paid rankings or promotional titles should not be presented as independent recognition.
Such claims can mislead investors about the analyst’s standing, expertise or regulatory approval. Where an independent organisation has genuinely granted an award, the Research Analyst may mention the award factually. However, the name of the awarding organisation, year and nature of the award should be clearly disclosed.
Misleading Client Testimonials
Client testimonials should be used with extreme caution. Testimonials claiming that a client earned a particular profit, recovered previous losses or achieved regular returns may effectively become past-performance or assured-return claims. Screenshots of trading accounts, profit-and-loss statements, payment messages or client chats should not be used to create an impression of guaranteed success. A testimonial should also not be fabricated, edited or presented without proper consent. Even genuine testimonials may create compliance concerns if they contain prohibited return claims.
Claims of Free Services
A service should be described as free only when it is genuinely provided without any condition, hidden payment or obligation. For example, a recommendation should not be advertised as free when users are required to purchase another service, open a trading account, provide referrals or pay a membership fee before accessing it. The material terms and conditions of any offer should be disclosed clearly. Words such as “free,” “complimentary” or “zero cost” should not be used where additional charges or conditions apply.
Games, Contests and Promotional Schemes
Research Analysts should avoid organising competitions, games, leagues, lucky draws or promotional schemes that encourage investors to subscribe, trade more frequently or purchase research services in exchange for gifts or rewards. Such promotional activities may encourage investment decisions based on prizes rather than research quality or suitability. They may also create an aggressive sales environment inconsistent with investor protection principles.
Social Media Recommendations and Public Appearances
Whenever a Research Analyst gives an opinion or recommendation regarding a particular security through social media, the communication may be treated as a research recommendation or public appearance. YouTube live sessions, interviews, webinars, podcasts, television appearances, Telegram calls and social media discussions may all fall within this category depending on their content. The analyst should ensure that every recommendation is supported by reasonable research and that the viewers receive sufficient information to understand the basis, risks and conflicts connected with the recommendation.
Disclosure of Financial Interests and Conflicts
A Research Analyst must disclose material conflicts of interest that may affect the independence of the recommendation. For example, the analyst may need to disclose whether the Research Analyst, research entity, associates or relatives have a financial interest in the subject company. The analyst may also need to disclose substantial ownership in the securities of the company or any other material relationship.
Other relevant disclosures may include whether the analyst or entity received compensation from the subject company, provided investment-banking or brokerage services, participated in a public offering or acted as a market maker. These disclosures should be presented prominently. They should not be hidden in a lengthy description or placed on a separate page that viewers are unlikely to open.
Research Must Be Supported by Data and Analysis
A Research Analyst should not publish a buy, sell or hold recommendation merely based on personal opinion, rumours or social media trends. The recommendation should be supported by a documented research report containing the relevant data, assumptions, methodology, valuation, financial analysis, risks and reasons for arriving at the recommendation.
The analyst should preserve the underlying research even where the final social media post is short. For example, a 30-second video recommendation should still be backed by a detailed internal research report. The supporting data should be obtained from reliable sources and should be reviewed for accuracy. Material assumptions and risks should be explained so that the recommendation is not presented as a certainty.
Trading Restrictions Around Research Recommendations
Research Analysts and specified connected persons may be subject to restrictions on trading in securities that are covered in their research. These restrictions are intended to prevent analysts from trading ahead of their recommendations or benefiting from price movements caused by their own publications.
Before publishing a recommendation, the entity should review whether the analyst, employee, associate or other covered person has traded in the security during the restricted period. The Research Analyst should maintain an internal dealing policy, pre-clearance procedure and record of personal trades. Trading contrary to a published recommendation may create additional conflict-of-interest concerns.
Collaborations With Finfluencers and Unregistered Persons
Research Analysts frequently collaborate with social media creators, financial educators, influencers, affiliates and marketing agencies. Such arrangements require careful regulatory review. A registered Research Analyst should not directly or indirectly associate with an unregistered person who provides securities-specific advice or recommendations without regulatory permission.
The restriction may apply to paid promotions, referral agreements, revenue-sharing arrangements, joint webinars, co-branded videos, client introductions and other commercial collaborations. An individual cannot be treated as a financial educator merely because the content is labelled educational. If the person gives stock-specific recommendations, future price predictions, entry and exit levels or return claims, the activity may amount to regulated advice or research.
Before entering into any collaboration, the Research Analyst should review the influencer’s previous content, registration status, business model, claims, advertisements and related channels. The written agreement should clearly restrict the influencer from making unauthorised recommendations, guaranteed-return claims or misleading statements on behalf of the Research Analyst.
Approval of Social Media Advertisements
Promotional social media content should be reviewed through the applicable internal and supervisory approval process before publication. The compliance officer should first determine whether the communication is purely educational, a research recommendation, a public appearance, an advertisement or a combination of these categories.
Where the content qualifies as an advertisement, the required approval should be obtained from the appropriate supervisory body or authority before publication, wherever such approval is mandated. The final approved version should not be changed after approval without further review. Even minor changes to the headline, thumbnail, return claim, risk warning or call-to-action may alter the compliance position of the advertisement.
Record-Keeping Requirements
Research Analysts should preserve copies of all social media advertisements and related approvals for the prescribed period. The records should include the final creative, video, caption, script, thumbnail, voice-over, publication date, platform name, approval communication and website link. Screenshots should also be preserved to show how the advertisement appeared to the public. This is important because posts may later be edited, deleted or removed by the platform.
Research records supporting recommendations should be maintained separately. These records may include financial data, valuation models, research notes, source documents, risk analysis and conflict-of-interest disclosures. A proper archive helps the Research Analyst demonstrate that the published content was supported by research and complied with the applicable disclosure requirements at the time of publication.
Internal Social Media Compliance Structure
A Research Analyst should establish a written social media policy covering employees, directors, analysts, marketing personnel, affiliates and agents. The policy should define who is authorised to operate official social media accounts and who can approve research and promotional content. Standard templates should be developed for registration disclosures, risk warnings, conflict disclosures and educational disclaimers.
The compliance team should maintain a content-classification process. Every proposed communication should be classified as educational content, research content, advertisement, public appearance or general corporate communication. A pre-publication checklist should verify the accuracy of the content, supporting research, registration details, conflict disclosures, risk warnings, trading restrictions and required approvals. Periodic audits should also cover profile biographies, pinned posts, old advertisements, automated messages, link-in-bio pages, closed subscriber groups and employee-controlled accounts used for business purposes.
Suggested Pre-Publication Checklist
Before publishing securities-market-related content, the Research Analyst should verify that the correct registered name and SEBI registration number are clearly displayed. The analyst should confirm whether the content contains a recommendation and whether a proper research report supports it. All financial interests, ownership positions, compensation arrangements and other material conflicts should be disclosed wherever applicable.
The content should be reviewed to ensure that it does not promise assured returns, claim excessive accuracy, use selective profit screenshots or refer to past performance for promotional purposes. Where the communication promotes a service, the required risk warning, identity details and approval should be included. The personal trading records of analysts and other covered persons should also be checked before the recommendation is published. Finally, the approved content and supporting records should be securely archived for future inspection and compliance review.
Penalties of Social Media Non-Compliance
Failure to comply with SEBI requirements may expose the Research Analyst to regulatory inspection, warning, directions, monetary penalties, suspension of registration or cancellation of registration depending on the nature and seriousness of the violation. SEBI may examine not only the final post but also the overall conduct of the analyst. This may include trading records, subscription receipts, research reports, client communications, promotional claims and collaborations with influencers.
Deleting a social media post after receiving a complaint does not necessarily eliminate liability. Screenshots, subscriber records and platform data may still be available. Research Analysts should therefore treat every social media communication as a formal regulated communication rather than a casual online conversation.
Conclusion
SEBI Research Analyst social media compliance is much broader than inserting a general disclaimer at the end of a post. It requires proper identification of the registered entity, transparent disclosure of conflicts, research-backed recommendations, responsible promotional language and systematic record-keeping. Research Analysts should avoid guaranteed-return claims, excessive accuracy statements, selective profit screenshots, misleading testimonials and collaborations with unregistered tip providers.
A strong internal review process should be established so that every post, video, webinar, advertisement and closed-group communication is examined before publication. By adopting a compliance-first approach, Research Analysts can use social media effectively while protecting investors, maintaining professional credibility and reducing the risk of regulatory action.
Frequently Asked Questions
Q1. Is mentioning the SEBI registration number in the profile sufficient?
Ans. Mentioning the registration number only in the profile may not be sufficient. The registered name and registration number should also be prominently disclosed at the beginning of every relevant securities-market-related post or video.
Q2. Do the rules apply to private Telegram and WhatsApp groups?
Ans. Yes. Securities-related communications shared through closed groups, paid channels or private messaging communities may also be subject to the applicable Research Analyst regulations and disclosure requirements.
Q3. Is every research recommendation considered an advertisement?
Ans. No. A genuine research recommendation supported by proper analysis is not automatically an advertisement. However, where the recommendation also promotes a paid service, subscription or commercial product, the promotional portion may attract the Advertisement Code.
Q4. Can a Research Analyst post screenshots of previous successful recommendations?
Ans. Using previous successful calls, profit screenshots or target-achievement posts for attracting clients may amount to prohibited past-performance advertising and may mislead investors.
Q5. Can an analyst claim that recommendations are 90% accurate?
Ans. Percentage-accuracy claims should be avoided because they may create an unrealistic expectation of future performance. A general risk disclaimer may not make such a claim compliant.
Q6. Can a Research Analyst promise recovery of previous investment losses?
Ans. No. A Research Analyst should not promise to recover losses or assure a particular return. Market outcomes cannot be guaranteed.
Q7. Can a registered Research Analyst work with a financial influencer?
Ans. A collaboration may be possible only after proper due diligence and compliance review. The influencer should not provide unauthorised securities advice, stock-specific recommendations or guaranteed-return claims.
Q8. Are educational videos subject to disclosure requirements?
Ans. Where educational content relates to the securities market and is issued through the official account of a Research Analyst, the registered identity and registration number should be prominently disclosed. If the video discusses a specific security, additional recommendation and conflict disclosures may also apply.
Q9. Is a disclaimer enough to protect misleading content?
Ans. No. A disclaimer cannot correct content that is fundamentally false, exaggerated or prohibited. The overall message, headline, visual presentation and call-to-action will be considered.
Q10. How long should social media records be preserved?
Ans. Advertisements and supporting records should be preserved for the period prescribed under the applicable SEBI requirements. As a sound compliance practice, the Research Analyst should retain the published content, approval, research basis, disclosures and screenshots for at least the required regulatory period.

Social media has become a communication and marketing tool for SEBI-registered Research Analysts in India. Through platforms such as YouTube, Instagram, LinkedIn, Facebook, X, Telegram and WhatsApp, analysts can share market updates, educational content, research views, stock analysis, webinar information and details of subscription-based services. These platforms help analysts reach a wider audience, but they also increase the risk of misleading claims, incomplete disclosures and unverified recommendations.

For this reason, social media activity must be treated as regulated communication rather than casual online content. Depending on its wording and purpose, a post may be considered a research report, recommendation, public appearance, client communication or advertisement. Research Analysts must therefore follow the SEBI (Research Analysts) Regulations, 2014, the Advertisement Code and supervisory guidelines. Proper compliance includes displaying registration details, disclosing conflicts of interest, avoiding guaranteed returns or exaggerated claims, maintaining supporting research records and obtaining required approvals before publishing promotional material.

Understanding Social Media Compliance for Research Analysts

Social media compliance for a Research Analyst can generally be understood at three levels. The first level relates to the disclosure of the Research Analyst’s registered name and SEBI registration number. These details help investors identify whether the person or entity publishing securities-related content is actually registered with SEBI. The second level relates to research recommendations and public appearances. Whenever a Research Analyst discusses or recommends a particular security, the recommendation should be supported by proper research and relevant conflicts of interest must be disclosed. The analyst must not publish unsupported market calls merely for gaining views, followers or subscribers.

The third level relates to advertising and promotion. Whenever social media content promotes a paid research service, subscription package, premium group, webinar, membership plan or commercial service, the content may be treated as an advertisement and must comply with the applicable Advertisement Code. A single social media post may fall under more than one category. For example, a YouTube video that recommends a stock and simultaneously asks viewers to purchase a premium subscription would contain both a research recommendation and an advertisement. The Research Analyst would therefore need to comply with the requirements applicable to research communications as well as promotional content.

Meaning and Scope of Social Media Platforms

For compliance purposes, social media should be understood broadly. It includes public platforms such as YouTube, Instagram, LinkedIn, Facebook, X, Threads and Reddit. It also includes messaging platforms and closed communities such as Telegram channels, WhatsApp groups, private subscriber groups and paid discussion forums. A Research Analyst cannot avoid regulatory responsibility by claiming that a recommendation was shared only in a private group.

If the communication relates to securities, investments or research services, the applicable SEBI requirements may still apply regardless of whether the group is publicly accessible or restricted to paying members. The form of the content is also not important. Compliance requirements may apply to videos, reels, stories, live sessions, text posts, captions, podcasts, webinars, voice notes, infographics, community posts and forwarded messages. The substance and purpose of the communication are more important than the format in which it is published.

Mandatory Disclosure of Registered Name and Registration Number

A SEBI-registered Research Analyst should prominently disclose the registered name and SEBI registration number on every social media profile used for securities-market-related activities. This disclosure helps investors verify the identity and regulatory status of the person or entity publishing the content. The registered name should be the legal or registered name appearing in SEBI and supervisory body records. A brand name, social media username or abbreviated name should not be used as a substitute for the registered name.

For example, the profile may state:

ABC Research Services Private Limited

SEBI Registered Research Analyst

SEBI Registration No.: INH0000XXXXX

The information should be displayed clearly on the main profile page, biography, description or other prominent section. It should not be hidden in an unrelated website link or placed in a manner that makes it difficult for users to locate.

Disclosure at the Beginning of Social Media Content

In addition to profile-level disclosure, the registered name and registration number should also be disclosed at the beginning of securities-market-related content. For a video, reel or short-form clip, the details may be shown on the opening screen. The analyst may also verbally state the registered name and registration number at the start of the video. The disclosure should remain visible for a sufficient period so that viewers can read and understand it.

For a text post, caption or messaging-platform communication, the registration details should appear near the beginning of the message. Placing them only at the bottom after long promotional content or multiple hashtags may not provide adequate visibility. The purpose of this requirement is to ensure that investors know from the beginning that the content is being issued by a regulated Research Analyst. It also helps distinguish registered professionals from unregistered tip providers and social media influencers.

Entities Holding Multiple SEBI Registrations

Some entities may be registered with SEBI in more than one capacity. For example, an entity may operate as a Research Analyst, Investment Adviser, Stock Broker or Portfolio Manager. In such cases, the entity should clearly identify the capacity in which a particular social media communication is being issued. If the post relates to research recommendations, the Research Analyst registration details should be disclosed.

Registration obtained for another activity should not be presented as though it authorises research services. The social media profile may provide a link to a page containing all relevant SEBI registrations. However, the registration applicable to the particular content should still be prominently identified at the beginning of the post or video.

When Social Media Content Becomes an Advertisement

Not every social media post published by a Research Analyst is automatically an advertisement. A genuine research report, market analysis or educational communication may not be considered promotional merely because it is published online. However, content may become an advertisement when it directly or indirectly promotes the Research Analyst’s products, services, subscriptions, commercial standing or ability to generate investment results.

For example, a post announcing a paid research subscription, premium Telegram channel, investment webinar, membership plan or discounted service package is likely to be treated as an advertisement. Similarly, content that repeatedly highlights the supposed success, expertise or superiority of the analyst for attracting clients may also fall within the advertisement basis. A research report can also become promotional if it contains repeated calls to purchase a subscription, join a paid group or contact the analyst for personalised services. Research Analysts should therefore carefully separate objective research from marketing communication.

Information Required in Social Media Advertisements

An advertisement issued by or on behalf of a Research Analyst should contain accurate and complete information about the registered entity. This generally includes the registered name, SEBI registration number, registered office address, trade name and corporate identity number, wherever applicable. The information must be presented clearly and should not be false, exaggerated, incomplete or ambiguous.

The Research Analyst should not create an impression that SEBI has approved, guaranteed or endorsed the quality of the analyst’s recommendations. The wording of the advertisement should be simple enough for an ordinary investor to understand. Technical language should not be used in a manner that hides risks or exaggerates the benefits of the service.

Mandatory Market-Risk Warning

Advertisements relating to research services should prominently include the prescribed market-risk warning:

“Investment in securities market are subject to market risks. Read all the related documents carefully before investing.” The wording of the prescribed warning should not be unnecessarily altered. It should be displayed in a readable size and should not be hidden among lengthy disclaimers or placed against a background that makes it difficult to read.

In video advertisements, the warning should generally be shown visually and communicated through a clear voice-over. It should remain on screen for a reasonable period so that viewers can understand it. Where the advertisement is issued in Hindi or another regional language, the warning may also be translated accurately into that language. However, the translated version should communicate the same meaning and should not dilute the nature of the risk.

Use of Website Links in Short Social Media Posts

Social media platforms sometimes impose character limits or restrict the amount of information that can be placed in a post. In such cases, a Research Analyst may provide a link to the official website containing complete regulatory disclosures, terms and conditions and risk warnings. However, the link should be used only as an additional source of information.

Important identity disclosures such as the registered name and SEBI registration number should still be directly visible on the profile and at the beginning of the relevant social media content. The website should be updated and accessible. A broken link, outdated disclosure page or link leading only to promotional material may not satisfy the objective of transparent disclosure.

Securities Displayed Only for Illustration

Sometimes a Research Analyst may display the name of a security only to explain a general concept. For example, a company’s share price chart may be used to explain technical analysis, valuation or market volatility without recommending the security.

In such cases, the analyst may include the disclaimer:

“The securities quoted are for illustration only and are not recommendatory.” However, merely inserting this disclaimer will not convert an actual recommendation into educational content. If the post includes a clear buy, sell or hold opinion, price target, entry point or future-return expectation, it may still be treated as a recommendation. Regulators will examine the actual substance of the communication rather than relying only on the disclaimer used by the Research Analyst.

Registration Does Not Guarantee Performance

SEBI registration confirms that the Research Analyst is registered to provide regulated research services, subject to compliance with the prescribed requirements. It does not guarantee that every recommendation will be profitable or accurate. Research Analysts should therefore clearly communicate that SEBI registration and NISM certification do not assure performance or returns.

They should not use the registration number as a promotional badge suggesting that SEBI endorses their recommendations. The SEBI logo should not be used in a social media advertisement in a manner that implies regulatory approval or partnership. The registration details should be stated factually without exaggerating their significance.

Prohibited and Misleading Claims on Social Media

Research Analysts are required to maintain fairness, honesty and transparency in all communications. A statement may be misleading not only because of what it expressly says but also because of what it implies or intentionally fails to disclose. An analyst should therefore review captions, thumbnails, video titles, advertisements, testimonials and promotional messages carefully before publishing them.

Assured, Guaranteed or Risk-Free Returns

A Research Analyst must not promise assured returns, fixed profits, minimum returns or risk-free investment outcomes. The securities market is inherently exposed to price movements, economic conditions, company-specific developments and other risks. Expressions such as “guaranteed profit,” “sure-shot call,” “no-loss strategy,” “fixed monthly income,” “100% target achievement” or “capital protection guaranteed” should not be used. The prohibition also applies to indirect assurances. For example, repeatedly stating that subscribers always make profits or that losses will be completely recovered may create the same misleading impression as an express guarantee.

Percentage Accuracy and Target-Based Claims

Claims regarding the percentage accuracy of recommendations should be avoided. Statements such as “95% accurate calls,” “90% success rate” or “every target achieved” may mislead investors into believing that the analyst’s future recommendations are almost certain to succeed. A disclaimer stating that market investments are risky may not cure an advertisement that is primarily built around an exaggerated accuracy claim. Research Analysts should also avoid offering services until a particular return or target is achieved. Such offers may suggest that the analyst can control market outcomes or guarantee a specific financial result.

Past-Performance Claims

Research Analysts should not use past performance as a promotional tool in advertisements. Social media posts displaying previous successful calls, profit screenshots, target-achievement cards or monthly return reports may create a misleading impression.

Such content often highlights only successful recommendations while ignoring losses, withdrawn calls, price movements that did not meet the target or recommendations that remained open. Even where past figures are genuine, their selective presentation may influence investors unfairly. A statement that past performance does not guarantee future results may not automatically make prohibited promotional content acceptable.

Superlative and Ranking Claims

Research Analysts should not describe themselves as the “best,” “number one,” “top-rated,” “most trusted” or “leading” analyst unless the claim is based on an independently verifiable and legally acceptable basis. Self-created awards, paid rankings or promotional titles should not be presented as independent recognition.

Such claims can mislead investors about the analyst’s standing, expertise or regulatory approval. Where an independent organisation has genuinely granted an award, the Research Analyst may mention the award factually. However, the name of the awarding organisation, year and nature of the award should be clearly disclosed.

Misleading Client Testimonials

Client testimonials should be used with extreme caution. Testimonials claiming that a client earned a particular profit, recovered previous losses or achieved regular returns may effectively become past-performance or assured-return claims. Screenshots of trading accounts, profit-and-loss statements, payment messages or client chats should not be used to create an impression of guaranteed success. A testimonial should also not be fabricated, edited or presented without proper consent. Even genuine testimonials may create compliance concerns if they contain prohibited return claims.

Claims of Free Services

A service should be described as free only when it is genuinely provided without any condition, hidden payment or obligation. For example, a recommendation should not be advertised as free when users are required to purchase another service, open a trading account, provide referrals or pay a membership fee before accessing it. The material terms and conditions of any offer should be disclosed clearly. Words such as “free,” “complimentary” or “zero cost” should not be used where additional charges or conditions apply.

Games, Contests and Promotional Schemes

Research Analysts should avoid organising competitions, games, leagues, lucky draws or promotional schemes that encourage investors to subscribe, trade more frequently or purchase research services in exchange for gifts or rewards. Such promotional activities may encourage investment decisions based on prizes rather than research quality or suitability. They may also create an aggressive sales environment inconsistent with investor protection principles.

Social Media Recommendations and Public Appearances

Whenever a Research Analyst gives an opinion or recommendation regarding a particular security through social media, the communication may be treated as a research recommendation or public appearance. YouTube live sessions, interviews, webinars, podcasts, television appearances, Telegram calls and social media discussions may all fall within this category depending on their content. The analyst should ensure that every recommendation is supported by reasonable research and that the viewers receive sufficient information to understand the basis, risks and conflicts connected with the recommendation.

Disclosure of Financial Interests and Conflicts

A Research Analyst must disclose material conflicts of interest that may affect the independence of the recommendation. For example, the analyst may need to disclose whether the Research Analyst, research entity, associates or relatives have a financial interest in the subject company. The analyst may also need to disclose substantial ownership in the securities of the company or any other material relationship.

Other relevant disclosures may include whether the analyst or entity received compensation from the subject company, provided investment-banking or brokerage services, participated in a public offering or acted as a market maker. These disclosures should be presented prominently. They should not be hidden in a lengthy description or placed on a separate page that viewers are unlikely to open.

Research Must Be Supported by Data and Analysis

A Research Analyst should not publish a buy, sell or hold recommendation merely based on personal opinion, rumours or social media trends. The recommendation should be supported by a documented research report containing the relevant data, assumptions, methodology, valuation, financial analysis, risks and reasons for arriving at the recommendation.

The analyst should preserve the underlying research even where the final social media post is short. For example, a 30-second video recommendation should still be backed by a detailed internal research report. The supporting data should be obtained from reliable sources and should be reviewed for accuracy. Material assumptions and risks should be explained so that the recommendation is not presented as a certainty.

Trading Restrictions Around Research Recommendations

Research Analysts and specified connected persons may be subject to restrictions on trading in securities that are covered in their research. These restrictions are intended to prevent analysts from trading ahead of their recommendations or benefiting from price movements caused by their own publications.

Before publishing a recommendation, the entity should review whether the analyst, employee, associate or other covered person has traded in the security during the restricted period. The Research Analyst should maintain an internal dealing policy, pre-clearance procedure and record of personal trades. Trading contrary to a published recommendation may create additional conflict-of-interest concerns.

Collaborations With Finfluencers and Unregistered Persons

Research Analysts frequently collaborate with social media creators, financial educators, influencers, affiliates and marketing agencies. Such arrangements require careful regulatory review. A registered Research Analyst should not directly or indirectly associate with an unregistered person who provides securities-specific advice or recommendations without regulatory permission.

The restriction may apply to paid promotions, referral agreements, revenue-sharing arrangements, joint webinars, co-branded videos, client introductions and other commercial collaborations. An individual cannot be treated as a financial educator merely because the content is labelled educational. If the person gives stock-specific recommendations, future price predictions, entry and exit levels or return claims, the activity may amount to regulated advice or research.

Before entering into any collaboration, the Research Analyst should review the influencer’s previous content, registration status, business model, claims, advertisements and related channels. The written agreement should clearly restrict the influencer from making unauthorised recommendations, guaranteed-return claims or misleading statements on behalf of the Research Analyst.

Approval of Social Media Advertisements

Promotional social media content should be reviewed through the applicable internal and supervisory approval process before publication. The compliance officer should first determine whether the communication is purely educational, a research recommendation, a public appearance, an advertisement or a combination of these categories.

Where the content qualifies as an advertisement, the required approval should be obtained from the appropriate supervisory body or authority before publication, wherever such approval is mandated. The final approved version should not be changed after approval without further review. Even minor changes to the headline, thumbnail, return claim, risk warning or call-to-action may alter the compliance position of the advertisement.

Record-Keeping Requirements

Research Analysts should preserve copies of all social media advertisements and related approvals for the prescribed period. The records should include the final creative, video, caption, script, thumbnail, voice-over, publication date, platform name, approval communication and website link. Screenshots should also be preserved to show how the advertisement appeared to the public. This is important because posts may later be edited, deleted or removed by the platform.

Research records supporting recommendations should be maintained separately. These records may include financial data, valuation models, research notes, source documents, risk analysis and conflict-of-interest disclosures. A proper archive helps the Research Analyst demonstrate that the published content was supported by research and complied with the applicable disclosure requirements at the time of publication.

Internal Social Media Compliance Structure

A Research Analyst should establish a written social media policy covering employees, directors, analysts, marketing personnel, affiliates and agents. The policy should define who is authorised to operate official social media accounts and who can approve research and promotional content. Standard templates should be developed for registration disclosures, risk warnings, conflict disclosures and educational disclaimers.

The compliance team should maintain a content-classification process. Every proposed communication should be classified as educational content, research content, advertisement, public appearance or general corporate communication. A pre-publication checklist should verify the accuracy of the content, supporting research, registration details, conflict disclosures, risk warnings, trading restrictions and required approvals. Periodic audits should also cover profile biographies, pinned posts, old advertisements, automated messages, link-in-bio pages, closed subscriber groups and employee-controlled accounts used for business purposes.

Suggested Pre-Publication Checklist

Before publishing securities-market-related content, the Research Analyst should verify that the correct registered name and SEBI registration number are clearly displayed. The analyst should confirm whether the content contains a recommendation and whether a proper research report supports it. All financial interests, ownership positions, compensation arrangements and other material conflicts should be disclosed wherever applicable.

The content should be reviewed to ensure that it does not promise assured returns, claim excessive accuracy, use selective profit screenshots or refer to past performance for promotional purposes. Where the communication promotes a service, the required risk warning, identity details and approval should be included. The personal trading records of analysts and other covered persons should also be checked before the recommendation is published. Finally, the approved content and supporting records should be securely archived for future inspection and compliance review.

Penalties of Social Media Non-Compliance

Failure to comply with SEBI requirements may expose the Research Analyst to regulatory inspection, warning, directions, monetary penalties, suspension of registration or cancellation of registration depending on the nature and seriousness of the violation. SEBI may examine not only the final post but also the overall conduct of the analyst. This may include trading records, subscription receipts, research reports, client communications, promotional claims and collaborations with influencers.

Deleting a social media post after receiving a complaint does not necessarily eliminate liability. Screenshots, subscriber records and platform data may still be available. Research Analysts should therefore treat every social media communication as a formal regulated communication rather than a casual online conversation.

Conclusion

SEBI Research Analyst social media compliance is much broader than inserting a general disclaimer at the end of a post. It requires proper identification of the registered entity, transparent disclosure of conflicts, research-backed recommendations, responsible promotional language and systematic record-keeping. Research Analysts should avoid guaranteed-return claims, excessive accuracy statements, selective profit screenshots, misleading testimonials and collaborations with unregistered tip providers.

A strong internal review process should be established so that every post, video, webinar, advertisement and closed-group communication is examined before publication. By adopting a compliance-first approach, Research Analysts can use social media effectively while protecting investors, maintaining professional credibility and reducing the risk of regulatory action.

Frequently Asked Questions

Q1. Is mentioning the SEBI registration number in the profile sufficient?

Ans. Mentioning the registration number only in the profile may not be sufficient. The registered name and registration number should also be prominently disclosed at the beginning of every relevant securities-market-related post or video.

Q2. Do the rules apply to private Telegram and WhatsApp groups?

Ans. Yes. Securities-related communications shared through closed groups, paid channels or private messaging communities may also be subject to the applicable Research Analyst regulations and disclosure requirements.

Q3. Is every research recommendation considered an advertisement?

Ans. No. A genuine research recommendation supported by proper analysis is not automatically an advertisement. However, where the recommendation also promotes a paid service, subscription or commercial product, the promotional portion may attract the Advertisement Code.

Q4. Can a Research Analyst post screenshots of previous successful recommendations?

Ans. Using previous successful calls, profit screenshots or target-achievement posts for attracting clients may amount to prohibited past-performance advertising and may mislead investors.

Q5. Can an analyst claim that recommendations are 90% accurate?

Ans. Percentage-accuracy claims should be avoided because they may create an unrealistic expectation of future performance. A general risk disclaimer may not make such a claim compliant.

Q6. Can a Research Analyst promise recovery of previous investment losses?

Ans. No. A Research Analyst should not promise to recover losses or assure a particular return. Market outcomes cannot be guaranteed.

Q7. Can a registered Research Analyst work with a financial influencer?

Ans. A collaboration may be possible only after proper due diligence and compliance review. The influencer should not provide unauthorised securities advice, stock-specific recommendations or guaranteed-return claims.

Q8. Are educational videos subject to disclosure requirements?

Ans. Where educational content relates to the securities market and is issued through the official account of a Research Analyst, the registered identity and registration number should be prominently disclosed. If the video discusses a specific security, additional recommendation and conflict disclosures may also apply.

Q9. Is a disclaimer enough to protect misleading content?

Ans. No. A disclaimer cannot correct content that is fundamentally false, exaggerated or prohibited. The overall message, headline, visual presentation and call-to-action will be considered.

Q10. How long should social media records be preserved?

Ans. Advertisements and supporting records should be preserved for the period prescribed under the applicable SEBI requirements. As a sound compliance practice, the Research Analyst should retain the published content, approval, research basis, disclosures and screenshots for at least the required regulatory period.