SEBI's new Common Advertisement Code: what changes for PMS marketing online

Until now, a PMS firm, a mutual fund and an investment adviser each followed a different set of advertising rules. That's ending. In October 2026, SEBI notified a single Common Advertisement Code for the entities it regulates. For a PMS firm's marketing team, it changes how ads are approved and spells out what they can't say.

This guide covers what the code says, when it starts and what to fix in your Google, Meta and LinkedIn campaigns before then.

The dates

• June 2026: SEBI published a consultation paper on a common code.
• 24 September 2026: SEBI's board approved it.
• 8 October 2026: SEBI notified it, as the SEBI (Intermediaries) (Second Amendment) Regulations, 2026. It was published in the Gazette the next day.
• About April 2027: the code takes effect on the 180th day after publication.

Until it takes effect, the current rules apply. For portfolio managers, those are in SEBI's Master Circular for Portfolio Managers of 16 July 2025. The code also adds that more detail, including how reporting will work, will come through SEBI circulars. Watch for those.

Who it covers

• portfolio managers;
• mutual funds and asset management companies;
• investment advisers;
• research analysts;
• stock brokers;
• depository participants;
• online bond platform providers.

SEBI can add more entities later. Each type of entity has a supervisory body that handles approvals and reporting. For portfolio managers, it's the Association of Portfolio Managers in India (APMI).

AIFs aren't covered. They're privately placed and can't make public offers, and SEBI said bringing them under a public advertising code may not be desirable.

Mutual fund distributors working for AMCs are covered indirectly, through the AMCs, and AMFI can add its own standards on top.

What counts as an advertisement

The definition is wide. It covers websites, social media, streaming and other digital channels, as well as print and outdoor. If it promotes your firm or a product, assume it's an ad: a Google search ad, a Meta carousel, a sponsored LinkedIn post, a YouTube pre-roll, a landing page or a WhatsApp broadcast.

Some things aren't treated as ads:

• genuine educational or investor-awareness content, if branding is minimal and there's no promotional call to action;
• client reports and responses to client queries;
• greetings, and similar non-promotional messages.

Educational content funded from investor-education budgets still has to be reported for monitoring.

Approval: less before, more after

This is the biggest practical change.

• Most ads don't need approval before they go out. Instead, they're reported after release. SEBI's board approved a window of three working days to upload them to the supervisory body's portal, which then reviews them. The exact process will be set by a SEBI circular.
• Ads with a celebrity still need prior approval. SEBI's board approved four working days for the supervisory body to decide.

"Celebrity" is defined widely. It includes:

• well-known public figures;
• influencers whose following on a single platform exceeds the threshold set by the Advertising Standards Council of India (ASCI);
• virtual influencers, meaning computer-generated characters with human-like traits. That catches AI avatars.

Even with approval, celebrity endorsements are allowed at the firm or brand level only. They can't make inducements or claims about a specific strategy, product or service. The cost of a celebrity endorsement can't be passed on to clients.

Your own people are an exception. Founders, promoters, directors and senior management appearing in their own firm's ads don't count as celebrities. A founder-led video doesn't need prior approval for that reason alone.

What you can't say

These carry straight into ad copy:

• No testimonials. Not in ads, in any form. SEBI considered and rejected industry requests to allow them.
• No guaranteed, risk-free or "indicative" returns.
• No implying past performance will repeat. Past performance can only be shown the way SEBI specifies.
• No vague return claims such as "high returns" or "high yield" without a basis. SEBI added this ban after the consultation.
• Ratings only from a PaRRVA. If you show a rating or ranking, it must come from a Past Risk and Return Verification Agency, under the conditions set.
• No dark patterns, as defined in the Central Consumer Protection Authority's 2023 guidelines: false urgency, hidden costs and the like.
• Examples carry a label. If an ad uses a stock or scheme as an example, it must say on the same page: "The securities or scheme(s) are quoted as an example and not as a recommendation."

Required risk disclaimers still apply. Where space is short, as in SMS, pop-ups and push notifications, you can link to the full disclosures on your website.

SEBI has been here before. In June 2025, it asked portfolio managers to remove ads with exaggerated claims. The code turns that pressure into written rules.

If someone else advertises in your name

The code also covers unauthorised ads by third parties using your name: fake WhatsApp groups, cloned pages, scam ads. When you learn of one, you must start action within seven days, tell your supervisory body, report the outcome and disclose the incident on your website. Someone on your team should be watching for these.

What to check in your campaigns now

You have until about April 2027, but campaigns built today will still be running then. Go through these:

1. Google Search ads. Remove return figures, "top performing" and "high return" phrases from headlines and descriptions, including in responsive ads, where Google mixes and matches the lines.
2. Landing pages. Check performance tables against SEBI's format for showing past performance. Remove client quotes and star ratings.
3. Meta and LinkedIn creatives. Check every image and video for testimonial-style quotes, return numbers and urgency tactics such as "Only 3 slots left".
4. Influencer and finfluencer plans. Anyone above ASCI's follower threshold now needs prior approval, and can only talk about your brand, not your strategy.
5. AI avatars. If you use an AI presenter in videos, treat it as a celebrity.
6. Educational content. Keep it educational: light branding and no "Invest now" button. A webinar that ends in a sales pitch is an ad.
7. Records. Set up a log of every ad, with its date and channel, so you can report within three working days once the portal is live.
8. Brand monitoring. Set up alerts for your firm's name on Meta's Ad Library, Telegram and WhatsApp, so you can act on fakes within seven days.

What this means for lead generation

None of this stops PMS firms generating leads online. It changes what persuades. Without return claims and testimonials, the ads that work explain the strategy simply, show who the founder is and why they invest the way they do, and make the next step easy: a call or a meeting, not a "guaranteed" number. That's how we run lead generation for PMS and AIF firms.

If you also advertise on Google, read our guide to G2RS and Google's Financial Services Verification first.