BFSI Marketing and Compliance FAQ: 80 Questions on SEBI, IRDAI and RBI Rules for Creative and Launch Teams
- What are SEBI’s rules for mutual fund and AMC advertising?
- How does NFO launch marketing work inside the regulatory window?
- What do AMFI guidelines require of distributor and IFA communication?
- What are IRDAI’s rules for insurance advertising and product launches?
- What are RBI’s rules for bank, NBFC and digital-lending advertising?
- How do disclaimers, risk-o-meters, past performance and testimonials work in financial creative?
- What are the rules on social media, influencers and finfluencers in BFSI?
- How does Yamm Labs build compliance into the creative process?
- Sources
Supporting reading: SEBI, IRDAI and RBI advertising rules: a creative team’s guide and the 30-day NFO launch marketing checklist.
What are SEBI’s rules for mutual fund and AMC advertising?
What counts as an advertisement under SEBI’s mutual fund rules? Does a LinkedIn post or a sales deck count?
Yes. The SEBI (Mutual Funds) Regulations, 2026 define an advertisement as any communication issued by or on behalf of the mutual fund or AMC that may influence the investment decision of any investor or prospective investor. That covers a LinkedIn post, a WhatsApp forward, a distributor deck, a fund manager interview and a hoarding equally. Treat every outward-facing asset as an advertisement for review purposes. The old 2000 SEBI guidelines said the same thing in different words, extending the code to TV interviews, seminars and sales literature.
What are the core principles of SEBI’s advertisement code for mutual funds?
SEBI’s advertisement code (Fifth Schedule of the 2026 Regulations) requires advertisements to be accurate, true, fair, clear, complete, unambiguous and concise. They must not be false, misleading, biased or deceptive, must not be based on assumptions or projections, and must not disguise the significance of any statement. Slogans must not be exaggerated or unrelated to the risk and return profile of the product. Content must be consistent with the SID, SAI and KIM, and must not discredit other advertisements or make unfair comparisons. Every creative decision should be tested against that list.
What is the exact standard warning for mutual fund advertisements, and can we shorten it?
The standard warning is: Mutual Fund investments are subject to market risks, read all scheme related documents carefully. SEBI’s advertisement code says no addition or deletion of words shall be made to it, and it must appear in legible fonts. In vernacular-language advertisements the warning must appear in that language. So no, you cannot shorten it, paraphrase it or bury it in a footnote. Design around the warning as a fixed element from the first layout, not as something dropped in at the end.
How long must the standard warning stay on screen in a TV or video ad?
SEBI’s advertisement code requires that in audio-visual advertisements the standard warning appears both as a visual and as a voice-over reiteration, and that both are audible and understandable. The code gives an example: the visual and the voice-over containing the fourteen words, running for at least five seconds, may be considered clear and understandable. Plan the edit so the warning gets its own uninterrupted five seconds with the voice-over synchronised, and do not compress it in short-form cut-downs for social.
Can we use a celebrity or a film star in a mutual fund advertisement in India?
No. SEBI’s advertisement code in the 2026 Regulations states plainly: no celebrities shall form part of the advertisement. This is stricter than the earlier position, under which celebrity endorsements were permitted only at industry level with SEBI’s prior approval. For a scheme or an AMC brand campaign, plan on real customers played by actors who are not celebrities, illustration, animation, or the fund’s own people. If your campaign strategy depends on a famous face, check the current position with your compliance officer before briefing.
Can we use testimonials, customer stories or a rated number one ranking in a mutual fund ad?
No. SEBI’s advertisement code says advertisements shall not contain any testimonials or any ranking based on any criteria. That rules out customer quotes, star-rating badges, award logos used as ranking claims, and best fund in category lines. What you can do is describe the fund’s stated investment approach, its category and its objective in plain terms consistent with the scheme documents. If a ranking or rating is genuinely material, ask your compliance officer whether it can be used outside advertising, for example in a regulatory disclosure.
Can a mutual fund ad show projected returns or a what your money could become illustration?
Not for a scheme. SEBI’s advertisement code prohibits statements based on assumptions or projections. AMFI’s Best Practices Circular 109 of November 2023 clarifies that no future returns can be shown even on an illustration basis, and permits numerical illustrations only in non-scheme material, using AMFI-prescribed benchmark CAGR figures, to explain compounding. SEBI had observed AMCs showing illustrations that led investors to expect fixed returns, with disclaimers in fine print. Keep any growth illustration generic, AMFI-compliant and away from scheme names.
Can our ad quote an indicative yield or say which stocks the fund will hold?
No. SEBI’s master circular for mutual funds says that mutual funds, AMCs and distributors shall not offer any indicative portfolio or indicative yield, and that no communication in this regard shall be issued in any manner. For close-ended debt schemes the SID may disclose the credit evaluation policy, excluded sectors, instrument types and allocation ranges, but not a portfolio or yield. Marketing copy that hints at what the fund will buy or what it will earn is off limits.
Can we say India’s most trusted AMC or best fund house in an advertisement?
Avoid it. SEBI’s advertisement code prohibits exaggerated or unwarranted slogans and any ranking based on any criteria. A superlative like most trusted or best is either an unverifiable slogan or an implied ranking, and either way it is likely to fail review. Replace the superlative with a verifiable fact: the year the AMC was set up, the number of schemes it manages, or its stated investment philosophy, each consistent with the SAI. Facts survive review; adjectives do not.
Who signs off a mutual fund advertisement, and does it have to be filed with SEBI?
Inside the AMC, the compliance officer is the gate. Until 2026 the SEBI master circular required AMCs to submit advertisements to SEBI within seven days of issue, with the compliance officer expressly confirming compliance with the advertisement code, and to keep copies. The March 2026 master circular’s advertisement chapter that we read does not repeat that filing section, and the 2026 Regulations restructured the framework, so check the current filing position with your compliance officer rather than assuming either way.
How does NFO launch marketing work inside the regulatory window?
How long can an NFO stay open, and how does that shape the launch plan?
SEBI’s master circular says that for open-ended and close-ended schemes (other than ELSS) the NFO should be open for subscription for a minimum of three working days and not more than fifteen calendar days. The fund manager may shorten or extend the period within that band based on market conditions. Because the selling window is short, the campaign has to be ready before day one. Positioning, hero visuals, explainer film, distributor kit and the compliance pass all belong before the NFO opens, not during it.
What is the 30-day window in NFO marketing?
In our practice, the 30-day window is the countdown before the NFO opens, not a regulatory period. Our NFO launch marketing checklist walks it back from day 30: lock the positioning, build one hero visual, produce the explainer film, build the collateral system, run the compliance pass, then arm the distribution channel in the last days. Separately, SEBI’s master circular requires the AMC to deploy the funds collected in an NFO within 30 business days of allotment, which is a fund-management obligation, not a marketing one.
What can an NFO advertisement say when the scheme has no track record?
It can describe the investment objective, the category, the asset allocation and the risk profile, exactly as stated in the SID and KIM, because SEBI’s advertisement code requires consistency with those documents. It cannot show past performance, because the scheme has none, and SEBI’s master circular says no past performance is to be provided for schemes in existence for less than six months. It cannot project returns or suggest an indicative portfolio or yield. The creative task is to make a clear objective interesting, not to imply an outcome.
Can we show how a similar existing fund performed to promote an NFO?
Be very careful. SEBI’s advertisement code prohibits misleading statements by implication or omission, and unfair comparisons. Presenting another scheme’s or an index’s past returns beside a new scheme’s name invites the inference that the new fund will behave the same way. If any performance of an existing scheme managed by the same fund manager is shown, SEBI’s performance disclosure rules apply in full, including CAGR periods and the other schemes managed by that fund manager. Most compliance officers will strike this out; ask before you design it.
Does an NFO campaign need a risk-o-meter when the scheme has no portfolio yet?
Yes. SEBI’s master circular requires mutual funds to assign a risk level to a scheme at the time of launch or NFO, based on scheme characteristics, and to depict it through the risk-o-meter with the line The risk of the scheme is [level]. The prescribed six-level colour scheme applies to all digital and polychrome printed promotion materials. So the NFO creative must carry the scheme risk-o-meter (and benchmark risk-o-meter where required) from the first ad. Get the assigned level from the AMC’s product team before layouts start.
What happens to NFO money after the offer closes, and why does it matter to marketing?
SEBI’s master circular requires units to be allotted or money refunded, with statements of account dispatched, within five working days of NFO closure, and the scheme to be available for ongoing transactions within five working days of allotment. The AMC must deploy the funds as per the asset allocation within 30 business days of allotment, with consequences if it does not. For marketing this means the post-NFO communication, welcome mailer and continuous-offer creative must be ready before the NFO closes, not commissioned afterwards.
Can an NFO campaign use a limited period or last three days urgency message?
The NFO period is a fact, so stating the closing date is factual. The risk is in tone. SEBI’s advertisement code prohibits advertisements framed to exploit the lack of experience or knowledge of investors and slogans unrelated to the risk and return profile. A countdown that reads as pressure to invest before thinking is likely to fail review; a plain NFO closes on [date] line with the standard warning and risk-o-meter usually passes. Check the exact wording with your compliance officer.
What must an NFO campaign say about where to read the scheme documents?
Every advertisement must carry the standard warning, which itself directs investors to read all scheme related documents carefully. SEBI’s master circular also requires trustees and AMCs to ensure the SID and SAI are readily available on the mutual fund’s website. In practice, NFO creative links or points to the SID, KIM and SAI on the AMC website and, for digital ads, carries a working link. Keep the document names consistent with what the AMC has actually filed.
How should we build NFO collateral so the compliance pass does not derail the launch?
Build one master creative that carries every mandatory element (scheme name, category, objective line, risk-o-meter, benchmark, standard warning, document pointer) and derive every other format from it. Get the master approved first. Then adaptations (print, hoarding, social, WhatsApp, email, distributor deck) inherit approved copy and only change layout. Our NFO launch marketing checklist puts the compliance pass at day six to three before opening, after the collateral system exists but before the distributor kit ships, so that a change ripples once, not fifty times.
What should the field and distributor kit for an NFO contain?
AMFI’s master circular for distributors says MFDs must use marketing material provided by the AMC and must not design their own scheme material or use an AMC’s name or logo without prior written approval. So the kit is the only creative most distributors will ever use. Include an approved one-pager, a short explainer film, approved WhatsApp-sized creatives, email templates, an FAQ and talking points, all carrying the standard warning and risk-o-meter, plus a note on what distributors may not add: returns, guarantees or comparisons.
What do AMFI guidelines require of distributor and IFA communication?
What is AMFI’s rule on showing returns in SIP calculators and power of compounding illustrations?
AMFI’s Best Practices Circular 109 of November 2023 allows numerical illustrations only in non-scheme related material, meaning material with no scheme information, and only to explain compounding through SIP, SWP or STP calculators. The illustration must use the CAGR AMFI prescribes for each category, which at issue were the mean ten-year rolling returns of the benchmarks (for example 12.64 percent for Sensex, 12.93 percent for Nifty, 7.20 percent for the 10-year G-Sec), must disclose that basis, and must carry the standard warning and the past performance disclaimer. AMFI reviews the figures annually.
Can a SIP calculator on our website let users choose any return rate?
Only within a band. AMFI’s circular clarifies that goal planning and SIP, STP and SWP calculators may let investors select a return from a range starting at 2 percent up to 13 percent to understand compounding, as long as the tool is not used to depict the returns of any particular scheme. The 13 percent ceiling was set because the highest benchmark mean in AMFI’s table was the Nifty figure. Check with your compliance officer whether AMFI has revised the range since.
Can our brochure show an SWP as a multiple of an SIP, such as invest X, withdraw Y for life?
No. AMFI’s circular records that SEBI had observed AMCs using illustrations that could lead investors to believe they would receive fixed returns, including demonstrating SWP as a multiple of SIP, with disclaimers and assumptions in fine print. SEBI asked AMFI to tell AMCs to refrain from such advertisements. The circular then states that no future returns can be shown even on an illustration basis. An SWP-from-SIP story is exactly the pattern the regulator called out.
Can a mutual fund distributor create their own creative for our scheme?
Not without written permission. AMFI’s master circular for mutual fund distributors says MFDs shall use marketing material provided by the AMCs and shall not design their own marketing materials in respect of any scheme or display the name, logo or mark of any AMC without the AMC’s prior written approval. For agencies this means the AMC-issued distributor kit is the only route to the field, and any distributor request for a custom creative goes back through the AMC’s compliance function.
What must a mutual fund distributor’s WhatsApp post, website or business card display?
AMFI’s master circular requires MFDs to display the tagline AMFI-registered Mutual Fund Distributor along with or below their name and ARN code, in a clear and legible font of at least font size 12 in all printed communication, and clearly on websites, apps, electronic materials, business cards and sign boards. Distributors must also quote a valid ARN and EUIN on transactions. When we design distributor-facing templates, the name, ARN and tagline lock-up is a fixed element.
Can a distributor call themselves a wealth advisor or investment consultant?
No. AMFI’s master circular, citing the SEBI (Investment Advisers) Regulations, says MFDs shall not use terms such as Adviser, Advisor, Financial Adviser, Investment Adviser, Wealth Adviser, Wealth Manager or Consultant in their name unless registered with SEBI as an investment adviser. The registered name must reflect the registration actually held and must not create an impression of a role the entity does not have. Every MFD must make clear to the client that they are acting as a distributor.
What can a distributor not say to a client about returns?
AMFI’s code of conduct for MFDs requires them to abstain from indicating or assuring returns for any scheme or transaction. Where an MFD also sells assured-return products, they must not mis-sell mutual funds on the basis of indicative or assured return or regular income, and must explain that mutual fund investments are not guaranteed and that the principal may be exposed to loss. Distributors must draw clients’ attention to the risk disclosures in the SID, SAI and KIM.
What are AMFI’s expectations on distributors’ social media conduct?
AMFI’s master circular requires MFDs to train their representatives on responsible usage of social media platforms with respect to content standards, authenticity and approval for the information, frequency of usage and other ethical practices. Combined with the rule that scheme material must come from the AMC, this means a distributor’s social feed should carry AMC-approved creatives, generic AMFI-compliant education, and the mandatory name, ARN and tagline, and nothing that indicates returns or promotes a scheme in the distributor’s own words.
Can a distributor comment on or compare rival AMCs’ schemes on social media?
Not in a way that disparages. AMFI’s master circular says MFDs shall refrain from making false or defamatory statements about any AMC, AMFI, mutual fund scheme or other MFDs in any private or public forum, including chat groups, social media, print or electronic press and conferences. Any written or oral communication must be based on facts and presented in an unbiased manner. Fair, factual comparison of stated features is one thing; ranking or rubbishing a rival is another.
How should an agency handle AMC-to-distributor content to stay within AMFI rules?
Treat distributor content as advertising with an extra layer. It must satisfy SEBI’s advertisement code (standard warning, no projections, no testimonials, consistency with the SID), and it must be issued by the AMC so that distributors are using AMC-provided material as AMFI requires. Build fixed lock-ups for the distributor’s name, ARN and AMFI tagline, keep return language out entirely, and route every piece through the AMC’s compliance officer before release. Version and date each asset so that a superseded creative can be withdrawn from the field.
What are IRDAI’s rules for insurance advertising and product launches?
Which IRDAI rulebook governs insurance advertising today?
The IRDAI (Protection of Policyholders’ Interests, Operations and Allied Matters of Insurers) Regulations, 2024, effective 1 April 2024, which replaced the IRDAI (Insurance Advertisements and Disclosure) Regulations, 2021, plus the Master Circular on Protection of Policyholders’ Interests dated 5 September 2024 and the Master Circular on Operations and Allied Matters of Insurers. The 2021 regulations remain useful reading because many of their definitions and prohibitions carry forward in substance, but always work from the 2024 framework and check with your compliance officer.
What is the difference between an insurance advertisement and an institutional advertisement?
An insurance advertisement is a communication, through any mode or medium, related to an insurance product and intended to result in the sale or solicitation of a policy. An institutional advertisement is not intended to solicit purchase and only promotes the brand image of the insurer or intermediary, typically carrying the registered name, logo, address and contact details. The line matters because product-related obligations (product name and benefits as filed, UIN, risk disclosures) attach to insurance advertisements. Add product information to a brand film and it becomes an insurance advertisement.
What identity details must an insurance advertisement carry?
The 2024 Regulations require the insurer to include its registered name along with its trade name, monogram or logo, visible prominently. IRDAI’s 2024 master circular tells prospects that insurance advertisements carry the registered name of the insurer and the unique identification number (UIN) of the product wherever a product is advertised. The 2021 regulations also required registration numbers on websites and privacy disclosures. Build the registered-name and UIN lock-up as a locked layer in every template.
What does IRDAI treat as an unfair or misleading insurance advertisement?
The 2024 Regulations prohibit advertisements that affect a prospect’s ability to identify and discern the benefits, disguise or obscure terms and conditions, make claims beyond the ability of the policy to deliver, hide or underplay the inherent risks, omit or insufficiently disclose important exclusions, limitations and conditions, contain illegible text including on account of font size, or display false or fabricated facts, figures and features. The 2021 regulations added examples such as implying sponsorships that do not exist and using terms that convey a fabricated sense of security.
Can an insurance ad highlight a benefit that only applies in an extreme scenario?
The 2021 IRDAI regulations listed, as unfair or misleading, advertisements where the features or benefits prominently displayed are those applicable only under extreme or exceptional scenarios, and advertisements where non-guaranteed benefits are not flagged as prominently as the benefits themselves. The 2024 framework keeps the principle that ads must not hide risks or obscure conditions. So the headline benefit should be the typical case, with conditions stated at comparable prominence, not a best-case number with the conditions in a footnote.
Can we use awards, ratings or number one insurer claims in insurance advertising?
The 2021 regulations required any rating or award claim to come from an entity independent of the insurer and its affiliates, with no payment or procured services to obtain it, disclosed with its source and year, valid for twelve months or until the next edition, and prohibited any claim of ranking regarding the insurer’s position in the market on any criterion. Claims-paid ratios had to follow IRDAI instructions. The 2024 framework moved to a board-approved advertising policy; confirm the insurer’s current policy on awards with the compliance officer before using one.
Can an insurance agent, broker or bank partner publish its own creative for our product?
Only with the insurer’s written approval. The 2024 Regulations require every advertisement by a distribution channel to be approved by the insurer in writing before issue, and distribution channels may advertise only as soliciting the insurer’s products, not as if the products were their own. The insurer must ensure that advertising through its distribution channels is subject to adequate controls and oversight. Practically, the insurer issues a channel kit and every partner adaptation comes back for sign-off.
Who approves an insurance advertisement inside the insurer, and does it still need filing with IRDAI?
Under the 2024 Regulations the insurer has a board-approved advertisement committee of key management persons, and advertisements are released under a board-approved policy; the 2021 requirement to file each advertisement with IRDAI within seven days and to submit an annual compliance certificate no longer appears. Records must be kept for three years from the date the advertisement is withdrawn, and approved advertisements are to be uploaded on the insurer’s website within three days of release. Confirm the internal routing with your compliance officer.
What extra disclosures apply to ULIP, participating and annuity product advertising?
IRDAI’s 2024 master circular contains standard benefit illustrations for linked, pension, participating and other products, and states that illustrations are shown at assumed investment returns of 4 percent and 8 percent per annum for products other than annuities. Advertising for linked and participating products must make clear that the policyholder bears the investment risk and that bonuses are not guaranteed, and must not present a market-linked product as a traditional one. The 2021 rules required non-guaranteed benefits to be flagged as prominently as the benefits themselves.
What do we need to know about advertising a pilot product or a product launch?
IRDAI’s 2024 master circular says that for pilot products all sales and publicity material must disclose that the product is a pilot and close-ended, the date by which it may be withdrawn or converted into a regular product, the migration option if it is discontinued, and must carry the tag line PILOT PRODUCT. For any launch, product names and benefits must match what was filed, the UIN must appear once allotted, and the advertisement committee should see the master creative before adaptations begin.
What are RBI’s rules for bank, NBFC and digital-lending advertising?
Is there a single RBI advertising code for banks and NBFCs?
No. RBI does not publish one advertising code the way SEBI and IRDAI do. Marketing obligations sit inside the Fair Practices Code for NBFCs, the Master Circular on Customer Service in Banks, the Key Facts Statement requirements and the Reserve Bank of India (Digital Lending) Directions, 2025. The through-line is transparency: annualised interest, all charges, the borrower’s language, and no communication that obscures the true cost of credit. Treat those documents together as your advertising code, and check the current circulars with your compliance officer.
What must a loan advertisement say about interest rates?
RBI’s Fair Practices Code for NBFCs requires the rate of interest to be an annualised rate so the borrower knows the exact rate, and requires the rate and the approach for gradation of risk to be disclosed in the application form, communicated in the sanction letter, and made available on the company’s website. Penal interest must be shown in bold in the loan agreement. For creative, this means a headline rate should be annualised, not monthly, and the same rate should be reachable on the website the ad points to.
Can a loan ad say instant approval or loan in minutes?
Be careful. RBI’s Fair Practices Code requires NBFCs to give an acknowledgement and a timeframe for disposal of loan applications and to convey sanction in writing with all terms; the Digital Lending Directions 2025 require a Key Fact Statement before the loan contract is executed and a cooling-off period afterwards. A claim of minutes must be literally true for the typical applicant and must not gloss over those steps. Check with your compliance officer what your process can honestly support.
What language should loan communication be in?
RBI’s Fair Practices Code for NBFCs says all communications to the borrower shall be in the vernacular language or a language understood by the borrower, that the sanction letter and any change in terms must be notified in that language, and that the Fair Practices Code itself should preferably be in the vernacular and put on the website. For campaigns, that means regional adaptations are not a nice-to-have, and the disclosures in the regional version must be true translations, not shortened ones.
What must a digital lending app or website disclose publicly?
The RBI (Digital Lending) Directions, 2025 require a regulated entity to display at a prominent single place on its website details of all its digital lending products and its digital lending apps, details of its lending service providers and their apps, particulars of customer care and internal grievance redressal, links to RBI’s Complaint Management System and Sachet portal, and its privacy policies. These are content and design requirements for the site, and the lender must also report its apps to RBI.
What is a Key Fact Statement and does it affect creative?
Under RBI’s April 2024 Key Facts Statement circular, which the Digital Lending Directions 2025 adopt, the lender must give the borrower a KFS before the loan contract is executed, including the annual percentage rate and all charges. Digitally signed documents such as the KFS, loan product summary and sanction letter must flow to the borrower automatically. For creative, the number in the advertisement must reconcile with what the KFS will show; a headline rate that the KFS contradicts is a complaint waiting to happen.
What is the cooling-off period in digital lending?
RBI’s Digital Lending Directions 2025 give the borrower an explicit option to exit a digital loan during an initial cooling-off period by paying the principal and the proportionate APR without penalty; the Directions set a minimum period of one day and allow the lender to retain a reasonable one-time processing fee only if it was disclosed upfront in the KFS. Loan journeys and onboarding communication should explain this option clearly rather than hide it.
Can a loan marketplace or aggregator app promote one lender’s offer over another?
No. RBI’s Digital Lending Directions 2025 require a lending service provider that works with multiple lenders to show a digital view of all matching offers, with the lender’s name, amount, tenor, APR, monthly repayment and penal charges, and a link to each KFS, so the borrower can make a fair comparison. The Directions say the content displayed shall be unbiased and objective and shall not directly or indirectly promote or push a product of a particular lender, including through dark or deceptive patterns.
Can a lender advertise a pre-approved limit increase or automatically raise a credit limit?
RBI’s Digital Lending Directions 2025 say there shall be no automatic increase in credit limit unless an explicit request is received from the borrower, evaluated and kept on record. Marketing may invite a customer to request a higher limit, but a communication that presents an increase as already applied, or that opts the customer in by default, conflicts with that rule. Draft the call to action as a request the borrower makes, not a benefit already granted.
How does a bank communicate a new fee or a change in charges?
RBI’s Master Circular on Customer Service in Banks requires charges to be reasonable and not out of line with the cost of providing the service, requires any charge levied subsequently to be made known to depositors in advance with one month’s notice, and prescribes a format for displaying interest rates and service charges on websites so customers can find them at a glance. Fee-change mailers therefore need a clear effective date, the old and new charge, and a link to the updated schedule.
How do disclaimers, risk-o-meters, past performance and testimonials work in financial creative?
What does a risk-o-meter look like and where must it appear?
SEBI’s master circular prescribes a pictorial meter called the Riskometer with six levels: Low, Low to Moderate, Moderate, Moderately High, High and Very High, and the line The risk of the scheme/benchmark is [level]. The risk level is assigned at launch, evaluated monthly and disclosed on the AMC and AMFI websites within ten calendar days of month end. Any change is communicated by addendum and by email or SMS to unitholders. Scheme promotion materials carry the scheme risk-o-meter; check with your compliance officer where the benchmark meter is also required.
Can we change the colours of the risk-o-meter to match our brand palette?
No. SEBI’s master circular specifies the colour for each level by name and HTML code (for example Irish Green for Low and Red for Very High) and says this colour scheme applies to all digital and polychrome printed promotion materials. Recolouring the meter to fit a brand palette breaks the disclosure. Design the layout so the meter sits cleanly against your palette instead of altering the meter itself.
How do we show past performance in a mutual fund ad?
SEBI’s master circular requires performance to be advertised as CAGR for at least the past one, three and five years and since inception, plus point-to-point returns on a standard investment of ten thousand rupees, computed from the last day of the month preceding the advertisement. The ad must say whether it shows the regular or direct plan, with a footnote that plans have different expense structures, must show the scheme benchmark and the prescribed additional benchmark, and must footnote any change of fund manager during the period.
If we advertise one scheme’s performance, do we have to show the fund manager’s other schemes?
Yes. SEBI’s master circular says that when a scheme’s performance is advertised, the advertisement shall also include the performance of all other schemes managed by that scheme’s fund manager, as CAGR for one, three and five years against their benchmarks. If the manager runs more than six schemes, the AMC discloses the total number and the top three and bottom three. Digital advertisements may instead provide an exact website link to that summary. This single rule shapes the layout of every performance ad.
Can a fund less than a year old advertise returns?
Only in a limited way. SEBI’s master circular says that where a scheme has existed for less than six months, past performance shall not be provided. Between six months and one year, only the simple annualised growth rate for the past six months and since inception, computed from the preceding month end, may be shown. The full CAGR format applies once the scheme has a one-year history. For a first-anniversary campaign, plan the performance creative around the month-end data date, not the launch date.
Can liquid or overnight funds show seven-day returns?
Yes, with conditions. SEBI’s master circular allows overnight, liquid and money market funds, where investors have very short horizons, to advertise performance by simple annualisation of yields, provided a figure is available for at least seven, fifteen and thirty calendar days, and provided it does not give an unrealistic or misleading picture of performance or future performance. The three periods travel together; a creative that shows only the most flattering one is the kind of selective disclosure the code prohibits.
How small can the disclaimer font be?
SEBI’s advertisement code requires the standard warning in legible fonts and prohibits design that disguises the significance of any statement. AMFI’s circular says disclaimer font size should be commensurate with the other sections of the advertisement, after SEBI observed disclaimers in fine print that investors were likely to miss. IRDAI’s 2024 Regulations list illegible text, including on account of font size, as a form of misleading advertisement. None of the current sources we read specifies a point size for the warning, so the working test is legibility at the medium’s viewing distance, agreed with your compliance officer.
Can we use customer testimonials in financial creative?
For mutual funds, no: SEBI’s advertisement code says advertisements shall not contain any testimonials. For insurance and lending, testimonials are not banned outright, but IRDAI’s rules on claims beyond the policy’s ability to deliver, on non-guaranteed benefits and on fabricated facts apply, and RBI’s transparency expectations apply to loans. A testimonial that implies a return, a claim outcome or an approval speed the typical customer will not get is misleading regardless of regulator. Use them sparingly, verify them, and never in mutual fund work.
How should dividend or IDCW payouts be advertised?
SEBI’s master circular requires IDCW advertisements to disclose the amount declared or paid in rupees per unit, the face value of each unit and the prevailing NAV at the time of declaration. Immediately below the payout figure, the advertisement must state that the NAV will fall to the extent of the payout and statutory levy. Percentage-only payout headlines, or payout figures separated from that NAV statement, will not pass review.
What disclaimer applies to insurance benefit illustrations and past fund performance?
IRDAI’s 2024 master circular provides standard benefit illustration formats for linked, pension and participating products at assumed returns of 4 percent and 8 percent per annum, and the 2021 regulations required that illustrations of future benefits rest on assumptions that are realistic in the light of the insurer’s current performance and that non-guaranteed benefits be flagged as prominently as the benefits themselves. The earlier IRDAI master circular required past performance to be labelled as not necessarily an indication of future performance. Confirm the current wording with your compliance officer.
What are the rules on social media, influencers and finfluencers in BFSI?
Can a mutual fund, broker or AMC partner with a finfluencer in India?
Only if the influencer is not doing either of two prohibited things. SEBI’s circular of 22 October 2024 says persons regulated by SEBI (including AMCs) and their agents shall not have any direct or indirect association with anyone who provides advice or recommendations on securities without being registered or permitted by SEBI, or who makes claims of returns or performance without SEBI’s permission. Regulated entities were told to terminate existing contracts with such persons within three months. Registered advisers and research analysts, and pure educators, are outside the prohibition.
What exactly counts as association with a finfluencer under SEBI’s rules?
SEBI’s January 2025 clarification circular defines association as a transaction involving money or money’s worth, referral of a client, interaction of information technology systems, or any other association of a similar nature. Sharing client information counts as referral. So a paid post, an affiliate link, an API integration, a lead-sharing arrangement or a co-branded event with a person engaged in the prohibited activities is an association, and it is not permitted. The regulated entity is responsible for its agents’ associations too.
Can we sponsor an investor education creator?
Yes, provided they are genuinely educating. SEBI’s circulars say the term another person does not include a person engaged solely in investor education, as long as that person does not directly or indirectly give unregistered advice or make return claims. The regulated entity must ensure that the educator stays on that side of the line for the duration of the association. Write that condition, and a right to terminate if it is breached, into the creator contract.
What separates education from advice, in SEBI’s terms?
SEBI’s January 2025 clarification says a person engaged solely in education should not be using the market price data of the preceding three months to speak about or display the name of any security, including code names, in talks, videos, tickers or screen shares in a way that indicates a future price, advice or recommendation. Content that explains concepts, categories and processes without pointing at live securities is education. Content that walks through today’s chart of a named stock is not.
If our marketing agency runs influencer campaigns, who is liable?
The regulated entity. SEBI’s January 2025 clarification states that advertising, branding or lead generation through a marketing agency amounts to a violation if the regulated entity or its agent indirectly ends up associated with someone engaged in a prohibited activity. The agency is a route, not a shield. At Yamm Labs we therefore treat creator vetting as part of the brief, document the creator’s registration status or education-only scope, and keep the AMC’s compliance officer in the approval chain for every creator.
Can we run programmatic ads that might appear next to finfluencer content?
SEBI’s clarification distinguishes two cases. Where the regulated entity or its agent has control over where its advertisement or content appears, it is expected to use that control to avoid association, and there is no violation if it does. Where it has no control over the content or entity it gets associated with, an association that results is a violation. Practically, use placement controls, exclusion lists and allow-lists, and keep records that show the controls were applied.
Can an insurance company use influencers?
IRDAI does not prohibit influencers as such, but the 2024 Regulations require every advertisement by a distribution channel to be approved in writing by the insurer, and the 2021 regulations required insurers to ensure that static or interactive content on social media satisfies the advertisement rules and to monitor third-party interactive content on their pages. An influencer post that describes benefits is an insurance advertisement: registered name, UIN, product as filed, risks not underplayed. SEBI’s clarification also warns SEBI-regulated firms about associating with promoters of other BFSI products who make return claims.
Can a mutual fund distributor post a scheme meme or reel?
Only if the AMC made it or approved it. AMFI’s master circular says MFDs must use AMC-provided marketing material and may not design their own scheme material or use an AMC’s name or logo without written approval, must be trained on responsible social media use, and must not indicate or assure returns. A distributor’s own reel about a named scheme is therefore a compliance issue for both the distributor and the AMC, whose compliance officer is expected to monitor distributor conduct.
What should the social media policy of a BFSI brand cover?
Who may post, what pre-approval each content type needs, the mandatory elements for product content (standard warning and risk-o-meter for mutual funds; registered name and UIN for insurance; annualised rate and KFS pointer for loans), the rule that no post projects returns or uses testimonials where prohibited, how comments and interactive content are monitored, how creators are vetted against SEBI’s prohibited activities, how paid placements are controlled, and how posts are archived. IRDAI’s 2021 regulations explicitly expected insurers to monitor third-party interactive content on their pages.
Does SEBI’s finfluencer rule apply to a fintech app that is not SEBI-registered?
The rule binds persons regulated by SEBI and their agents, so an unregistered app is not directly bound by it. But the moment that app runs a campaign with a SEBI-registered broker, AMC or adviser, the regulated partner must ensure the app is not engaged in unregistered advice or return claims, because the association would breach the partner’s obligations. SEBI’s clarification also notes that products under other regulators, such as insurance or banking, carry those regulators’ rules. Check both regimes before a cross-sector partnership.
How does Yamm Labs build compliance into the creative process?
How does Yamm Labs keep BFSI creative from failing compliance review?
Yamm Labs is a design-led brand and creative agency for fintech and BFSI companies, founded in Gurugram in 2017. Our creative work is built to pass SEBI, IRDAI and RBI review because the mandatory elements are designed in at the start, not retrofitted. We read the relevant code before the first layout, treat the standard warning, risk-o-meter, registered name, UIN or annualised rate as fixed layout elements, and write copy that describes objectives and features rather than promising outcomes. Clients include TATA AIA, HDFC Life, Axis Bank, Paytm Money and Aditya Birla Sun Life Mutual Fund.
What are the compliance gates in a Yamm Labs project?
Three. Gate one is the brief: we confirm the regulator, the product documents (SID and KIM, product filing and UIN, or KFS and loan terms) and the client’s mandatory-element list. Gate two is the master creative: one asset carrying every mandatory element goes to the client’s compliance officer before any adaptation is built. Gate three is the adaptation set: every derived format is checked against the approved master for copy, disclaimers and lock-ups, then released with a version number and date.
What is the compliance officer’s role in a creative project, and when do we involve them?
The compliance officer is the person who confirms that an advertisement complies with the code; under SEBI’s pre-2026 filing process that confirmation was explicit, and IRDAI’s framework relies on an advertisement committee. We involve them at gate one to agree the mandatory-element list and at gate two on the master creative, which is early enough to change a concept without waste. We do not treat the compliance officer as a final proofreader; by then a structural objection costs the launch date.
What is a template system and why does it reduce compliance risk?
A template system is a set of layouts for every format the campaign needs, each with locked zones for mandatory elements (warning, risk-o-meter, registered name and UIN, ARN and AMFI tagline, rate and KFS pointer) and editable zones for headline, visual and body. Because the locked zones cannot be moved or resized by whoever adapts the file, the disclosures cannot quietly shrink or vanish in the fiftieth WhatsApp creative. It also means an approved master propagates its approval to every adaptation, which is what makes short NFO windows workable.
How does Yamm Labs version-control disclaimers?
Every disclaimer, warning and disclosure block lives in a single controlled text source with a version number, the regulator reference it is based on, the date it was agreed with the client’s compliance officer, and the formats it applies to. Templates pull from that source. When a rule changes, for example the 2026 SEBI Regulations replacing the 1996 code, we update the source once, bump the version, and reissue the affected templates with a change note. Each released asset carries its disclaimer version so a superseded creative can be identified and withdrawn.
What does the client need to provide before creative work starts?
The approved product documents (SID, SAI and KIM; product filing and UIN; KFS format and loan terms), the compliance officer’s name and turnaround time, the current mandatory-element list and any house disclaimer text, the assigned risk-o-meter level for a mutual fund scheme, brand guidelines, and the target formats and languages. For distributor or channel material, we also need the client’s rules on what partners may and may not change. Without these, the first compliance pass becomes a discovery exercise rather than a check.
Does Yamm Labs give legal or compliance advice?
No. We are a creative agency, not a law firm or a compliance function. We read the regulations and circulars so that our work arrives at review already shaped by them, and we can point to the source for every mandatory element we place. The decision that an advertisement complies belongs to the client’s compliance officer and, where the rules require it, an advertisement committee or trustees. Where we are unsure, we say so and ask the compliance officer rather than guess.
How does Yamm Labs handle multi-language adaptations?
The mandatory elements travel with the language. SEBI’s advertisement code requires the standard warning in the vernacular for vernacular advertisements; IRDAI’s 2021 regulations required mandatory disclosures to be in the same language as the whole advertisement and treated language versions with unchanged content as the same advertisement; RBI’s Fair Practices Code requires borrower communication in a language the borrower understands. We produce the English or Hindi master first, get it approved, then adapt with certified translations of the locked text so that regional versions are not paraphrased.
What does Yamm Labs deliver for an NFO or insurance launch?
For an NFO: positioning and messaging, one hero visual system, an explainer film, the collateral set (print, outdoor, digital, email, WhatsApp), and the distributor kit, sequenced against our 30-day NFO checklist so that the compliance pass happens before the field kit ships. For an insurance launch: the same structure, with the registered-name and UIN lock-up, benefit illustration formats and channel-partner kit built for the insurer’s written approval process. Each deliverable arrives with its disclaimer version and an adaptation guide.
How do we start working with Yamm Labs on a compliant campaign?
Send us the product, the regulator, the launch date and the formats you expect to need, through the contact form on yammlabs.com. We come back with the mandatory-element list as we read it, the questions we would put to your compliance officer, and a sequence plan. For NFOs, our NFO launch communication page describes the engagement in more detail. Yamm Labs works from Gurugram with clients across India and the Gulf, and with international clients. Yamm Labs is not related to Yet Another Mail Merge (YAMM), the Google Workspace add-on, or to yaM Labs, a US meeting-software startup.
Launching a fund, a policy or a lending product?
Yamm Labs builds NFO and product-launch communication that arrives at compliance review already shaped by SEBI, IRDAI and RBI rules. See our NFO launch communication agency page, or Talk to Yamm Labs →
Last updated: 18 September 2026
Sources
- Securities and Exchange Board of India (Mutual Funds) Regulations, 2026, Regulation 28 and Fifth Schedule (Advertisement Code), SEBI, notified January 2026, in force 1 April 2026
- Master Circular for Mutual Funds as on March 20, 2026 (Chapter 1 on NFO period, Chapter 6 on risk-o-meter, Chapter 7 on NFO fund deployment, Chapter 14 on advertisements), SEBI, 20 March 2026
- Master Circular for Mutual Funds as on March 31, 2024, Chapter 13: Advertisements (including the pre-2026 filing requirement), SEBI, copy hosted by HDFC Mutual Fund
- Guidelines for Advertisement by Mutual Funds, SEBI, 2000
- AMFI Best Practices Guidelines Circular No. 109/2023-24: Usage of illustrations for depicting future returns in non-scheme related materials, AMFI, 1 November 2023
- AMFI Master Circular for Mutual Fund Distributors (AMFI/MFD-CIR/32/2025-26), AMFI, consolidating circulars to 31 December 2025
- Association of persons regulated by the Board and their agents with certain persons (SEBI/HO/MIRSD/MIRSD-PoD-1/P/CIR/2024/143), SEBI, 22 October 2024
- Details/clarifications on provisions related to association of persons regulated by the Board, MIIs, and their agents with persons engaged in prohibited activities (SEBI/HO/MIRSD/MIRSD-PoD-1/P/CIR/2025/11), SEBI, 29 January 2025
- IRDAI (Insurance Advertisements and Disclosure) Regulations, 2021, Gazette of India, 9 April 2021 (since replaced by the 2024 Regulations)
- IRDAI (Protection of Policyholders’ Interests, Operations and Allied Matters of Insurers) Regulations, 2024, advertising provisions, as reproduced by Taxguru; verify against the Gazette text
- Master Circular on Protection of Policyholders’ Interests, 2024 (IRDAI/PP&GR/CIR/MISC/117/9/2024), IRDAI, 5 September 2024
- Guidelines on Fair Practices Code for NBFCs, Reserve Bank of India
- Master Circular on Customer Service in Banks, Reserve Bank of India
- Reserve Bank of India (Digital Lending) Directions, 2025, Reserve Bank of India, 8 May 2025
