The SEBI Advertisement Code, Decoded for Creative Teams: What a Mutual Fund Ad Can and Cannot Say

By Yamm Labs · Updated September 2026 · 10 min read

A 30-second NFO film comes back from the AMC’s compliance desk with one note: “Standard warning not legible on mobile.” The film is beautiful. The disclaimer sits in white text over a bright sky, on screen for two seconds, voiced at double speed. The creative team thinks the note is pedantic. The compliance officer thinks the film is unairable. Both are right, and the fight could have been avoided at the storyboard stage. The SEBI advertisement code is a set of layout and copy constraints, and the teams that treat it that way ship faster.

What does the SEBI advertisement code actually govern?

The code is part of SEBI’s mutual fund regulations and is refined by circulars and AMFI guidance. Every AMC’s compliance team applies it to every piece of communication that could induce someone to invest: press ads, hoardings, TV and OTT films, social posts, app banners, WhatsApp creatives sent by distributors, even a SIP calculator screen. If it names a scheme or nudges an investment decision, it is an advertisement.

The rules cluster into five areas, and each one lands on the designer’s desk in a specific form.

• Claims. No guaranteed or assured returns unless the scheme is actually guaranteed. No promises of safety, no “wealth in five years”, no “cheap NAV at ₹10” pitch during an NFO. Language must be simple and not misleading.
• Past performance. If returns are shown at all, they must be shown in a prescribed structure: compound annual growth rates over standard periods, alongside the scheme’s benchmark, for both regular and direct plans, as of a stated date, with the line that past performance may or may not be sustained in future.
• Disclaimers and labels. The standard warning, “Mutual Fund investments are subject to market risks, read all scheme related documents carefully”, is mandatory in every ad. Scheme-specific ads also carry the riskometer, which since 2021 has six levels from Low to Very High.
• Endorsement. Individual AMCs cannot use celebrities to promote schemes. Celebrity endorsement is permitted only for industry-level investor awareness campaigns run through AMFI, with prior SEBI approval. More recently SEBI has barred regulated entities from associating with unregistered finfluencers who make return claims.
• Comparisons and rankings. Comparing schemes, showing rankings or star ratings, or claiming “No.1” is allowed only with the source, criteria, date and period disclosed, and only where the comparison is fair and like-for-like.

For the wider picture across the three regulators, our guide to SEBI, IRDAI and RBI advertising rules for creative teams covers what each one cares about. This post goes one level deeper into the mutual fund code alone.

What can a mutual fund ad say about returns?

This is the rule that kills the most headlines. The creative instinct is to lead with a number: “18% in 3 years.” The code says a number can only appear inside the full performance structure, never alone. A compliant performance panel has a fixed anatomy, and it is worth building it as a component in the brand’s design system rather than redrawing it every time.

• Standard periods. Returns for 1 year, 3 years, 5 years and since inception, expressed as CAGR. If the scheme is younger than one of those periods, that column is marked not applicable rather than dropped silently.
• Benchmark alongside. The scheme’s benchmark index returns for the same periods sit in the adjacent column. This is the single most common omission in social creatives.
• Regular and direct. Both plans, both growth options, shown separately.
• Point-to-point on a standard sum. Value of a fixed initial investment, conventionally ₹10,000, over each period.
• Date stamp. Performance as on a specific recent date, stated on the creative itself.
• Other schemes by the same fund manager. When a scheme’s returns are shown, the performance of other schemes managed by the same fund manager must also be disclosed, or a pointer given to where it can be found.
• The line. “Past performance may or may not be sustained in future and is not a guarantee of any future returns.”

The design consequence: a performance panel needs at least six columns and three rows of small type, plus footnotes. It will not fit legibly in a 1080×1080 Instagram post. This is why most AMC social creatives avoid returns altogether and lead with a theme, a category or a SIP behaviour. That is not timidity. It is a rational response to the rule.

Two more copy rules bite here. Since April 2021 the payout option is called Income Distribution cum Capital Withdrawal, or IDCW, and any creative still saying “dividend plan” will be rejected. And SIP creatives cannot show a projected corpus at an assumed rate as though it were a forecast; illustrations must be labelled as illustrations with the assumed rate stated.

Where does the standard warning go, and how big?

The standard warning is the same sentence everywhere, but the code’s legibility requirement lands differently in each medium. Here is how we specify it across formats when we set up an AMC’s template system.

Scheme-specific ads add the riskometer: a semicircular dial with the scheme’s level marked, shown alongside the benchmark’s riskometer, the scheme name and the line stating who the product is suitable for. Treat it as a lockup with fixed proportions, a minimum size and a placement rule. Do not recolour it to match the campaign palette.

Can a mutual fund ad use a celebrity, a star rating or a “No.1” claim?

Three things creative teams keep proposing, and the answer to each.

• Celebrity. Not for an AMC’s own scheme or brand. The “Mutual Funds Sahi Hai” campaign, run by AMFI since 2017, is the industry-level exception and it needed SEBI’s sign-off. An AMC can use employees, its fund managers and ordinary people. It cannot use a cricketer to say “I invest in this fund”.
• Finfluencers. Since SEBI’s 2024 amendments, an AMC cannot have a commercial association with an unregistered person who gives investment advice or makes return claims. Creator-led investor education is possible only within tight limits, and the creator cannot talk about scheme returns.
• Ratings and rankings. A star rating or a “No.1 in category” claim can be used, but the ad must show who awarded it, on what criteria, for what period and as of what date. Design-wise a rating badge is never a badge alone; it is a badge plus a three-line footnote, so we design them as one component.
• Comparisons. “Better than FD” is the classic rejection. A debt fund cannot be compared to a bank deposit as though they carry the same risk. Comparisons across schemes are allowed only where they are like-for-like and the basis is disclosed.

Compliant vs non-compliant: how each ad element is judged

The table below is the checklist we hand a creative team before the first layout, annotated with the fix that usually gets a rejected element through.

How should creative and compliance review a mutual fund ad?

Most AMC review workflows fail because compliance sees the work last. The film is shot, the hoarding is rendered, and the compliance officer is asked to approve an object that cost ₹40 lakh to make. Of course the note feels adversarial. The fix is to move compliance to three earlier gates, each of which is cheap.

1. Gate one: the claim list. Before any layout, the strategist writes every claim the campaign will make in plain sentences, plus the headline words. Compliance approves the list in a day. Everything downstream inherits that approval.
2. Gate two: the template. Disclaimer bands, riskometer lockup, performance panel, rating component and footnote styles are approved once per format, not once per creative.
3. Gate three: the storyboard or wireframe. For film, the disclaimer card and VO line are in the storyboard with a timing. For app screens, the disclaimer position is in the wireframe. Compliance signs the structure before production money is spent.
4. Final check. A mechanical pass on the finished asset: right scheme name, right date on the performance data, right ARN on distributor versions, riskometer level matches the latest disclosure.

Two housekeeping rules make this work. Every creative carries an internal reference code so compliance can track it, and every performance figure comes from the same monthly source as the factsheet, so the two never disagree. If you are planning an NFO, the NFO launch marketing checklist sets these gates against the calendar.

Why do mutual fund ads get rejected?

From the review rounds we have sat in, the same handful of reasons come up. None of them are about the idea.

• Illegible standard warning. Too small, too low-contrast, too brief on screen, or cropped by a platform overlay.
• Missing benchmark. Scheme returns shown without the benchmark column.
• Stale data. Returns as of an old date, or a riskometer level that changed after the last disclosure.
• Prohibited words. “Guaranteed”, “safe”, “assured”, “best” and “dividend” in copy.
• Unlabelled illustration. A SIP calculator output presented as a projection.
• Distributor edits. A distributor removing the disclaimer strip from a shared template.
• Unfair comparison. Fund versus deposit, or fund versus a peer scheme on a cherry-picked period.

Every one of these is a template or a copy-list problem, which means every one of them is preventable before the creative round starts.

A mutual fund ad is compliant by construction or it is compliant by luck; only one of those scales across 200 creatives a quarter.

People also ask

What is the mandatory disclaimer on mutual fund advertisements in India?

The standard warning is “Mutual Fund investments are subject to market risks, read all scheme related documents carefully.” It must appear legibly in every ad and, in audio-visual and audio formats, must also be read out in a way a viewer or listener can follow. Scheme-specific ads additionally carry the riskometer.

Can a mutual fund advertisement show past returns?

Yes, but only in the prescribed structure: CAGR for 1, 3 and 5 years and since inception, alongside the benchmark, for regular and direct plans, as of a stated date, with the past-performance line. A return figure cannot appear on its own as a headline number.

Can an AMC use a celebrity in a mutual fund ad?

No. Celebrity endorsement is allowed only for industry-level investor awareness campaigns run through AMFI with SEBI’s prior approval, such as “Mutual Funds Sahi Hai”. An individual AMC cannot use a celebrity to promote its brand or schemes.

Why was “dividend” replaced by IDCW in mutual fund communication?

From April 2021 SEBI required the payout option to be called Income Distribution cum Capital Withdrawal, because payouts include a return of the investor’s own capital and the word “dividend” suggested profit. All creatives, calculators and app labels must use IDCW.