Common Advertisement Code for SEBI-Regulated Entities: Marketing Approval and Archive Controls
By Ravi Sisodia · Reviewed by CA Divyanshu Sengar · Updated 5 October 2026
SEBI's proposed common advertisement code remains a consultation. Regulated entities should not call it binding yet, but can prepare a common marketing approval and archive layer across business lines.
Finin2min 2-Minute Summary
- SEBI proposed a Common Advertisement Code for specified regulated entities on 23 June 2026.
- The proposal remains consultation-stage at the 4 October source check.
- A common code would reduce fragmented advertising standards but does not replace product-specific disclosure rules.
- Marketing governance should identify the regulated capacity in which each communication is issued.
- Every approved advertisement should have substantiation, risk disclosure, approver, media/version and archive evidence.
Proposal status belongs on the compliance tracker
Do not reject or approve advertisements solely by citing a consultation clause as if it were already operative. Keep current entity-specific rules in force until SEBI finalises the common code.
Use the consultation to map gaps and simplify internal standards in advance.
One campaign can touch multiple registrations
A financial group may operate as broker, IA, RA, PMS distributor or other regulated capacity. The advertisement file should say which entity and registration is responsible for the claim, rather than using one group brand and leaving the legal speaker unclear.
Social-media disclosure requirements already operative must continue independently.
Substantiate numbers before creative approval
Return, performance, cost, ranking, 'best' or comparative claims need source data, period, benchmark and methodology. The archive should preserve the exact published creative, not only the editable source file.
Influencer/agent content should be contractually subject to the same approval route.
Advertisement case: one group campaign crosses three regulated entities
A financial group may publish a video discussing broking, PMS and research under one brand. Under any future common code, the challenge is identifying which legal entity is making each claim and which registration/disclosure standard applies. One generic group disclaimer can be too vague.
The approval file should split the script by regulated capacity, identify the data source for each return/ranking statement and preserve the exact final cut. If an influencer reposts an edited clip that removes mandatory disclosures, the group needs a monitoring and takedown/escalation process.
- Map every claim to the regulated legal entity/capacity.
- Archive the final published creative, not only the script.
- Monitor edited/reposted agent or influencer content.
Archive-retention design
Advertisement governance should define how long approval packs and final creatives remain retrievable and who can alter or delete them. Where content is published across several platforms, save the platform-specific version because captions, disclosures and truncation can differ. A central content ID helps compliance reconstruct which approved creative appeared on which handle and date.
- Assign a unique content ID.
- Retain platform-specific published versions.
Marketing archive checklist
- Current rule vs proposal matrix.
- Regulated entity/capacity identified.
- Claim substantiation.
- Risk/qualifier review.
- Compliance approval.
- Final creative/version/media.
- Publication and retention evidence.
Questions readers commonly ask
Is the common code final?
No. The 23 June 2026 item is a consultation/proposal.
Can firms prepare now?
Yes, by harmonising internal controls without representing the proposal as law.
Does it replace social-media disclosure rules already issued?
No. Existing operative circulars continue unless changed.
What should be archived?
The exact final advertisement, approvals and supporting claim evidence.
Official / primary sources
- SEBI Common Advertisement Code proposal - 23 June 2026 consultation/press release
- SEBI Social Media Disclosure Circular - Existing operative social-media disclosure control
Disclaimer
Important: General educational and professional-reference material. Verify the current operative regulation/circular, portal version and exact facts before acting. Consultation papers are proposals unless a later operative instrument adopts them. Educational and professional reference only; confirm the current law, rates and the facts of your case before relying on this page.