Can I pay a finfluencer for leads, or work with someone who is not SEBI registered?
In force
No, not if that person gives advice or recommendations on securities without registration, or makes claims about returns or performance without SEBI's permission.
"Association" is defined widely. It covers money or money's worth, referring a client, and connecting your IT systems, plus anything similar. Paying for leads, taking a referral fee, and sharing client information are all caught.
The responsibility is yours, not theirs. You must make sure anyone you or your agents deal with is not doing either prohibited thing, to the extent of your association with them.
It applies through a marketing agency too. If your lead generation agency ends up putting you alongside such a person, that is a breach.
What you can do: work with someone who is clean on both counts; and deal with people engaged in genuine investor education, who are carved out.
That education carve-out has a sharp edge. Since 8 May 2026, an educator must not use market price data from the preceding thirty days while naming a security. It used to be three months. The February 2026 Master Circular still prints the old three-month figure, so do not rely on it for this point.
Existing contracts with such persons were to be terminated by 21 January 2025.
The regulation exempts association through a "specified digital platform", but SEBI has not named any platform as one. You cannot rely on that exemption today.
What SEBI says, word for word
Regulation 16A(1)“No person regulated by the Board or the agent of such a person shall have any direct or indirect association, with another person who— (i) provides advice or any recommendation, directly or indirectly, in respect of or related to a security or securities, unless the person is registered with or otherwise permitted by the Board to provide such advice or recommendation; or (ii) makes any claim, of returns or performance expressly or impliedly, in respect of or related to a security or securities, unless the person has been permitted by the Board to make such a claim”Source: SEBI (Intermediaries) Regulations, 2008 — Regulation 16A, inserted with effect from August 29, 2024 Open document ↗
Regulation 16A, Explanation 2“For the purposes of this regulation, the expression "association" shall mean- (a) a transaction involving money or money's worth; (b) referral of a client; (c) interaction of information technology systems; (d) any other association of a similar nature or character.”Source: SEBI (Intermediaries) Regulations, 2008 — Regulation 16A, Explanation 2 Open document ↗
FAQ Circular, Q13“Sharing client information is of similar nature as of "referral of a client". Hence, making any payment or receiving payment or sharing any client information from or with any person shall amount to "association" under these regulations, and is not permitted.”Source: SEBI Circular SEBI/HO/MIRSD/MIRSD-PoD-1/P/CIR/2025/11, dated January 29, 2025 Open document ↗
FAQ Circular, Q8 (as amended 8 May 2026)“Such person should not be using the market price data of the preceding thirty days to speak/talk/display the name of any security including using any code name of the security in his/her talk/speech, video, ticker, screen share etc. indicating the future price, advice or recommendation related to security or securities.”Source: SEBI Circular SEBI/HO/MIRSD/MIRSD-PoD-1/P/CIR/2025/11, dated January 29, 2025, response modified with effect from May 8, 2026 Open document ↗
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