Can my research report itself count as an advertisement?
In force
Yes. If anything in the report promotes your products or services, the report is treated as an advertisement, no matter how you sent it.
That matters because the whole advertisement code then applies to it: prior approval, the standard warning, no superlatives, no unverified performance figures.
In practice this catches the free sample report used to win subscribers, and the report posted publicly on social media with a line about joining your service.
What SEBI says, word for word
Clarification Circular“a research report, irrespective of the mode of its dissemination... shall be construed as an advertisement if anything contained in the said research report is either expressly or impliedly in the nature of promotion of products or services offered by an RA”Source: SEBI Circular SEBI/HO/MIRSD/MIRSD-PoD1/P/CIR/2024/146, dated October 24, 2024 Open document ↗