You may give a client past performance certified by an ICAI or ICMAI member, one-to-one and only when they ask, until PaRRVA-verified metrics take over.
SEBI's circular dated 30 October 2025 sets an interim route for you to show past performance to clients. It covers the period before PaRRVA, the Past Risk and Return Verification Agency, becomes operational. The circular does not give a separate start date, and it does not say when PaRRVA will be operational.
PaRRVA was set up under a SEBI circular dated 4 April 2025. It verifies performance only for the period after you onboard with it. Industry associations asked SEBI for a way to share performance from before that. This circular is the answer.
What you can do now
You may give past performance data to a client, including a prospective client, only if that client specifically asks for it. The data must be certified by a member of ICAI or ICMAI. You share it one-to-one. You cannot put it on your website, in public media or anywhere else the general public can see it.
Every time you share this data, you must attach the disclaimer set out in paragraph 3(e) of the circular. It states that the data is not verified by PaRRVA, may not be comparable with other IAs or RAs, and that registration with SEBI or enlistment with RAASB is not a guarantee of future returns. RAASB has been directed to specify the template for this data within one month of the circular, in consultation with the Industry Standard Forums and SEBI. Use that template once it is out.
The deadlines that follow PaRRVA
If you want to keep sharing certified past performance, you must enrol with PaRRVA within three months of it becoming operational. If you do not, you lose the right to share certified past performance three months after that date.
The certified data can only cover the period before PaRRVA becomes operational. For any period after that date, you can advertise or share performance only through risk and return metrics verified by PaRRVA.
Two years after PaRRVA becomes operational, the interim route ends. From then on you can show only PaRRVA-verified risk and return metrics, and you cannot use pre-PaRRVA performance in any client communication.
Breaching the circular exposes you to enforcement action, including summary proceedings under Regulation 30A(1)(c) of the SEBI (Intermediaries) Regulations, 2008, which covers claims of return or performance not permitted by SEBI.
“IAs/RAs may provide past performance data certified by a member of ICAI/ICMAI to a client (including prospective client) only on specific request of such client”
Ease of doing business – Interim arrangement for certified past performance of Investment Advisers and Research Analysts prior to operationalisation of Past Risk and Return Verification Agency (“PaRRVA”), paragraph 3(a)
The document
This summary is prepared from the SEBI document linked above. Read the original before you act on it.