The Securities and Exchange Board of India (SEBI) has issued a significant regulatory circular vide Circular No. HO/47/17/12(11)2025-MRD-POD3/I/11107/2026 dated May 08, 2026, prescribing unified and revised norms for the sharing and usage of market price data for educational purposes. This circular brings much-needed consistency to a regulatory framework that had been operating under two conflicting time-lag requirements — a one-day lag for sharing data (May 2024 circular) and a three-month lag for using that same data in educational content (January 2025 circular). Acting on stakeholder feedback and the outcome of a public consultation process, SEBI has now replaced both with a single uniform 30-day lag applicable to both sharing and usage. The circular also carves out a special one-day access window for NISM for use exclusively in its simulation lab. The provisions take effect from July 01, 2026.
🔴 Key Action — Effective July 01, 2026
Uniform 30-day lag now applies for both sharing and usage of market price data for investor education and awareness activities. The one-day sharing lag (May 2024 circular) and the three-month usage lag (January 2025 circular) both stand modified. NISM retains a one-day access privilege for its simulation lab only. Legal agreements with audit trail provisions are mandatory for all data-sharing arrangements.
| Detail | Information |
|---|---|
| Circular Number | HO/47/17/12(11)2025-MRD-POD3/I/11107/2026 |
| Date | May 08, 2026 |
| Issued To | All Recognised Stock Exchanges, Clearing Corporations, Depositories, Registered Intermediaries, BSE Limited (IAASB/RAASB) |
| Effective Date | July 01, 2026 |
| Modifies | Para 2(iii) & 2(iv) of Circular dated May 24, 2024 + Q.8 FAQ of Circular dated January 29, 2025 |
| Key Change | Sharing lag: 1 day → 30 days | Usage lag: 3 months → 30 days | NISM: retains 1-day for simulation lab |
| Legal Authority | Section 11(1) SEBI Act, 1992 | Regulation 51, SECC Regulations 2018 | Section 26(3), Depositories Act 1996 | Regulation 97, SEBI (Depositories & Participants) Regulations 2018 |
| Signed By | Hruda Ranjan Sahoo, General Manager, SEBI (Tel: 022-26449586) |
📖 Section 1 — Background: The Two-Circular Problem That Needed Fixing
The story behind this circular begins in May 2024, when SEBI was grappling with a growing concern: online gaming platforms, mobile apps, and websites were using real-time market price data of listed companies for purposes that had nothing to do with genuine investor education. In response, SEBI issued Circular No. SEBI/HO/MRD/MRD-PoD-3/P/CIR/2024/56 dated May 24, 2024, which barred Market Infrastructure Institutions (MIIs) — comprising all recognised Stock Exchanges, Clearing Corporations, and Depositories — and registered market intermediaries from sharing real-time price data with any third party, except where required for the orderly functioning of the securities market or for fulfilling regulatory requirements. A limited carve-out allowed price data to be shared for investor education and awareness activities, but only with a minimum one-day lag.
Then, in January 2025, SEBI issued a second circular — Circular No. SEBI/HO/MIRSD/MIRSD-PoD-1/P/CIR/2025/11 dated January 29, 2025 — which introduced a sharper content-level restriction: entities solely engaged in education could only use price data that was at least three months old in their content, classes, videos, and communications. This circular operated at a different level than the May 2024 one — the first governed sharing by MIIs; the second governed usage by educators.
⚠️ The Conflict — Why Two Circulars Caused Confusion
Under the dual framework: an MII could share price data with an educator with just a one-day lag — but that educator could only use data that was three months old in their content. This meant educators were receiving near-current data they legally couldn't use, and the mismatch between the two standards created ambiguity for both data providers and educators about what was actually permissible.
🔍 Section 2 — What Triggered This Change? The Road to 30 Days
Stakeholder feedback began flowing in from both sides of the debate. On one side, market participants flagged that the one-day lag was dangerously short — near-real-time data in the hands of educators could be misused to function as de facto investment advice or research, blurring the regulatory boundary between pure education and regulated advisory activity. On the other side, educators argued that the three-month lag rendered data educationally stale — a three-month-old market event is difficult to teach about meaningfully when the underlying market conditions have completely changed.
SEBI Chairman Tuhin Kanta Pandey publicly acknowledged the "inconsistency" in December 2025 and indicated that corrective action was imminent. On January 6, 2026, SEBI issued a formal consultation paper proposing a uniform 30-day lag, inviting public comments until January 27, 2026. The paper explained that using live or near-live data in educational content effectively crosses into investment advisory or research analyst territory — since analyzing current prices to draw conclusions about future prices is, by definition, regulated activity. After reviewing the public responses, SEBI finalised the 30-day norm, and this May 08, 2026 circular is the formal outcome.
✅ Why 30 Days? The Regulatory Logic
A 30-day lag is long enough that the data cannot be used to generate meaningful, actionable trading signals (preventing misuse as advice), yet recent enough to remain pedagogically relevant — market events from a month ago are still recognisable and teachable. SEBI's internal deliberations concluded that 30 days "suffices the purpose of protecting against misuse of exchange data as well as keeping the education content relevant."
📋 Section 3 — What the New Circular Prescribes: The 3 Key Changes
Change 1 — 30-Day Sharing Lag for Educational Data: MIIs (Stock Exchanges, Clearing Corporations, Depositories) and registered market intermediaries may now share market price data for investor education and awareness activities only with a lag of thirty days, provided no monetary incentive is offered to participants. The requirement for a formal legal agreement between the data provider and the recipient entity continues — and must now specifically include provisions for audit trail maintenance to track how the shared data is used, enabling enforcement action in case of misuse.
Change 2 — 30-Day Usage Lag for Educational Content: Entities solely engaged in education must not use market price data from the preceding thirty days to speak, display, reference, or name any security — including by code name — in their talks, speeches, videos, tickers, or screen shares, if such reference carries any implication of future price movement, advice, or recommendation. This replaces the earlier three-month threshold and brings usage norms in sync with sharing norms.
Change 3 — NISM Special Carve-Out: The National Institute of Securities Markets (NISM) — SEBI's own capacity-building arm — has been granted a dedicated exception. NISM may receive and use market price data with a lag of only one day, but exclusively for use in its simulation lab. This carve-out does not extend to NISM's other educational programmes, publications, or research outputs — it is strictly limited to the simulation environment used for hands-on trader and intermediary training.
📊 At a Glance — Before vs After
| Parameter | 🔴 Before (Old Rule) | 🟢 After (New Rule) |
|---|---|---|
| Sharing lag (MII → Educator) | 1 day (May 2024 circular) | 30 days |
| Usage lag (Educator → Content) | 3 months (Jan 2025 circular) | 30 days |
| NISM simulation lab access | Not specifically addressed | 1 day (special carve-out) |
| Legal agreement requirement | Required | Required + audit trail mandatory |
| Effective date | — | July 01, 2026 |
🎓 Section 4 — The NISM Carve-Out: Why NISM Gets Special Treatment
NISM — the National Institute of Securities Markets — is a public trust set up by SEBI as its dedicated capacity-building arm for the securities market, with the specific mandate of creating a pan-India securities education ecosystem. Its role is not merely academic — it delivers SEBI-mandated certification programmes that market intermediaries (stockbrokers, mutual fund distributors, research analysts, investment advisers, depository participants) must pass before being allowed to operate. NISM also trains SEBI's own officers.
Its simulation lab in particular requires near-current market data because it is designed to replicate real trading conditions. A simulation running on 30-day-old data cannot teach traders and intermediaries how to respond to current market microstructure, order flow dynamics, or volatility patterns — defeating the purpose of a simulation. The circular recognises this specific operational need and grants NISM a one-day lag exclusively for simulation lab use, making clear this exception does not create a precedent for other institutions.
💡 What Counts as NISM's Simulation Lab?
The carve-out is strictly limited to NISM's simulation lab. NISM cannot use the one-day privilege for its classroom courses, online programmes, certificate examinations, or published study materials. Those must comply with the standard 30-day lag. Only the controlled simulation environment — where students practise trading in a sandboxed replication of live markets — qualifies for the one-day exception.
📜 Section 5 — Amended Provisions in Detail
Amendment to Circular dated May 24, 2024: Paragraphs 2(iii) and 2(iv) of Circular No. SEBI/HO/MRD/MRD-PoD3/P/CIR/2024/56 stand modified. The revised Para 2(iii) now reads that market price data may be shared for investor education and awareness activities — without monetary incentive — with a lag of thirty days, with a carve-out for NISM's simulation lab at one day. The revised Para 2(iv) requires MIIs and market intermediaries to exercise due diligence, and the legal agreement must include provisions preventing misuse including maintenance of an audit trail for data usage.
Amendment to Circular dated January 29, 2025: Question No. 8 of the FAQ at Annexure-A of Circular No. SEBI/HO/MIRSD/MIRSD-PoD-1/P/CIR/2025/11 — which distinguishes "education" from "advice/recommendation" — stands modified. The revised answer clarifies that an entity solely engaged in education must not use market price data from the preceding thirty days (down from three months) to name or display any security in a manner indicating future price, advice, or recommendation. The NISM simulation lab exception is reiterated here as well.
👥 Section 6 — Who Is Affected? Impact by Category
| Entity | Impact | Action Required |
|---|---|---|
| Stock Exchanges / MIIs | Must apply 30-day minimum lag when sharing price data for any educational/awareness purpose | Update data-sharing agreements and access policies; implement technical controls to enforce 30-day lag |
| Market Intermediaries (Brokers, DPs, etc.) | Cannot share price data for educational use with less than 30-day lag; must maintain audit trail | Review and update existing data-sharing arrangements; ensure legal agreements include audit trail provision |
| Financial Educators / Trading Academies | Cannot use any price data younger than 30 days in educational content — significant reduction from prior 3-month threshold | Update content pipelines; ensure no security is named/displayed with data less than 30 days old in any video, ticker, or screen share |
| Finfluencers / Online Educators | High impact — 30-day rule is the bright line between permissible education and regulated advisory activity | Immediate content audit; discuss any security by name only using data older than 30 days or face potential enforcement |
| NISM | Positive — retains one-day data access for simulation lab | Ensure one-day access is strictly limited to simulation lab infrastructure; all other programmes must comply with 30-day norm |
| Retail Investors | Indirect — educational content they consume will be based on data at least 30 days old, but quality of education is better aligned with regulatory intent | No action needed; continue accessing education from SEBI-compliant platforms |
📅 Section 7 — Complete Regulatory Timeline
May 24, 2024
SEBI Circular on Real-Time Price Data Sharing (First Circular)
MIIs and market intermediaries barred from sharing real-time data with third parties except for market functioning or regulatory compliance. Educational sharing permitted with a one-day minimum lag. Legal agreement mandatory. Aimed at curbing proliferation of gaming platforms using live market data.
January 29, 2025
SEBI Circular on Prohibited Activities — 3-Month Usage Lag (Second Circular)
Entities solely engaged in education restricted to using price data that is at least three months old in their educational content. Introduced to prevent educational content from being used as a vehicle for investment advice. FAQ No. 8 explains the distinction between education and advisory activity.
December 2025
SEBI Order Against Avadhut Sathe — ₹546 Crore Impounded
SEBI passes a landmark order against financial influencer Avadhut Sathe, impounding approximately ₹546.16 crore earned through his trading academy (ASTAPL), for using live market data to provide de facto investment advice while claiming to be purely educational. SEBI Chairman publicly acknowledges "inconsistency" in the two-circular framework.
January 6, 2026
SEBI Issues Consultation Paper — 30-Day Lag Proposed
SEBI issues a formal consultation paper proposing a uniform 30-day lag for both sharing and usage of price data for educational purposes. Public comments invited until January 27, 2026. Proposal explains that near-live data usage blurs the line between education and regulated advisory activity.
January 27, 2026
Public Consultation Closes
Deadline for submission of public comments on the 30-day lag proposal. SEBI receives stakeholder feedback from educators, MIIs, intermediaries, and investor associations. Majority support the balancing rationale — though some educators requested a shorter lag and some investor advocates pushed for a longer one.
May 08, 2026
Final Circular Issued — 30-Day Lag Made Law
SEBI issues Circular No. HO/47/17/12(11)2025-MRD-POD3/I/11107/2026 formalising the 30-day lag for both sharing and usage. NISM simulation lab receives one-day carve-out. Both prior circulars (May 2024 and January 2025) are partially modified. Effective July 01, 2026. MIIs directed to implement systems, amend bye-laws, and disseminate to market participants.
⚡ Section 8 — The Finfluencer Connection: Why This Circular Matters Beyond the Text
This circular cannot be read in isolation from SEBI's broader campaign against unregistered financial influencers ("finfluencers") — online creators who use near-real-time stock data to provide what is effectively investment advice under the guise of education. The core regulatory challenge is that India's securities laws require specific SEBI registration (as an Investment Adviser or Research Analyst) to provide investment advice or research. But tens of thousands of YouTube channels, Telegram groups, and social media profiles do exactly that — while calling it "education."
The 30-day rule creates a clear, bright-line enforcement test: if any content names or displays a security using data less than 30 days old in a manner that implies future price direction, that content is presumptively advisory — not educational — and the creator must be registered. Conversely, content using data older than 30 days, without indicating future prices or giving advice, falls within the permissible educational zone. This is a significant compliance clarification for the thousands of financial educators currently operating in the grey zone.
🚨 Enforcement Risk — What Is Now Clearly Prohibited
Any content — video, live session, screen share, ticker, or social media post — that: (a) names or displays a specific security using price data from the last 30 days, AND (b) carries any indication of future price, buy/sell direction, or investment recommendation — is now squarely in regulated territory. Publishing such content without SEBI registration as an Investment Adviser or Research Analyst exposes the creator to SEBI enforcement, penalties, and potential impounding of earnings.
⚙️ Section 9 — Obligations on MIIs: What They Must Do by July 01, 2026
All Market Infrastructure Institutions have been specifically directed to take three categories of action ahead of the July 01, 2026 effective date. First, they must put in place the necessary systems to implement the revised data-sharing norms — including technical controls to enforce the 30-day lag on educational data feeds and separate, more privileged access for NISM's simulation lab. Second, they must make necessary amendments to their bye-laws, rules, and regulations wherever required to formalise the new standards into their governing frameworks. Third, they must bring these provisions to the notice of all market participants, including investors, and publish the circular on their websites.
❓ Section 10 — Frequently Asked Questions
📝 Bottom Line — Key Takeaways
✅ 30-day is the new standard — both sharing and usage of price data for educational purposes must observe a 30-day lag from July 01, 2026.
✅ NISM's simulation lab retains a one-day privilege — no other entity qualifies for this exception.
✅ Legal agreements are mandatory — and must now include an audit trail provision for data usage.
✅ For educators and finfluencers — using any stock's price data younger than 30 days in content that implies price direction = regulatory risk. Ensure compliance or seek IA/RA registration.
✅ For MIIs and intermediaries — update your data-sharing agreements, implement 30-day controls, amend bye-laws, and publish the circular on your website before July 01, 2026.
✅ Broader enforcement signal — this circular complements SEBI's wider finfluencer crackdown. The 30-day rule is now the legal bright line between permissible education and regulated advisory activity.
Source: SEBI Circular No. HO/47/17/12(11)2025-MRD-POD3/I/11107/2026 dated May 08, 2026 — Norms for sharing and usage of price data for educational purposes | SEBI Circular SEBI/HO/MRD/MRD-PoD-3/P/CIR/2024/56 dated May 24, 2024 | SEBI Circular SEBI/HO/MIRSD/MIRSD-PoD-1/P/CIR/2025/11 dated January 29, 2025. Available at sebi.gov.in under Legal Framework – Circulars. This article is for informational purposes only and does not constitute legal or investment advice.
