CIRCULAR
HO/38/12/11(1)2025-MIRSD-POD/ I/73/2025 October 30, 2025
To,
All Registered Investment Advisers
All Registered Research Analysts
Investment Adviser Administration and Supervisory Body (IAASB)
Research Analyst Administration and Supervisory Body (RAASB)
Madam / Sir,
Sub: 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”)
1. SEBI, vide circular dated April 4, 2025, specified the framework for creation and
operationalization of PaRRVA in order to address the demand of Investment
Advisers (“IAs”) and Research Analysts(“RAs”) to display their performance.
PaRRVA will carry out the verification activities prospectively for the period post
on-boarding of the IAs/RAs with PaRRVA
2. SEBI has received representations from the Industry associations of IAs/RAs to
facilitate IAs/RAs to communicate past performance data to clients for the period
prior to operationalisation of PaRRVA.
3. Considering the representation of the industry, as an interim arrangement, the
following has been decided:
a) 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;
b) Such past performance data shall be communicated to clients (including
prospective clients) on a one-to-one basis and such past performance data
shall not be made available to general public through public media/website
of IA/RA or any other mode.
c) IAs/RAs who wish to communicate certified past performance data to clients
(including prospective clients) must enrol with PaRRVA within three months
of its operationalization, else such IAs/RAs will not be able to communicate
certified past performance data to clients post three months from the date
of operationalization of PaRRVA.
d) The applicable period for such past performance data shall be prior to the
date of operationalization of PaRRVA. Accordingly, the performance for the
period subsequent to the date of operationalisation of PaRRVA shall only
be advertised or provided to client using risk and return metrics verified by
PaRRVA.
e) Any communication of such past performance data shall be accompanied
with the following disclaimer:
“The performance data presented herein are not verified by Past Risk and
Return Verification Agency (PaRRVA) or any other agency recognized by
SEBI for this purpose. The performance data presented herein may not be
comparable to performance data of any other IA/ RA. Computation of the
performance may vary across the industry. Users are requested to apply
their due diligence before making investment decisions on the basis of the
given past performance data. Past performance is no guarantee of future
results. Investment in securities is subject to market risk. Registration with
SEBI or enlistment with IAASB or RAASB (as the case may be) is not a
guarantee or assurance of future returns. ”
f) After two years from the date of operationalisation of PaRRVA, IAs/RAs will
be permitted to communicate/display only PaRRVA verified risk and return
metrics and will not be permitted to use past performance data related to
the period prior to the date of operationalisation of PaRRVA, in any
communication to clients (including prospective clients).
4. IAASB/RAASB is hereby directed to specify the templates in which the certified
past performance data shall be communicated, within one month of the date of this
Circular, in consultation with Industry Standard Forums for IAs and RAs and SEBI.
5. It may be noted that contravention of the provisions of this circular will make an
entity liable for enforcement actions, including summary proceedings “under
Regulation 30A.(1)( c) of SEBI(Intermediaries) Regulations, 2008 which states that
a person found to have made claim(s) of return or performance in respect
of or related to a security or securities, unless otherwise permitted by the Board to
make such claim(s) shall be liable for summary proceedings.
6. This circular is issued in exercise of powers conferred under Section 11(1) of
Chapter IV of the Securities and Exchange Board of India Act, 1992 and Regulation
30A of the SEBI (Intermediaries) Regulations, 2008, to protect the interests of
investors in securities and to promote the development of, and to regulate the
securities markets.
7. This circular is available on SEBI website at www.sebi.gov.in under the category:
‘Legal → Circulars.
Yours faithfully,
Aradhana Verma
General Manager
Tel. No. 022-26449633
E-mail: aradhanad@sebi.gov.in