Introduction

On January 6, 2026, SEBI released a consultation paper proposing a revised framework for the sharing and usage of price data for educational and investor awareness activities. The paper seeks to harmonize earlier regulatory positions while addressing concerns raised by stakeholders regarding misuse of market data.

The consultation reflects SEBI’s broader objective of strengthening investor protection without stifling genuine financial education.

Background: Evolution of SEBI’s Framework

May 2024 Circular – Restricting Live Data

To curb the misuse of real-time price data by unregulated online platforms, SEBI prohibited stock exchanges from sharing live price data with third parties.
However, recognizing the importance of investor education, a one-day lag was permitted for educational and awareness activities.

January 2025 Circular – Content-Based Restrictions

Subsequently, SEBI clarified that entities solely engaged in education could use only price data older than three months in their educational content.
The intent was to clearly demarcate education from activities that resemble:

• Investment Advisory (IA)

• Research Analyst (RA)

The Problem with Dual Time Lags

While both circulars operated in different domains — one governing data sharing and the other content usage — their coexistence created challenges:

• A one-day lag was considered too short and susceptible to misuse

• A three-month lag was viewed as excessively long, making education less effective

• Stakeholders found compliance and interpretation cumbersome

SEBI acknowledged these concerns and undertook an internal review.

The Proposed Solution: A 30-Day Uniform Lag

The consultation paper proposes:

• A uniform 30-day lag for:

  • Sharing of price data by MIIs and intermediaries

  • Usage of such data in educational content

• All other prohibitions and conditions under the January 2025 circular to remain unchanged

SEBI believes this strikes a balance between:

• Preventing near-real-time analysis disguised as education

• Allowing educators to use relatively recent market data

Regulatory Rationale

SEBI reiterates a key principle:

Educational activity must not involve analysis of current market data aimed at predicting future prices.

Using live or near-live data inherently moves content into the realm of advice or research, which requires registration and regulatory oversight.

The 30-day buffer is intended to:

• Break the immediacy of trading relevance

• Reduce the incentive for speculative misuse

• Preserve the pedagogical value of market examples

Implications for Educators and Platforms

If finalized, the proposal will:

• Provide greater clarity to educators and institutions

• Require content creators to re-design modules around historical data

• Limit the scope of “market commentary” in educational formats

At the same time, it may enhance the credibility of genuine investor education initiatives.

Call for Public Comments

SEBI has invited public comments on:

1. Whether a 30-day lag is appropriate

2. Whether additional safeguards are required

3. Any other suggestions on the proposed framework

Last date for submission: January 27, 2026

Conclusion

SEBI’s consultation paper reflects a maturing regulatory approach — one that recognizes both the importance of investor education and the risks of regulatory misuse.

The proposed 30-day uniform lag could become a practical middle ground, provided it is supported by clear guidance and effective enforcement.

Stakeholder engagement at this stage will be crucial in shaping a framework that is robust, fair, and future-ready.