Regulatory · 8 min read
SEBI requires mutual fund apps to display specific risk disclaimers, scheme information, and conflict-of-interest disclosures on every product screen. The "Mutual funds are subject to market risk" disclaimer is mandatory but not sufficient — SEBI also mandates expense ratio disclosure, distributor commission transparency, and Scheme Information Document (SID) accessibility. Getting these wrong risks SEBI action against your RIA/ARN registration and your AMC partner relationships.
Any app or platform that facilitates mutual fund investments in India falls under SEBI and AMFI regulations. This includes Registered Investment Advisors (RIAs) operating under SEBI RIA regulations, Mutual Fund Distributors (MFDs) operating under AMFI ARN registration, and execution-only platforms (EOPs) that provide infrastructure without advice. The specific disclosure requirements vary by registration type — RIAs face stricter advice-disclosure requirements than distributors.
If your app is powered by a BSE StarMF or MFU integration, or uses an AMC's API directly, your platform is the regulated entity responsible for user-facing disclosures — not just the AMC.
The most well-known requirement: all mutual fund advertising and product pages must carry the disclaimer "Mutual fund investments are subject to market risks, read all scheme related documents carefully." This must appear in a font size not smaller than the primary text on the page. SEBI specifically prohibits displaying this disclaimer in grey-on-white or otherwise de-emphasized — it must be clearly legible.
Common violation: displaying this disclaimer only in the footer or in a small font at the bottom of a product card. SEBI's guidance expects it to appear on the same screen as investment call-to-actions, not hidden in fine print.
SEBI has strict rules on how scheme performance can be displayed. Returns must be shown for 1-year, 3-year, and 5-year periods (or since inception if the fund is younger). Performance must be compared against the scheme's benchmark — displaying absolute returns without benchmark comparison is non-compliant. Point-to-point returns for lump sum investments and XIRR for SIP investments are the required calculation methods.
SEBI prohibits displaying returns for a period that would be cherry-picked to show the scheme in a flattering light. If you show 3-year returns, you must also show 1-year and 5-year. Trailing returns from a specific date that coincides with a market low is considered misleading and has been specifically cited in SEBI enforcement actions.
Past performance disclaimer: "Past performance may or may not be sustained in future" must appear alongside any performance display — not in the footer but adjacent to the performance numbers.
SEBI's Direct vs Regular plan framework requires apps to clearly communicate the difference when both options are available. If your platform earns commission from Regular plans, this must be disclosed to users — SEBI prohibits recommending Regular plans without disclosing the commission relationship. The specific language required: "We earn a commission from [AMC name] when you invest in the Regular plan of this scheme."
Expense ratio must be displayed on the scheme product page. The Total Expense Ratio (TER) — not just the management fee — is what's required. Many apps display the "fund manager fee" which is lower than TER; this is non-compliant. TER for Direct plans must also be compared to Regular plan TER if both are offered, so users understand the cost difference.
The SID (Scheme Information Document) and SAI (Statement of Additional Information) for every scheme must be accessible within one click from the scheme's product page. A broken link or a link that navigates through multiple pages to reach the SID violates this requirement. SEBI inspections specifically check link accessibility.
KIM (Key Information Memorandum) must be displayed before investment, not just in the documents section. For SIP mandates specifically, SEBI requires the mandate amount, frequency, and cancellation terms to be displayed clearly before the user confirms.
If your platform is registered as an RIA (Registered Investment Advisor), you must prominently disclose your fee structure to users before providing any advice. SEBI mandates this be a formal disclosure document that users must acknowledge — not just a footer mention. The disclosure must state whether you are paid by the user (fee-only model) or by AMCs (commission model), and if both, the nature of each.
RIAs cannot earn distribution commission — this is a hard regulatory line. An RIA platform that recommends Regular plans and earns commission is violating SEBI RIA regulations. Many platforms operate in a grey zone here; SEBI enforcement has become stricter since 2023.
The instinct is to bury disclosures to protect conversion — smaller text, footer placement, grey-on-white. This is both legally risky and strategically wrong. Research across investment platforms consistently shows that transparent disclosure of fees and risks increases long-term user trust and reduces support volume from users who feel misled after losses. Groww's direct-plan-first approach, with clear expense ratio display, contributed to their trust positioning — not hurt it.
Design approach: treat mandatory disclosures as trust-building elements rather than legal boilerplate. "We're SEBI Registered (INA000000000)" prominently placed is a trust signal. "Total cost of investing: ₹83/year on ₹1 lakh investment" is more trustworthy than hiding the TER. Transparent = trustworthy in a category where users have been burned by mis-selling.
No. Commission disclosure requirements apply only when your platform earns distribution commission from AMCs — which happens only on Regular plans. A direct-plan-only platform has no commission relationship to disclose, which actually simplifies compliance and strengthens trust positioning. SEBI's Direct plan framework was specifically designed to create this incentive for platforms to prefer direct plans.
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