Investment Apps
Placing a trade and recommending a trade are two different regulated activities. Each needs its own licence.
Why this is on a data and AI site: an investment app collects identity, income and trading data, which is personal data under the DPDP Act. If SEBI regulates you and you use AI, Regulation 16C of the SEBI (Intermediaries) Regulations makes you solely responsible for that AI's output and the data it uses.
In India, placing a trade and advising on a trade are two different licences.
A discount-broking app is licensed to place orders for its users. It cannot tell them what to buy.
If you give personalised investment recommendations, you need to register with SEBI as an Investment Adviser.
That registration comes with real duties. These are not paperwork.
- Rules about what you can charge.
- A duty to put the client's interests first.
- A duty to keep client money separate from your own.
Am I a Data Fiduciary?
Investment products carry DPDP duties on top of SEBI rules — start with the self-check to see where you sit under DPDP before designing the SEBI-facing overlay.
Run it nowSEBI watches for mixing the two. Putting advice-shaped content or nudges inside an execution-only app is exactly that pattern.
Where you draw this line matters. It shows whether your product respects the licence you hold, or works around it.
This page summarises finance and fintech expectations for orientation. For binding rulings on your product, consult qualified counsel and the primary source below.
The adviser duties described above (fees, fiduciary duty, segregation of client funds) sit in the Investment Advisers Regulations, 2013 — not in the SEBI Act, 1992. We have not yet confirmed a primary-source URL for the Regulations, and we do not link the Act for a claim the Act does not support.
Supports only the claim that SEBI is the statutory regulator and the source of the licensing regime — not the specific adviser duties above. Primary-source URL not yet confirmed.