Educators or Advisers? Mapping the Regulatory Void Governing ‘Finfluencers’ in India’s Retail Investment Ecosystem

India’s securities markets are witnessing an unprecedented retail investment boom. The National Stock Exchange accounts for over twenty-four crore unique investor accounts as of November 2025, compared to about four crore demat accounts in FY 2020. A sizeable proportion of these new investors are introduced to the markets by social-media ‘finfluencers’ – persons who give stock-tips, trading advice and portfolio guidance on YouTube, Instagram, Telegram and X but are not registered with the Securities and Exchange Board of India (“SEBI”) as investment advisers or research analysts under the SEBI (Investment Advisers) Regulations, 2013 or the SEBI (Research Analysts) Regulations, 2014. This paper explores the regulatory response to this phenomenon, focusing on the SEBI (Intermediaries) (Amendment) Regulations, 2024 and the clarificatory circular of October 2024 and January 2025 which seek to sever the connection between finfluencers and SEBI-regulated entities. While these notifications address the supply-side engagement with finfluencers, the demand-side connection between finfluencers and retail investors is only indirectly regulated, as most finfluencer content is not provided “for consideration” within the meaning of Regulation 2(1)(m) of the SEBI (Investment Advisers) Regulations, 2013. Through doctrinal and policy-analytical research, this paper examines SEBI’s regulatory perimeter in relation to finfluencers, drawing on statutory text, SEBI board meeting minutes, enforcement orders (including the Rs 546 crore impounding order against Avadhut Sathe in December 2025 and the Rs 17.2 crore order against Mohammad Nasiruddin Ansari, ‘Baap of Chart’), and comparative jurisprudence in the UK (FCA Guidance FG24/1) and the US. The paper concludes that India’s approach to finfluencers is reactive, intermediary-focused and narrowly tailored, and makes several recommendations, including a statutory redefinition of ‘investment advice’, a light-touch registration regime for educational content, mandatory disclosure labelling, and a co-ordinated takedown response by SEBI and the Ministry of Electronics and Information Technology under the Information Technology Rules, 2021.