Implementation of past performance certification prior to PaRRVA operationalisation


As per SEBI guidelines regarding certification of past performance data of IAs/RAs prior to operationalisation of Past Risk and Return Verification Agency (“PaRRVA”):

  • All past performance data provided to clients must be certified by a member of ICAI/ICMAI

  • Such past performance data shall be communicated to clients only on specific request of such client, on a one-to-one basis


To comply with these requirements:

  1. All managers need to necessarily opt in to a certification workflow from the Publisher Platform. For the same, 2 options are being provided:

  • Certification via CAs empanelled with the publisher platform: As a part of this technology solution, empanelled CAs will validate and certify the performance of each of the smallcases of the manager. CA certificates for each portfolio/smallcase will be appended to the respective factsheets and portfolio reports.  . 

  • Self-validation workflow: In this workflow, managers would need to get the past performance certified by themselves and upload the verified index series and certificates for your smallcases using the publisher platform. The index series and the certificate shared by you will be appended to the factsheet and portfolio reports. .


PLEASE NOTE: 

  • The last date to opt in to any of the provided validation workflow is 26 December, 2025. Please opt in to avoid getting your smallcases blocked. Also, such smallcases will not be available to users on the smallcase app, broker platforms and smallcase website.

  • Once you opt in to any of the provided workflows, you will NOT be allowed to switch or opt out at a later stage


  1. As you are already aware that users need to provide the consent on your respective websites before accessing the returns. The copy and disclosures included in this consent have already been updated in line with the SEBI circular. Please find a screenshot of the same at the bottom of the help article.  


Please go through the below sections to get more details on the above points.


Selecting a Performance Validation Workflow

Option 1: Opt in to certification via CAs empanelled with the publisher platform

  • Performance of all your active model portfolios (i.e., portfolios that are not played-out) will be continuously verified and relevant certificates will be generated  once every 2 weeks by empanelled CAs 

  • Such certificates will be appended to factsheets and Portfolio Reports, through which users will be able to access the same


User-facing impact:

  • Users will continue to see the past performance after providing the consent. (same as current implementation)


Pricing details:

  • A Service Fee would be charged every time a verification is performed (defined as verification cycle) and certificate(s) for the same are issued by the CAs. 

  • For each Verification Cycle, the fee will be calculated in the following manner: Number of portfolios * INR 200, subject to a minimum fee of INR 500.

  • The pricing has been decided to pass on the CA charges approximately on actual basis

  • Example to understand pricing: 

    

Number of active portfolios at the time of verification cycle

Total cost to Manager per verification cycle

Total Cost to Manager per month (2 verification cycles per month)

2 active portfolios 

Max (No. of active portfolios*200, 500)
= Max (2*200, 500) = INR 500 for all portfolios

Monthly cost = 500 *2 = INR 1000 for all portfolios 

4 active portfolios 

Max (4*200, 500) = INR 800 for all portfolios

Monthly cost = INR 800*2 = INR 1600 for all portfolios

6 active portfolios

Max (6*200, 500) = INR 1200 for all portfolios

Monthly cost = INR 1200*2 = INR 2400 for all portfolios



To opt in to this workflow, you will be required to consent to:

  • Terms and Conditions for availing the technology services by the publisher platform 

  • Representations and Terms and Conditions of each CA


The steps to opt in to this are provided below:


  1. Log in to the Publisher Platform

  2. Navigate to Profile -> Compliance -> Select Performance Validation Workflow


  1. Select the option “Opt in to CPPL workflow” and click on Save Details


  1. You will now be asked to consent to the terms and conditions for availing the technology services and representations + T&Cs for each CA. Please go through the same. You can go ahead and process the consent by selecting the checkbox and pressing “Continue”

           


  1. Once saved, your workflow opt-in will be recorded in our system.

Option 2: Opting in to self-validation workflow

In this workflow, you can get the performance validated for your smallcases by partnering with CA/CMAs of your choice. In case you opt in to this, a self-validation workflow will be provided on the Publisher Platform to you.

  • You can upload the CA/CMA validated index series, returns & certificates for each of your active smallcases at regular interval, defined by you

  • The index series & returns will be updated across smallcase properties, factsheet & Portfolio Reports as per the latest provided values by you

  • The latest CA/CMA certificate will also be appended to the Factsheet and Portfolio Reports 


We will be providing more details about this workflow and how to use it later. 


Important to note : 

  • In case you opt in to this workflow, your smallcases will no longer be listed on smallcase app and website 8 January onwards. Your smallcases will continue to be listed & visible to users on your microsite and broker platforms.

  • In case you do not provide a validated index series and certificate for a smallcase by 8 January, your smallcases will be BLOCKED. Post providing the validated index series and certificate, you will be allowed to change the smallcase state.


User-facing impact:

  • Users on the smallcase app & website will no longer be able to search or discover your smallcases on the smallcase app and website from 8 January onwards. Your smallcases will continue to be searchable & visible to users on your microsite and broker platforms.

  • In case you do not provide a validated index series and certificate for a smallcase by 8 January, your smallcases will be BLOCKED. Hence, no new subscriptions will be possible in these smallcases. Post providing the validated index series and certificate, you will be allowed to change the smallcase state.

  • Users will be able to see performance graph as well as returns as per the last validated index series provided by you for a portfolio


The steps to opt in to the self-validation workflow are provided below:


  1. Log in to the Publisher Platform

  2. Navigate to Profile -> Compliance -> Select Performance Validation Workflow

  1. Select the option “Opt in to self-validation workflow” and click on Save Details


  1. You will now be shown some important points regarding the self-validation workflow. Please go through them, select the checkbox and click on Continue

 

  1. Once saved, your workflow opt in will be recorded in our system


Updated Consent Disclosures

On your microsites, consent disclosure and copy have already been updated in line with the SEBI guidelines. PFA the screenshot.