Research Analyst (RA) advertisements in audio-visual media (television, video, online videos, etc.) have specific requirements for displaying the standard warning. These requirements ensure that the warning is clearly communicated to the audience. This article provides a comprehensive technical analysis of the audio-visual media requirements.
Regulatory Basis
The audio-visual media requirements are specified in the Advertisement Code circular dated April 5, 2023 (SEBI/HO/MIRSD/MIRSD-PoD-2/P/CIR/2023/51).
Audio-Visual Media Requirements
1. Visual Display
Requirement: The standard warning must be displayed in the visual media based advertisement.
Guidelines:
- The warning must be clearly visible
- The warning must be legible
- The warning must be readable
- Minimum 10 font size
2. Voice Over Reiteration
Requirement: The standard warning must be accompanied by a voice over reiteration.
Guidelines:
- The voice over must be clear
- The voice over must be understandable
- The voice over must be audible
- The voice over must accompany the visual display
3. Timing Requirement
Requirement: The standard warning containing 20 words running for at least 10 seconds may be considered as clear and understandable.
Guidelines:
- The warning must be displayed for at least 10 seconds
- The voice over must also run for at least 10 seconds
- The display and voice over must be synchronized
4. Clarity and Understandability
Requirement: Both the visual and the voice over reiteration shall be audible in a clear and understandable manner.
Guidelines:
- The visual warning must be easily readable
- The voice over must be easily heard
- Both must be understandable to the audience
The 10-Second Rule Explained
What is the 10-Second Rule?
The 10-second rule provides that the standard warning, containing 20 words, running for at least 10 seconds may be considered as clear and understandable.
Why 10 Seconds?
- 20 words require adequate time for reading and comprehension
- 10 seconds is considered sufficient for viewing and hearing the warning
- This ensures the warning is not displayed too briefly to be noticed
What 10 Seconds Means
- The visual display must be on screen for at least 10 seconds
- The voice over must be audible for at least 10 seconds
- Both must be synchronized for the entire 10 seconds
- The 10 seconds must be continuous, not fragmented
Implementation Examples
Example 1: 15-Second TV Commercial
Scenario: A 15-second TV commercial.
Implementation:
- Display the standard warning for the full 10 seconds
- Voice over the standard warning for the full 10 seconds
- The warning should be displayed prominently
- The warning should not be in fine print
Example 2: 30-Second Video Advertisement
Scenario: A 30-second video advertisement.
Implementation:
- Display the standard warning for at least 10 seconds
- Voice over the standard warning for at least 10 seconds
- The warning can be at the beginning, middle, or end
- Ensure the warning is clear and understandable
Example 3: Social Media Video
Scenario: A social media video advertisement (e.g., Instagram, YouTube).
Implementation:
- Display the standard warning for at least 10 seconds
- Voice over the standard warning for at least 10 seconds
- The warning should be prominently displayed
- The warning should not be in fine print
Compliance Requirements
1. Visual Warning
| Requirement | Detail |
|---|---|
| Display | On screen |
| Duration | At least 10 seconds |
| Font Size | Minimum 10 |
| Legibility | Clear and readable |
| Placement | Prominent |
2. Voice Over Warning
| Requirement | Detail |
|---|---|
| Voice Over | Accompany visual |
| Duration | At least 10 seconds |
| Clarity | Clear and understandable |
| Audibility | Audible to audience |
| Synchronization | With visual display |
3. Timing
| Requirement | Detail |
|---|---|
| Total Duration | At least 10 seconds |
| Continuous | Not fragmented |
| Synchronized | Visual and audio synchronized |
Common Compliance Gaps
1. Insufficient Duration
Some RAs display the warning for less than 10 seconds.
Solution: Display the warning for at least 10 seconds.
2. No Voice Over
Some RAs display the warning but do not include a voice over.
Solution: Include a voice over reiteration.
3. Inaudible Voice Over
Some RAs have voice overs that are not audible.
Solution: Ensure the voice over is clearly audible.
4. Visual Warning Too Small
Some RAs display the warning in very small font.
Solution: Use at least 10 font size.
5. Warning Not Prominent
Some RAs place the warning in an inconspicuous location.
Solution: Place the warning prominently.
Compliance Checklist
| Requirement | Compliant? |
|---|---|
| Visual warning displayed | ☐ |
| Visual warning at least 10 font size | ☐ |
| Visual warning prominent | ☐ |
| Voice over reiteration included | ☐ |
| Voice over clear and understandable | ☐ |
| Voice over audible | ☐ |
| Visual displayed for at least 10 seconds | ☐ |
| Voice over for at least 10 seconds | ☐ |
| Visual and voice over synchronized | ☐ |
Conclusion and How Anuj Desai & Associates Can Help
Audio-visual media advertisements require specific compliance measures to ensure the standard warning is clearly communicated.
Anuj Desai & Associates offers specialized services to help RAs comply with audio-visual media requirements:
- Review of audio-visual advertisements
- Guidance on warning display and duration
- Assistance with voice over implementation
- Compliance audit and advisory
Contact us today to ensure your audio-visual advertisements comply with SEBI requirements. Our team will review your advertisements and provide a tailored compliance roadmap.
Disclaimer: This article is for informational purposes only and does not constitute legal advice. Readers are advised to consult qualified professionals for legal and compliance matters. Anuj Desai & Associates is a SEBI compliance consulting firm based in India.