SEBI Common Advertisement Code – Reflection 3 | Who Owns a Virtual Celebrity?

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 Published: 10 July 2026

By Nayakanti Prashant

3rd Gen Banker & Citizen Lobbyist – Bengaluru

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Can a virtual character become a celebrity?

SEBI says yes.

The next question is:

Who owns that virtual celebrity?


The Print Media has an expiry date, The Digital Media doesn’t have an expiry date

A few days ago, while reading SEBI's Consultation Paper on the proposed Common Advertisement Code (CAC), one provision immediately stood out.

 

Under Clause 7(2)(vii), SEBI proposes to recognise virtual characters—fictional computer-generated people or avatars with realistic human characteristics and the ability to influence their audience—as celebrities.

It is perhaps one of the most forward-looking provisions in the entire consultation paper because it recognises that influence in the digital era is no longer limited to human beings.

 

Recognition is an important first step.

Ownership may be the next conversation.

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Digital Trust Reflection 3 of 4

Consultation Paper Focus

• Section 6(A) – Celebrity Endorsements

• Section 7 – Proposed Common Advertisement Code

• Clause 7(2)(vii) – Virtual Characters

• Clause 7(6) – Celebrity Advertisements

 

Previous Reflections

• Reflection 1 – Who is a Celebrity?

• Reflection 2 – The Contract Ends. The Internet Remembers.

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Imagine this...

January 2026.

A familiar journey begins.

A virtual celebrity appears in an advertisement for Regulated Entity A. The campaign becomes popular.

The face becomes familiar.

Life moves on.

May 2026.

 

Something feels different.

Another advertisement appears.

The same virtual celebrity.

The same smile.

The same reassuring voice.

But this time...

it represents Regulated Entity B.

The investor pauses.

"Haven't I seen this virtual celebrity before?"

"Wasn't it associated with another regulated entity?"

For a brief moment...

recognition and uncertainty arrive together.

the face is familiar.

The association isn't.

Trust Hesitates

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Unlike a human celebrity, a virtual celebrity may involve multiple participants.

A creative agency.

An AI platform.

A technology provider.

A regulated entity.

A licensing agreement.

 

Yet...

from the investor's perspective...

none of that is visible.

The investor remembers only one thing.

The familiar digital face.

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A Reflection

 

SEBI's proposal rightly recognises that virtual characters are capable of influencing audiences and therefore deserve regulatory recognition. :

 

The consultation paper also proposes that celebrity endorsements should remain at the brand or entity level while avoiding endorsements of specific products or services, thereby balancing legitimate marketing objectives with investor protection.

 

As I reflected on these proposals, another question quietly emerged.

If a virtual celebrity can represent one regulated entity today...

and another tomorrow...

should investors also have greater transparency regarding who controls that digital identity?

 

Not because investors need to understand Artificial Intelligence.

But because they deserve clarity about the digital identities that seek to earn their trust.

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Conclusion

Reflection 1 asked...

Who is a Celebrity?

Reflection 2 asked...

When Does a Celebrity Endorsement Really End?

Perhaps Reflection 3 asks another equally important question.

Who Owns a Virtual Celebrity?

 

As virtual personalities become an integral part of digital communication, trust may increasingly depend not only on what investors see, but also on how clearly digital identities are governed over time.

Perhaps that is also one of the broader ideas behind **The Joy of Digital Transactions Day (April 11).**

Every trusted digital transaction begins with a trusted digital interaction.

And every trusted digital interaction deserves transparency, continuity and accountability.

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Next Reflection

 

Reflection 4

 

Can Technology Govern the Digital Trust Lifecycle?

 

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Disclaimer: -

 

These are the author's personal reflections on SEBI's Consultation Paper on the proposed Common Advertisement Code for Specified SEBI Regulated Entities.

They are intended to contribute constructively to the ongoing public consultation.

The proposals discussed remain under consultation and do not represent SEBI's final regulatory position.

The ultimate destination is April 11 – Digital Transactions Day.

The journey with this SEBI Consultation paper adds to the overall journey experience.  

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The Joy of Digital Transactions

Nayakanti Prashant
3rd Gen Banker & Citizen Lobbyist – Bengaluru
Advocating Digital Transactions Day (April 11)

 

Author’s Blogs

https://prashantrandomthoughts.blogspot.com
https://prashantnepayments.blogspot.com
https://innovationinbanking.blogspot.com

 

 


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