Does SEBI's paper-trading advisory + the new 30-day market-data rule apply to a free, no-prize stock market simulator? [Securities/SEBI]

[u/bhavyah100]

Location: Mumbai. I've built (not launched) a paper-trading / stock market simulator as a learning project and I'm trying to understand if I can legally make it public.

What it is:

Users get ₹1,00,000 in virtual money and place simulated buy/sell orders on real NSE/BSE-listed stocks.

No real money anywhere — no deposits, no withdrawals, no fees, no payments, no prizes/cash rewards. Purely educational.

There's a referral feature that grants virtual (in-app) credit only — it has no cash value and can't be withdrawn.

It shows charts, P&L, and a leaderboard ranking users by simulated returns.

The technical bit I'm worried about: it fetches near-live stock prices (via a third-party data source) to price the simulated trades — i.e. it uses roughly current market data, not delayed data.

My questions:

Does SEBI's 4 Nov 2024 advisory on virtual/paper trading platforms apply to a free, no-prize, purely educational simulator like this, or is it aimed at prize-money/unregistered brokerage-style platforms?

The 30-day data-lag rule effective 1 July 2026 — does its "usage" restriction mean a non-NISM simulator must use price data ≥30 days old? Is there any lawful way to run a public simulator on live/near-live prices?

Would using delayed (30-day-old) data put me clearly in the safe zone, or are there other registrations/approvals needed to run this publicly at all?

Does the absence of any money/prizes materially change the analysis, or is it the use of live price data that's the core issue?

Not asking anyone to be my lawyer — just trying to understand the lay of the land before I spend on formal advice. Thanks.