Two way fungibility of IDRs required with prescribed procedures, disclosure of headroom, and structured conversion windows. Listed issuers of IDRs must file a specified quarterly holding pattern disclosing distribution of IDR holders and underlying equity represented, and must disclose on their website. Issuers must provide comparative corporate governance analysis for home and other listing jurisdictions using SEBI formats. Two way fungibility between IDRs and underlying shares is required subject to available headroom and procedural rules governing timing, fungibility windows, proportional allocation, retail reservation, disclosure of headroom and conversion transactions, and cost limits for sale proceeds conversions.