ISIN-level freezing of promoter holdings during buy-backs permits tendering and pre-existing encumbrance invocation while maintaining the freeze. Promoter and promoter-group holdings, including associates, must be frozen at the ISIN level from approval of a buy-back until closure of the offer. Tendering securities in a tender-offer buy-back and invocation of encumbrances created before the buy-back period remain permitted. Depositories must implement an operational framework covering freeze instructions, ISIN-level modalities, tendering, and invocation or release of pre-existing encumbrances; securities so invoked or released remain frozen. Listed companies and market intermediaries must comply with the framework.