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Circulars
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Extension of timelines and Update of reporting authority for IAs and RAs w.r.t. SEBI Circular for Compliance to Digital Accessibility Circular ‘Rights of Persons with Disabilities Act, 2016 and rules made thereunder- mandatory compliance by all Regulated Entities’ dated July 31, 2025
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Digital accessibility compliance: timelines extended and reporting authority updated for investment advisors and research analysts.
Regulated Entities must submit compliance/action reports and platform lists, appoint IAAP-certified accessibility auditors, conduct accessibility audits, remediate audit findings, and submit annual audit confirmations within revised timelines; reporting authority for Investment Advisors and Research Analysts is changed to BSE Ltd., while brokers/depository participants report to exchanges/depositories and other entities report to the regulator.
Technical Clarifications to Cybersecurity and Cyber Resilience Framework (CSCRF) for SEBI Regulated Entities (REs)
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Cybersecurity and Cyber Resilience Framework: SEBI clarifies scope, equivalence/exclusivity principles and reporting obligations for regulated entities.
SEBI clarifies CSCRF scope and compliance: REs must apply either the Principle of Exclusivity for systems used solely for SEBI activities or the Principle of Equivalence where primary regulator frameworks provide equivalent controls; REs must demonstrate which principle is relied upon and SEBI reserves the right to verify compliance submissions made to other regulators.
Relaxation in timeline to submit net worth certificate by Stock Brokers to offer margin trading facility to their clients
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Relaxation of net worth certificate timelines for stock brokers aligns submissions with financial results reporting timelines.
Brokers offering the margin trading facility must submit a half yearly auditor certificate confirming net worth as on 31 March and 30 September within the newly harmonised post period deadlines; stock exchanges must amend bye laws, notify members and disseminate the change for immediate implementation under SEBI's regulatory powers.
Extension of timeline for implementation of SEBI Circular ‘Margin obligations to be given by way of pledge/Re-pledge in the Depository System’ dated June 03, 2025
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Margin pledge implementation timeline extended to ensure system readiness and compliance by market infrastructures and participants.
Implementation of the circular requiring margins to be given by way of pledge/re-pledge in the depository system is extended from the original effective date to October 10, 2025 to permit depositories to complete system development and testing. Stock Exchanges, Depositories and Clearing Corporations must notify members, publish the circular, implement systems and procedures to ensure compliance, and amend bye-laws, rules and regulations to effect the change; the circular is issued under statutory regulatory powers to protect investors and regulate the securities markets.
Master Circular for Debenture Trustees
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Debenture trustees: SEBI consolidates rules on registration, due diligence, security monitoring, defaults and investor protections.
SEBI's Master Circular for Debenture Trustees consolidates regulatory requirements: online registration, prior approval for change in control, and board accountability; detailed due diligence duties at appointment and security creation including independent verification, standardized due diligence certificates, and retention of records; mandatory creation, registration and trustee validation of charges before listing; use of a centralised Security and Covenant Monitoring System for asset, covenant and payment tracking with unique Asset IDs; periodic security cover certification and valuation; Recovery Expense Fund mechanics for enforcement expenses; structured investor consent and meeting procedures on default; comprehensive disclosure, reporting, grievance redress and outsourcing/conflict management obligations.
Transaction charges paid to Mutual Fund Distributors
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Distributor remuneration: SEBI removes prescribed transaction charges requirement, allowing AMCs to remunerate distributors at their discretion.
The circular deletes the Master Circular provisions prescribing transaction charges and the minimum subscription condition for distributor remuneration, allowing AMCs discretion to remunerate distributors; the deletions take immediate effect and the measure is issued under SEBI's regulatory powers to protect investors and regulate the securities market.
Review of Framework for conversion of Private Listed InvIT into Public InvIT
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Conversion framework for private listed InvITs aligned with follow-on offer requirements and sponsor unitholding and lock-in obligations.
The circular revises the conversion framework so sponsor(s) and sponsor group(s) must maintain the minimum unitholding specified in Regulation 12(3) and 12(3A) at all times and the lock-in shall follow Regulation 12(5). It also aligns procedure and disclosure for the public issue converting a private listed InvIT with follow-on offer requirements under the InvIT Regulations, substituting terminology and requiring compliance with follow-on offer disclosures and procedures.
Ease of doing business (EODB) - Policy for joint annual inspection by MIIs – information sharing mechanism– action by Lead MII
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Joint annual inspection regime for multi-registered market entities to streamline oversight and enable shared enforcement action.
SEBI mandates a joint annual inspection regime where entities with multiple MII registrations are inspected jointly by all relevant MIIs, with Depositories and Clearing Corporations handling DP and clearing activities respectively, and one MII designated as Lead MII to initiate enforcement action. MIIs must establish an information sharing mechanism, adopt a joint SOP detailing inspection criteria and procedures, retain the ability to conduct special purpose inspections based on triggers, and revise bylaws and rules for implementation.
Review, Appeal or Waiver of penalty requests emanating out of actions taken by the Member Committee
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Review, appeal or waiver of penalty procedures updated: member committee and governing board mechanisms govern appeals and escalations.
Requests for review, appeal or waiver of penalty against actions by an MII's Internal Committee must be placed before the Member Committee; requests against actions of the Member Committee shall be handled by a mechanism established by the Governing Board with Public Interest Directors and/or Independent External Professionals not part of the MC, pursuant to a Governing Board issued Standard Operating Procedure, with further appeal available to appropriate authorities under applicable law.
Rights of Persons with Disabilities Act, 2016 and rules made thereunder- mandatory compliance by all Regulated Entities.
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Digital accessibility required for regulated entities' platforms, mandating audits, remediation, accessible e KYC and annual compliance reporting.
SEBI mandates that all regulated entities ensure Digital Accessibility for persons with disabilities by making digital platforms conform to WCAG 2.1 (or latest), GIGW and IS 17802, implement accessibility features (ISL videos, captions, descriptive audio, tagged PDFs, alt text), include accessible alternatives in e-KYC and registration with human review of automated rejections, designate a Nodal Officer, conduct IAAP-audits with usability testing by PwDs, remediate findings within specified timelines, incorporate accessibility in procurement, and submit annual compliance reports to specified authorities.
Extension of timeline for implementation of Phase II & III of Nomination Circular dated January 10, 2025 read with Circular dated February 28, 2025
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Nomination framework timeline extended for phased implementation as SEBI defers key provisions to allow system changes and testing.
Extension of the implementation timeline for Phase II and Phase III of the nomination framework for the Indian securities market. SEBI extended Phase II to August 08, 2025 in view of system development and process changes required by depositories, depository participants and industry associations, and deferred Phase III to December 15, 2025 to allow further development and testing. All other provisions of the earlier nomination circulars remain unchanged.
Operational Efficiency in Monitoring of Non-Resident Indians (NRI) Position Limits in Exchange Traded Derivatives Contracts - Ease of Doing Investment
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NRI position limit monitoring revised: exchanges to monitor NRIs at client-level, removing mandatory CP code requirement.
Exchanges and Clearing Corporations must monitor NRI position limits in exchange-traded derivatives in the same manner as client-level position limits, removing the mandatory requirement for NRIs to notify Clearing Members and for Exchanges to assign Custodial Participant (CP) Codes; operational processes must be amended to capture NRIs trading without CP Codes and position limits for NRIs remain the client-level limits specified by the regulator.
Extension of timeline for implementation of SEBI Circular SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/0000013 dated February 04, 2025
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Extension of algorithmic trading implementation timeline shifts effective date, requiring exchanges to ensure compliance and amend bye laws.
The SEBI circular on safer participation of retail investors in algorithmic trading, previously to take effect from August 1, 2025, is deferred to October 1, 2025. Recognized stock exchanges must notify their members, publish the circular online, implement appropriate systems and procedures for compliance, and amend relevant bye-laws, rules and regulations to give effect to the decision. The circular is issued under Section 11(1) of the SEBI Act, 1992, read with Section 30 of the Stock Brokers Regulations, 1992.
Monitoring of Minimum Investment Threshold under Specialized Investment Funds (SIF)
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Minimum Investment Threshold enforcement: breach leads to unit freeze, 30 day notice to cure, then automatic redemption at NAV.
Daily monitoring by the Asset Management Company is required to prevent an investor's aggregate SIF holdings falling below the Minimum Investment Threshold. An Active Breach-a decline in aggregate SIF investment value below the threshold due to investor initiated transactions-will cause all units across SIF strategies to be frozen and a 30 calendar day notice to rebalance. If not remedied within 30 days, the frozen units will be automatically redeemed by the AMC at the applicable Net Asset Value on the next business day. AMCs, RTAs and Depositories must establish systems to implement this mechanism.
Frequently Asked Questions (FAQs) related to regulatory provisions for Research Analysts
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Research analyst regulation: certification and disclosure requirements clarified, easing compliance for institutional clients and NISM timelines.
SEBI clarifies that research entities must register under the RA Regulations while employed individuals must meet qualification and obtain specified NISM certification within one year. The circular details scope exclusions for research reports, reiterates that methodology does not exempt research services, prescribes registration procedures, fees, RAASB deposit requirements based on client counts, and sets out disclosure, recordkeeping and trading restrictions. Institutional investors/QIBs require disclosure of terms including MITC but not signed consent; distribution activities must be segregated or carried out at arm's length where research is provided on the same products, and proxy advisers must register and comply with specified disclosure and record obligations.
Master Circular for Portfolio Managers
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Portfolio Manager regulation consolidates SEBI circulars, updates registration, disclosure, investment limits and reporting obligations.
This Master Circular consolidates SEBI circulars for Portfolio Managers up to March 31, 2025, superseding the June 07, 2024 circular, rescinding specified prior circulars while preserving prior actions. It prescribes online registration and change in control procedures, compliance and certification requirements, client fund segregation and reconciliation rules, written policies for order placement and trade allocation, distributor oversight, cybersecurity and valuation norms, limits and prior consent and disclosure obligations for related party investments, reporting and audit requirements (monthly, quarterly, annual and offsite formats), standardized investment approach/strategy tagging and performance benchmarking, fee disclosure and high water mark rules, and investor grievance and reporting obligations.
Master Circular for Credit Rating Agencies
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Registration and conduct rules for credit rating agencies standardized master circular; sets registration, rating processes, disclosures and audit obligations.
Master Circular consolidates regulatory provisions for CRAs: online registration and prior approval for change in control; procedures for transfer, surrender, suspension and cancellation of registration; standardized rating scales including CE suffix and EL-based scale; mandatory operations manual, rating criteria, rating-process rules and rating committee governance; disclosure regime requiring standardized press releases, monthly No Default Statements, daily non-cooperative issuer lists and periodic PD and transition disclosures; and half-yearly internal audits, outsourcing safeguards and detailed conflict-of-interest controls.
Master Circular for ESG Rating Providers (ERPs)
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ESG rating regulation: SEBI issues a consolidated Master Circular tightening registration, governance, disclosures, and conflict controls for ERPs.
SEBI's Master Circular consolidates obligations for ESG Rating Providers: online registration procedures, prior SEBI approval and documentation requirements for change in control, rules for transfer/surrender/suspension/cancellation with client migration and record retention obligations; definition of required ESG products and a 0-100 rating scale; mandatory adoption of either subscriber pays or issuer pays models (no hybrid), issuer pays contract and non cooperation rules; governance, internal audit and conflict of interest safeguards; and extensive periodic and continuous disclosure, transition rate and IOSCO compliance reporting requirements.
Master Circular for listing obligations and disclosure requirements for Non-convertible Securities, Securitized Debt Instruments and/ or Commercial Paper
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Listing obligations mandate standardised continuous disclosure and reporting for issuers of non-convertible and securitised debt instruments.
Consolidates SEBI circulars into a Master Circular for issuers of listed Non-convertible Securities, securitised debt instruments and commercial paper, prescribing effective compliance measures: standardised formats for financial and audit reporting, procedures for disclosure of audit qualifications, use of proceeds statements, mandatory reporting of defaults and securitisation pool and loan level disclosures, corporate governance reporting for high value debt issuers, related party transaction protocols, sanctioning framework for non compliance and procedures for transfer and claiming of unclaimed amounts.
Master Circular for Real Estate Investment Trusts (REITs)
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REIT compliance framework consolidates SEBI circulars, mandating online filings, issuance protocols, disclosures and NDCF rules.
SEBI issues a Master Circular for REITs effective on issuance, consolidating prior REIT circulars and superseding those listed, while saving prior acts and pending applications. It mandates use of an online filing portal for registration and compliance, prescribes detailed public-issue and follow-on offer procedures (merchant banker duties, draft hosting, pricing, allocation, ASBA/UPI bidding, anchor/strategic investor rules), dematerialisation of units, and time-bound allotment/listing processes together with extensive continuous disclosure, audit, NDCF computation and investor redressal requirements.

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