SEBI Compliance Checklist 2025-26: Calendar, Dates, Forms
Shlok Sobti
SEBI Compliance Checklist 2025-26: Calendar, Dates, Forms
Missing a single SEBI deadline can snowball into fines, trading restrictions, and reputation risk. Yet dates, forms, and workflows sit across LODR, PIT, SAST, Depositories & Participants, and Companies Act—each with its own nuance and “T+” clocks. If you’re a Company Secretary, Compliance Head, CFO, or IR lead at a listed entity, you need one reliable, current-year view that translates regulations into what to file, when, where, and by whom—without the guesswork.
This guide gives you exactly that. It’s a practical, FY 2025–26 compliance checklist and month-wise calendar, complete with due dates, forms, filing portals, owners, cross-checks, and common pitfalls. You’ll also get a free, downloadable Invsify calendar (PDF/Excel) you can customize, plus optional alerting and automation ideas. We cover annual/quarterly/half-yearly LODR, event-based disclosures (Regs 7, 28, 29, 30, 31, 37, 39, 44, 45), DP 2018 issuer obligations, Companies Act filings, PIT controls, SAST disclosures, the board-to-results workflow, AGM and large corporate requirements, website/policy hygiene, penalties, and ready-to-use trackers. Let’s start with the downloadable calendar.
1. Download: Invsify’s SEBI compliance calendar 2025-26 (PDF/Excel)
Turn the SEBI compliance checklist into a working system. Our editable calendar consolidates LODR, PIT, SAST, Depositories & Participants, and Companies Act items into one FY 2025–26 view, so teams know exactly what to file, when, where, and by whom.
What you get
You’ll receive a clean PDF for circulation and a fully filterable Excel for execution. Each line maps regulation, requirement, frequency, due date/T+ clock, form, filing portal, owner, evidence needed, and cross-checks, plus a month-wise planner and risk flags for weekend/holiday spillovers.
Who should use it
Designed for Company Secretaries, Compliance Heads, CFO/Controllers, and IR leads at main-board and SME listed entities. Secretarial auditors and advisory teams can also use it as a standardized reference to validate completeness and timing.
How to download and customize
Use the Download buttons to grab PDF or Excel, then tailor the Excel: select exchange (BSE/NSE), confirm FY 2025–26, add company holidays and board calendar, assign owners/escalations, and filter by frequency or regulation. Lock final views for version control.
Optional add-ons (alerts, API, integrations)
Enable T−7/T−3/T−1 reminders via email, Slack/Teams, or WhatsApp, push an ICS feed to team calendars, and stream due dates into GRC/ticketing (e.g., Jira/ServiceNow) via webhook/API. Optional cues help prep XBRL/result workflows and website Reg 46 self-audits—always cross-check with latest SEBI/MCA circulars.
2. What changed for 2025-26: key SEBI and MCA updates to note
Before you lock your SEBI compliance checklist, align your FY 2025–26 calendar with recent LODR, DP Regulations, and MCA practices. A few items are now time-sensitive, XBRL-heavy, and “same-day” driven via stock exchanges. Build buffers and automate alerts for T+ clocks that can’t slip over weekends/holidays.
Headlines at a glance
Rumor verification under Reg 30(11): mandatory for top 100 listed, rolling to top 250 as notified; confirm/deny/clarify within 24 hours of mainstream media reports.
Event disclosure clocks (Reg 30(6)): 30 minutes post-board meeting; 12/24-hour outer limits depending on event origin.
RPT disclosures (Reg 23(9)): continue half-yearly on the date of publication of standalone and consolidated results.
Secretarial Compliance Report (Reg 24A): within 60 days of FY end; exchanges expect strict adherence.
Expanding XBRL on exchanges: more announcement categories require XBRL along with PDF—follow BSE/NSE circulars.
DDHS “Large Corporate” labels: initial disclosure within 30 days of FY start; annual within 45 days of FY end.
Effective dates and transition
Most clocks above are live; rumour verification for the top 250 is phased “as specified by SEBI.” Treat XBRL expansions as rolling changes—apply from the circular’s effective date and retrofit templates immediately.
Action checklist
Update your disclosure SOPs for 30-minute/12-hour/24-hour Reg 30 timelines.
Map RPT half-yearly to results publication day; pre-clear data with Audit Committee.
Refresh XBRL templates on BSE/NSE; run a mock file before live windows.
Reconfirm FY timers: Reg 24A, Reg 14 fees, Reg 7(3)/40(9)-(10), DDHS initial/annual.
Calibrate escalation paths for rumour verification within 24 hours.
Sources to monitor
SEBI regulations/circulars and exchange notices (BSE/NSE) for LODR/XBRL updates.
MCA portal/advisories for Companies Act forms and additional fees triggers.
Your RTA/depositories for DP Reg 74(5)/76 quarterly certification timelines and formats.
3. Annual compliances under SEBI LODR 2015
Annual LODR items anchor your SEBI compliance checklist and set the tone for the year—fees, certifications, results, and the annual report. Lock these first, then layer your quarterly/half-yearly and event-based workflows.
What it covers
Key annuals include listing fee payment, RTA/transfer processing certificates, secretarial compliance report, annual financial results, annual report/dispatch, AGM voting results, code of conduct affirmations, and “Large Corporate” disclosures under SEBI DDHS.
Due dates and frequency (2025-26)
These are typically anchored to 31 March year-ends—plan buffers for weekends/holidays and exchange cut-offs.
By 30 Apr: Reg 7(3) (CO+RTA certificate), Reg 40(9)/(10) (PCS certificate/filing), Reg 14 (listing fees), DDHS “Large Corporate” initial disclosure.
By 15 May: DDHS annual disclosure (if applicable).
By 30 May: Reg 24A Secretarial Compliance Report; Reg 33(3)(d) annual financial results with auditor’s report (within 60 days of FY end).
AGM season: Reg 34(1)/36(2) annual report not less than 21 days before AGM; Reg 44(3) voting results within 2 working days of the meeting; Reg 26(3) code of conduct affirmation at the first board meeting of the year.
Forms and where to file
File PDFs/XBRL on the stock exchange portals (BSE Listing Centre/NSE NEAPS) as prescribed; make listing fee payments on exchange systems; publish the annual report on the website and file with exchanges; maintain PCS certificates and working papers.
Owner and cross-checks
Company Secretary owns filings; CFO supports results/fees; RTA supports Reg 7/40; PCS issues Reg 24A and 40(9) certificates. Cross-check board minutes, fee receipts, XBRL validations, and website updates (Reg 46).
Pitfalls and pro tips
Don’t miss 30 Apr cluster items; align Reg 24A scope early with the PCS; pre-clear XBRL templates per latest exchange circulars; ensure the annual report matches filed results and includes all mandated sections before dispatch and exchange submission.
4. Quarterly compliances under SEBI LODR 2015
Quarterly filings set the market’s rhythm—ownership, governance, results, and use of proceeds. Lock these into your SEBI compliance checklist with clear T+ clocks, review paths, and XBRL readiness to avoid last‑minute scrambles and SOP fines.
What it covers
Regulation 31(1)(b): Shareholding pattern.
Regulation 27(2)(a): Corporate Governance report.
Regulation 13(3): Statement on investor complaints.
Regulation 33(3)(a): Quarterly financial results with Limited Review Report (Q1–Q3).
Regulation 32(1): Statement of deviation(s)/variation(s) in use of proceeds (where applicable).
Due dates and frequency (2025-26)
Typical quarter-end timelines; plan for weekend/holiday buffers and exchange cut-offs.
Regulation | Compliance | Timeline (Q1/Q2/Q3/Q4) |
|---|---|---|
Reg 31(1)(b) | Shareholding pattern | Within 21 days from quarter end (e.g., by 21 Jul/21 Oct/21 Jan/21 Apr) |
Reg 27(2)(a) | Corporate Governance | Within 21 days from quarter end |
Reg 13(3) | Investor complaints | Within 21 days from quarter end |
Reg 33(3)(a) | Financial results + LRR | Within 45 days (Q1–Q3); annual/Q4 results within 60 days of FY end |
Reg 32(1) | Deviation/variation statement | Within 45/60 days aligned to results timetable |
Forms and where to file
File PDFs (and XBRL where prescribed) on BSE Listing Centre/NSE NEAPS. Financial results require prescribed formats with the Limited Review Report/Auditor’s Report; follow current exchange XBRL taxonomies alongside PDFs where mandated.
Owner and cross-checks
Company Secretary owns submissions; CFO/Finance owns Reg 33 numbers and LRR; RTA supports Reg 31; Compliance/IR collate Reg 27 data; Board/Audit Committee review results and key disclosures. Cross-check PDF vs XBRL parity, promoter/public category totals, and grievance stats.
Pitfalls and pro tips
Don’t let the 21‑day filings slip due to holidays; pre‑schedule board dates and LRR.
If no funds were raised, confirm non‑applicability of Reg 32 per exchange format.
Ensure governance data (committee composition/meetings) reflects quarter‑end reality.
Validate shareholding pattern against depository/RTA reports before filing.
5. Half-yearly compliances under SEBI LODR 2015
Half-yearly LODR is largely about Related Party Transactions (RPT). Because this disclosure is now tied to your results day, treat it as a “same‑day” deliverable and rehearse the workflow with Finance and the Audit Committee ahead of board meetings.
What it covers
Disclosures of related party transactions under Regulation 23(9) for both standalone and consolidated numbers.
Due dates and frequency (2025-26)
File twice a year—H1 (Apr–Sep) and H2 (Oct–Mar)—on the date you publish standalone and consolidated financial results; some references still cite a 15‑day outer limit, but follow the stricter “same‑day” expectation.
Forms and where to file
Submit in the exchange‑prescribed format on BSE Listing Centre/NSE NEAPS (PDF and any XBRL schema if notified by the exchange). Align totals to the published results pack.
Owner and cross-checks
Company Secretary coordinates; CFO/Finance compiles RPT ledgers; Audit Committee pre‑reviews. Cross‑verify approvals under Reg 23, standalone vs consolidated coverage, and period cut‑offs.
Pitfalls and pro tips
Don’t miss consolidated data; map every counterparty to the approved RPT master.
Reconcile with IND AS party mapping and inter‑company eliminations.
If no transactions, follow exchange template for non‑applicability/NIL declaration.
Pre‑clear with statutory auditors for consistency with notes to results.
6. Event-based disclosures under SEBI LODR 2015 (Reg 7, 28, 29, 30, 31, 37, 39, 44, 45)
These are the “no‑slip” items on your SEBI compliance checklist. Triggers arrive without warning, and clocks start immediately—some as tight as 30 minutes, 12 hours, or 24 hours. Build clear SOPs, escalation paths, and ready-to-file templates.
What it covers
Event-led intimations/approvals around RTA appointment, capital raising and board meetings, material events (Reg 30), special shareholding pattern cases, schemes of arrangement, loss/duplicate certificates, voting results, and change of name.
Reg 7(5), 28, 29, 30, 31(1)(a)/(c), 37(2), 39(3), 44(3), 45(3)
Due dates and frequency (2025-26)
Timelines below are per SEBI/stock exchange guidance; “advance” excludes the date of intimation and meeting.
Regulation | Trigger | Timeline |
|---|---|---|
7(5) | Appointment of RTA | Within 7 days of agreement |
28(1) | Issue of securities | In‑principle approval before issue |
29(1)(a), 29(2) | Board meeting for financial results | ≥ 5 days in advance |
29(1)(b)-(f), 29(2) | Buyback/dividend/fund‑raise/bonus, etc. | ≥ 2 working days in advance |
29(3) | Alteration in nature of securities | ≥ 11 working days in advance |
30(6) | Board decisions on Schedule III events | 30 minutes post board closure |
30(6) | Event originating within entity | Within 12 hours |
30(6) | Event not originating within entity | Within 24 hours |
30(11) | Rumor verification (Top 100/250) | Within 24 hours of report |
31(1)(a) | Prior to listing | 1 day before listing |
31(1)(c) | Capital restructuring | Within 10 days of change (±2%) |
37(2) | Scheme of arrangement | Exchange NOC before court/NCLT filing |
39(3) | Loss/duplicate share certificates | Within 2 days of info |
44(3) | Voting results (GM) | Within 2 working days of GM |
45(3) | Change in name | CA certificate in explanatory statement |
Forms and where to file
File on BSE Listing Centre/NSE NEAPS in prescribed PDF and, where required, XBRL. Schemes (Reg 37) require submission to exchanges for observation/NOC before any court/NCLT filing.
Owner and cross-checks
Company Secretary: owns intimation, outcomes, and clocking.
CFO/Finance: numbers for results/dividend/capital actions.
RTA/Depositories: 31, 39 support and evidence.
Legal/PR/IR: Reg 30 wording; rumor verification (30(11)).
Cross-check board minutes, timestamps, and PDF–XBRL parity.
Pitfalls and pro tips
Pre-draft Reg 29/30 templates; log exact time of board closure for the 30‑minute clock.
Use a same-day checklist for Reg 30 with 12/24‑hour paths and escalation.
Align capital restructuring filings with depository/RTA records before Reg 31(1)(c).
For GMs, lock Reg 44(3) data and scrutinizer’s report workflow upfront.
Document non-applicability where relevant to avoid query loops with exchanges.
7. Depositories and Participants Regulations, 2018: issuer compliances
These quarterly DP obligations keep your listed capital in sync with depositories and evidence timely demat processing. They’re deceptively simple, but misses lead to stock exchange queries, investor service delays, and audit flags—so lock them into your SEBI compliance checklist with clear owners and tie‑outs.
What it covers
Two recurring filings safeguard capital integrity and investor service metrics.
Reg 76: Reconciliation of Share Capital Audit by a PCS, reconciling issued/paid‑up capital with depository/RTA records.
Reg 74(5): Demat processing certificate confirming cancellation/mutilation and timely dematerialization by the issuer/RTA.
Due dates and frequency (2025-26)
Set quarter-end timers and build weekend buffers.
Reg 76: Within 30 days from quarter end (e.g., by 30 Jul/30 Oct/30 Jan/30 Apr).
Reg 74(5): Within 15 days from quarter end (e.g., by 15 Jul/15 Oct/15 Jan/15 Apr).
Forms and where to file
Use exchange‑prescribed formats on BSE Listing Centre/NSE NEAPS; Reg 76 typically needs PDF plus XBRL. Submit the Reg 74(5) certificate in the format required by the stock exchanges (and to depositories as guided by the regulation/circulars).
Owner and cross-checks
Company Secretary owns submissions; PCS signs Reg 76; RTA issues Reg 74(5). Cross‑verify ISIN‑wise capital, corporate actions (bonus/split/buyback), demat/remat/transfer logs, and depository statements to ensure one‑to‑one reconciliation.
Pitfalls and pro tips
Don’t file Reg 76 without matching ISIN totals to both depositories and RTA ledgers.
Pre‑reconcile corporate actions before quarter close to avoid variance notes.
Use the latest exchange XBRL taxonomy; validate PDF–XBRL parity.
Calendar the tighter Reg 74(5) 15‑day clock with an internal T−7 reminder.
8. Companies Act 2013 filings every listed company must track
SEBI LODR runs in parallel with Companies Act timers—miss an MCA clock and your annual cycle (AGM, results, audits) goes off-track. Park these ROC/IEPF filings in your SEBI compliance checklist with clear owners, XBRL readiness, and buffers around AGM dates.
What it covers
DPT-3 (Return of Deposits): On or before 30 June.
DIR-3 KYC: By 30 September for all DIN holders.
AOC-4 XBRL: Within 30 days of AGM (listed entities: XBRL mandatory).
MGT-7 + MGT-8 (CS in Practice certification): Within 60 days of AGM.
MGT-15 (Report on AGM): Within 30 days of AGM.
ADT-1 (Auditor appointment/re-appointment): Within 15 days of AGM.
MSME-1 (Half-yearly): Oct–Mar by 30 Apr; Apr–Sep by 31 Oct.
IEPF-2: Within 60 days after AGM.
Internal: MBP-1 and DIR-8 annually; MGT-14 for Section 179(3) board resolutions (e.g., approval of FS/Board’s Report) within 30 days.
Forms and where to file
File prescribed e-forms on the MCA portal; keep PCS certificates/workpapers and synchronize disclosures with stock exchange submissions and your website.
Owner and cross-checks
Company Secretary owns filings; CFO supports AOC-4 numbers and DPT-3; secretarial auditor/PCS issues MGT-8 and relevant certificates. Tie-out AOC-4 to published results and the annual report.
Pitfalls and pro tips
Lock AGM date early; back-schedule AOC-4/MGT-7/15.
Use the correct XBRL taxonomy for AOC-4; ensure PDF–XBRL parity.
Reconcile MSME-1 with vendor ledgers; document NIL cases.
Attach MGT-8 for listed entities; mismatches trigger resubmissions.
9. Insider Trading (PIT) Regulations: trading window, UPSI and continual disclosures
PIT controls are your first line against leaks and timing errors. For FY 2025–26, lock your trading window calendar to quarterly results, hard‑gate UPSI handling around board outcomes, and track continual disclosures from promoters/designated persons with T+2 precision.
What it covers
Under SEBI (Prohibition of Insider Trading) Regulations, 2015, build controls around three pillars.
Trading window closure from each quarter-end till 48 hours after results disclosure (as per BSE/NSE circulars referencing Schedule B).
UPSI governance: identification, minimal access, approvals, and synchronized disclosures alongside LODR Reg 30 outcomes.
Continual disclosures (Reg 7(2)): promoters/promoter group/designated persons/directors must disclose trades exceeding Rs 10 lakh in a calendar quarter to the company; company reports to exchanges.
Due dates and frequency (2025-26)
Time the following with your board/results calendar and broker settlement cycles.
Trading window: close on 30 Jun/30 Sep/31 Dec/31 Mar and reopen 48 hours post results announcement.
Continual disclosures: within 2 trading days of receipt or becoming aware (company to exchange); insiders to company within 2 trading days.
Annual DP data capture (Code of Conduct/Schedule B): collect and refresh on an annual basis and upon changes.
Forms and where to file
Use exchange‑prescribed formats on BSE Listing Centre/NSE NEAPS for continual disclosures; send trading window closure/opening intimation to exchanges as per their templates. Insiders file to the Compliance Officer; the company files to exchanges.
Owner and cross-checks
Compliance Officer/Company Secretary owns the Code of Conduct, window notices, UPSI list, and exchange filings; Finance confirms result timestamps; HR/legal maintain designated person lists. Cross‑check broker confirmations and PAN‑level aggregations for threshold breaches.
Pitfalls and pro tips
Don’t miscount the 48‑hour clock—start after public disclosure, not board approval.
Intimate trading window closure before quarter-end; publish reopening only after both PDF/XBRL results go live.
Aggregate promoter group trades across accounts/entities to test the Rs 10 lakh threshold.
Keep UPSI access logs tight during rumour verification and Reg 30 disclosures; align wording and timing to avoid selective disclosure.
10. SAST Takeover Code: promoter encumbrance and other disclosures
Encumbrance reporting by promoters and persons acting in concert (PAC) is a fast‑clock item under the SAST Regulations. Build this into your SEBI compliance checklist with a clear trigger-to-exchange workflow and depository tie‑outs to avoid variance queries.
What it covers
Encumbrance means pledge, lien, non‑disposal undertakings and similar rights. Promoters/PAC must disclose:
Creation/invocation/release of encumbrance (Reg 31(1)/(2) read with 31(3)).
Yearly declaration confirming encumbrances made during the FY (Reg 31(4)/(5)).
Due dates and frequency (2025-26)
Disclosures are event-based with a year‑end affirmation.
Within 7 working days of creation/invocation/release.
Within 7 working days from FY end for the annual declaration.
Forms and where to file
File in exchange‑prescribed formats on BSE Listing Centre/NSE NEAPS; send to every stock exchange where listed and to the company (annual declaration also to the Audit Committee). Maintain depository/RTA evidence.
Owner and cross-checks
Promoters/PAC notify the Company Secretary; CS files with exchanges. Cross‑check against NSDL/CDSL pledge/encumbrance statements, RTA records, and LODR Reg 31 shareholding pattern.
Pitfalls and pro tips
Count “working days”; don’t miss negative lien/non‑disposal undertakings.
Aggregate across PAC; keep a live encumbrance register.
Reconcile ISIN‑wise quantities with depositories before filing; ensure recipient coverage (all exchanges and the company/Audit Committee for annual).
11. Board meeting to results lifecycle: notices, outcomes, XBRL and newspaper ads
Results days run on tight, non-negotiable clocks. Align board scheduling, Reg 29 intimations, Reg 30 outcomes, Reg 33 filings, and Reg 47 newspaper ads into a single playbook so Finance, CS, auditors, and IR move in sync.
Pre-meeting notices and intimation
Lock your board date early and trigger prior intimations well before the cut-offs; exclude the date of intimation and the meeting date while counting.
Reg 29 (financial results): Intimate at least 5 days in advance.
Reg 29 (other items): Intimate at least 2 working days in advance.
Trading window: Close from quarter-end till 48 hours after results disclosure; notify exchanges.
During and post-meeting filings
Capture board decisions precisely and file within Reg 30/33 clocks; time-stamp the board closure.
Reg 30(6) outcome: File within 30 minutes of board closure.
Reg 33 results (Q): File results with Limited Review Report within 45 days (Q1–Q3).
Reg 33 (annual/Q4): Within 60 days of FY end.
Reopen window: 48 hours after public disclosure.
XBRL, PDF and newspaper workflow
Exchanges increasingly require both PDF and XBRL; publish media ads quickly per Reg 47.
XBRL upload: Submit within 24 hours of board meeting alongside PDFs (as prescribed).
Newspaper publication (Reg 47): Within 48 hours of the BM.
File clippings: Within 24 hours of publication on exchange portals.
Controls and audit trail
Reduce restatements and queries with tight evidence trails and reconciliations.
Parity checks: Ensure PDF–XBRL–press ad numbers and wording match.
Approvals: Pre-clear formats with Audit Committee/statutory auditors; lock signatories.
Logs: Preserve time-stamped board closure, filing receipts, exchange acknowledgments, and website updates for secretarial audit and Reg 24A.
12. AGM and annual report checklist: Reg 34, 44 and allied filings
AGM season compresses multiple hard deadlines across SEBI LODR and the Companies Act. Use this section to stitch together notice/dispatch, meeting conduct, and all post‑AGM filings so exchanges, ROC, and your website carry the same, error‑free story.
Pre-AGM (notice, e-voting, dispatch)
Prepare the annual report and notice, finalize the e‑voting window, and schedule newspaper communication.
Reg 34(1) & 36(2): File the annual report with exchanges not later than the day you commence dispatch and ensure it’s at least 21 clear days before the AGM; host it on the website.
Companies Act Sec 101/136 & SS‑2: Dispatch notice and the audited financials/boards’ reports 21 clear days in advance.
E‑voting (listed entities): Provide facility to shareholders; include instructions in the notice.
Reg 47: Publish AGM/e‑voting advertisements; file clippings with exchanges.
During AGM (proceedings, scrutinizer)
Run e‑voting/poll as applicable, record attendance, and secure the scrutinizer’s report.
Reg 30: File concise proceedings/outcome of AGM within 24 hours.
Ensure resolutions, special business, and Q&A summaries are captured consistently with the notice.
Post-AGM filings and disclosures
Close out stock‑exchange and MCA obligations on time.
Reg 44(3): Submit voting results (with scrutinizer’s report) within 2 working days of the AGM.
MCA/ROC (allied): AOC‑4 XBRL (30 days), MGT‑7 with MGT‑8 for listed (60 days), MGT‑15 (30 days), ADT‑1 (15 days), IEPF‑2 (within 60 days after AGM). Update the website (Reg 46).
Checkpoints and timelines
Align annual report, results, and AGM notice wording; keep PDF–XBRL parity.
Time e‑voting to close before the meeting; reconcile with poll results.
Date‑count “clear 21 days” and exchange clocks; buffer for weekends/holidays.
Archive dispatch proofs, newspaper ads, scrutinizer’s report, exchange acknowledgments, and website snapshots for secretarial audit/Reg 24A.
13. Large corporate disclosures under SEBI DDHS circulars (2018 and subsequent changes)
If your entity qualifies as a “Large Corporate” under SEBI’s DDHS circular (2018/144), you must make two time‑bound disclosures each year. Build these into your SEBI compliance checklist even if status changes year to year—self‑assess at FY start and validate with Treasury.
What it covers
These disclosures confirm your Large Corporate status and subsequent borrowing outcomes for the year, in the exchange‑prescribed formats.
Initial disclosure: Status at the start of the FY.
Annual disclosure: Year-end confirmation and metrics, if applicable.
Due dates and frequency (2025-26)
Timelines are tight; plan with CFO/Treasury and CS.
Initial disclosure: Within 30 days from FY start (by 30 April).
Annual disclosure: Within 45 days from FY end (by 15 May).
Forms and where to file
File in the formats prescribed by the circular on BSE/NSE portals (PDF/XBRL where required). Retain working papers supporting thresholds and calculations.
Owner and cross-checks
Company Secretary files; CFO/Treasury owns numbers. Cross‑verify with audited financials, borrowings schedules, credit ratings, and board notes used for status assessment.
Pitfalls and pro tips
Don’t assume prior‑year status—recompute annually per the circular.
Keep a clear computation memo; exchanges may seek evidence.
Align figures and definitions used across initial vs annual disclosures to avoid queries.
14. Website, policies and governance artifacts required under Reg 46 and other provisions
Your website is a regulated disclosure channel, not just marketing. Under LODR Reg 46, keep a “functional” site with prescribed information, synced with exchange filings and AGM/annual report timelines (Reg 34). Treat it as part of your SEBI compliance checklist with owners, SLAs, and an archive policy.
Mandatory website sections
Ensure the sections prescribed by exchanges are live and current, including, for example:
Basic corporate information: registered office, contact, key managerial personnel.
Financials and annual report: audited results, annual report tied to Reg 34 and dispatch.
Shareholder information: notices, e‑voting instructions, meeting outcomes, voting results.
Disclosures/press releases: outcomes under Reg 30, investor presentations, media ads (Reg 47).
Functional policies page: company policies and codes made available as per applicable laws.
Policies and charters to publish
Host governance artifacts commonly expected by exchanges and auditors, such as:
Code of Conduct (directors/senior management) and affirmation note.
Vigil mechanism/whistle‑blower policy (listed entities).
Board committee charters: Audit, NRC, Stakeholders’ Relationship Committee.
RPT/Materiality/Archival & disclosure frameworks aligned to Reg 30 practices.
Update cadence and ownership
Owner: Company Secretary (content), with IR/PR (news) and IT (uptime/SSL).
Cadence: publish on or before exchange submissions; mirror PDFs; time‑stamp updates.
Controls: dual checks for parity with BSE/NSE filings; monthly link‑health review.
Self-audit tips
Run a quarterly crawl for broken links and missing PDFs; verify “functional” availability.
Check PDF–XBRL–web parity for numbers, dates, and signatories.
Maintain an archive (access plus retention) and a change log for secretarial audit.
Test mobile view, search, and download speed; keep e‑voting and AGM pages readily accessible during the season.
15. Month-wise compliance calendar for FY 2025-26 (quick view)
Use this quarter-by-quarter view to lock team bandwidth and board dates. It assumes 31 March year-end and main-board listing; always apply exchange clocks and count “working days” where required.
April–June
Anchor the April cluster. Build weekend buffers and pre-draft Reg 29/30 templates.
15 Apr: DP Reg 74(5) Q4 certificate; 21 Apr: Reg 31/27/13 for Q4.
30 Apr: Reg 7(3), Reg 40(9)/(10), Reg 14, DDHS initial, DP Reg 76 Q4, MSME‑1 (Oct–Mar).
By 30 May: Reg 24A; Reg 33 annual/Q4 results; Reg 23(9) H2 RPT on results day (if applicable).
30 Jun: DPT‑3; Q1 trading window closure starts.
July–September
Q1 filings bunch in July; AGMs close by September end. Lock dispatch + e‑voting early.
15/21/30 Jul: DP 74(5) Q1; Reg 31/27/13 Q1; DP 76 Q1.
By 14 Aug: Reg 33 Q1 results; Reg 32 deviation statement (if applicable).
Sep: Reg 34/36 dispatch ≥21 clear days before AGM; Reg 47 AGM/e‑voting ads.
By 30 Sep: DIR‑3 KYC; hold AGM; Q2 trading window closure.
October–December
Q2 cycle peaks in October–November. Close post‑AGM ROC clocks on time.
15/21/30 Oct: DP 74(5) Q2; Reg 31/27/13 Q2; DP 76 Q2.
31 Oct: MSME‑1 (Apr–Sep).
By 14 Nov: Reg 33 Q2 results; Reg 32 (if applicable).
Post‑AGM (if AGM in Sep): ADT‑1 (15 days), AOC‑4 XBRL (30 days), MGT‑15 (30 days), MGT‑7 with MGT‑8 (60 days), IEPF‑2 (60 days after AGM).
January–March
Stage year-end clusters now; clocks restart fast in April.
15/21/30 Jan: DP 74(5) Q3; Reg 31/27/13 Q3; DP 76 Q3.
By 14 Feb: Reg 33 Q3 results; Reg 32 (if applicable).
31 Mar: Q4 trading window closure; prep Reg 24A, Reg 14, Reg 7(3), Reg 40(9)/(10), DDHS initial.
Plan Reg 23(9) H2 RPT for the same day as FY results; align Audit Committee review.
16. Penalties, fines and common pitfalls to avoid
A tight SEBI compliance checklist reduces cost and risk. Misses trigger exchange SOP fines, show-cause notices, promoter-level restrictions, and in persistent cases, trading suspension or de-listing. MCA delays add steep additional fees and adjudication exposure. Build buffers and controls around the fastest clocks.
LODR non-compliance fines
Graded penalties apply for late/incorrect filings under exchange SOPs (e.g., Reg 30, 31, 33, 44, 46).
Repeated lapses can escalate to freezing of promoter/promoter group holdings and suspension.
PDF–XBRL mismatches or incomplete annexures often invite observations and re-filings.
MCA additional fees and consequences
Delayed AOC-4/MGT-7/MGT-15/ADT-1/DPT-3 attract additional fees and potential adjudication.
Persistent non-compliance can lead to prosecutions and director qualification scrutiny during secretarial audit.
Stock exchange SOPs on non-compliance
Exchanges enforce T+ clocks (30 minutes/12 hours/24 hours) and 21/45/60-day windows.
SOPs prescribe fines, warnings, and escalation for continued default, including moves toward suspension.
How to remediate and report
File immediately with a clear cover note; submit corrected PDF/XBRL and evidence (board minutes, timestamps).
Acknowledge exchange observations promptly; align website (Reg 46) and newspaper ads (Reg 47) the same day.
For MCA, complete e-forms with accurate attachments; document board approvals and seek condonation where applicable.
Hard-stop controls: T−7/T−3 reminders, maker–checker, parity checks (PDF–XBRL–web), and a logged incident register for Reg 24A review.
17. Ready-to-use templates, trackers and process controls
Turn your SEBI compliance checklist into a repeatable machine. Use these plug-and-play templates to assign owners, track clocks, and prove compliance during audits without scrambling.
Filings checklist matrix
Build one master sheet for FY 2025–26 that maps every item to dates, owners, and evidence.
Columns: Regulation, requirement, frequency, due/T+ clock, form, portal, owner, checker, status, evidence link, comments.
Views: Month-wise, regulation-wise, and “this week” filters; lock a baseline version.
RACI: who does what by when
Clarify accountability and escalation so no clock slips.
Responsible: Prepares content/data.
Accountable: Signs off and files.
Consulted: Audit Committee/Statutory Auditor/RTA.
Informed: IR/PR/CEO/Board.
Sample trackers and registers
Keep auditable, reconciled logs for fast responses.
Reg 30 log: event, trigger time, disclosure time, proofs.
Share capital recon (DP Reg 76): ISIN totals vs NSDL/CDSL/RTA.
Encumbrance register (SAST): creation/invocation/release with depository refs.
RPT ledger (Reg 23(9)): counterparty map and approvals.
Trading window log (PIT): close/open notices and timestamps.
Automation ideas and tools
Automate clocks and parity checks to cut errors.
Reminders: T−7/T−3/T−1 email/Slack/Teams/WhatsApp; ICS feed to calendars.
Working-day math:
=WORKDAY.INTL(due_date,-7,"0000011")for T−7 excluding weekends.Parity bots: compare PDF vs XBRL vs website vs press ads.
Evidence vault: auto-save receipts, acknowledgments, ads, and time-stamped PDFs to a shared repository with immutable logs.
Next steps
You now have a current-year SEBI compliance checklist with due dates, forms, portals, and the fastest clocks mapped. Lock your board calendar, assign owners (maker–checker), and set T−7/T−3/T−1 reminders. Reconcile PDF–XBRL–website parity before every “results” and “AGM” cluster, and rehearse the Reg 30 thirty‑minute and 12/24‑hour paths so no disclosure slips.
Download the FY 2025–26 calendar (PDF/Excel), tailor it to your entity (BSE/NSE, holidays, committees), and switch on alerts. Keep a single evidence vault for receipts, minutes, XBRL validations, newspaper clippings, and website snapshots—your PCS/secretarial audit will thank you. If you want a smarter way to run this playbook alongside your investor communications and reporting cadence, start with us at Invsify—smart, conflict‑free, and built for precision.
