Understanding Key Amendments - August 2025
- Aitijyamoy Mukherjee
- Aug 15
- 18 min read
RESERVE BANK OF INDIA
Reserve Bank of India (Pre-payment Charges on Loans) Directions, 2025
Notification No.: RBI/2025-26/64, dated July 2, 2025
Overview
The Reserve Bank of India has issued fresh directions to regulate pre-payment charges on loans, especially to protect individual borrowers and Micro & Small Enterprises (MSEs), after the Reserve Bank’s supervisory reviews showed inconsistent practices and restrictive clauses by lenders that often discouraged borrowers from switching to more favourable loan terms, either for availing lower rates of interest or better terms of service. The aim is to enhance borrower flexibility and transparency and reduce disputes.
Key Provisions
Scope & Applicability
Applies to all loans and advances sanctioned or renewed on or after January 1, 2026
Covers commercial banks (excluding payment banks), cooperative banks, NBFCs, and All India Financial Institutions (AIFI)
No Pre-Payment Charges For:
Individuals (non-business loans) no charges, regardless of co-borrowers
Business loans to individuals and MSEs:
No charges if loan is from a Commercial Bank (excluding Small Finance Banks, Regional Rural Banks, Local Area Banks), Tier 4 Urban Co-operative Bank, Non Banking Financial Company-Upper Layer, or AIFI
No charges for loans up to ₹50 lakh from Small Finance Banks, Regional Rural Banks, Tier 3 Urban Co-opertaive Banks, State and Central Co-opertaive Banks, and Non Banking Financial Company-Middle Layers
Other Key Conditions:
Applies even if the pre-payment is funded externally
No lock-in period required for availing waiver of charges
In dual/special-rate loans, waiver depends on whether the loan is on floating rate at the time of pre-payment
In Other Cases:
REs may levy charges as per approved policy
Charges must be based only on prepaid amount (for term loans) or sanctioned limit (for overdraft/cash credit)
Special Cases:
No charges if the borrower opts not to renew CC/OD facility and closes on due date
No charges if pre-payment is initiated by the lender
No retrospective charges allowed
All pre-payment charge policies must be clearly disclosed in the sanction letter, agreement, and Key Facts Statement (KFS)
Repeal
Previous circulars and directions listed in the Annex are repealed from the effective date
Foreign Exchange Management (Export of Goods & Services) (Amendment) Regulations, 2025
Notification No: FEMA 23(R)/(6)/2025-RB, dated June 24, 2025
Overview
This amendment updates the existing FEMA (Export of Goods & Services) Regulations, 2015, specifically to expand the scope of items that can be exported without payment of foreign exchange as long as they are re-imported back into India.
Key Provision Added
A new sub-regulation is added under Regulation 4, which deals with exports without payment of foreign exchange.
What’s new?A new clause (ca) has been inserted to allow:
“Tugs or Tug Boats, Dredgers and Vessels used for providing offshore support services”
These can now be exported without payment if they are re-imported into India.
This applies to vessels used for offshore support common in oil & gas, maritime logistics, and construction operations.
Basel III Capital Regulations – Use of Ratings by CareEdge Global IFSC Ltd.
Overview
Under the Basel III framework, banks assign risk weights to various claims (like loans to companies) based on credit ratings. Until now, banks were allowed to use ratings from Fitch, Moody’s, and Standard & Poor’s for this purpose. Now, CareEdge Global IFSC Limited has been added to this list, specifically for non-resident corporates operating from International Financial Services Centres (IFSCs).
Key Provision
Banks can now use credit ratings from CareEdge Global IFSC Ltd. to calculate risk weights for capital adequacy when dealing with non-resident corporates based in an IFSC.
Rating to Risk Weight Mapping:
Lending Against Gold and Silver Collateral – Voluntary Pledge for Agriculture and MSME Loans
Circular no: RBI/2025/2026/66 FIDD.CO.FSD.BC. No.08/05.05.010/2025-26, dated July 11, 2025
Overview
This notification provides clarification regarding agriculture and MSME loans under the collateral-free lending limit. The RBI confirms that if a borrower voluntarily pledges gold or silver as collateral, it will not violate the existing guidelines on collateral-free loans.
Key Clarification
Under current RBI norms, certain agriculture and MSME loans are eligible to be collateral-free up to a specified limit.
Borrowers sometimes choose to voluntarily offer gold or silver as collateral, even within that limit. Banks cannot mandate or insist on gold/silver as collateral for loans within the collateral-free threshold. The pledge must be purely at the discretion of the borrower.
RBI has clarified that such voluntary pledging of gold or silver does not count as a violation of the collateral-free loan rules.
Relevant References
Agriculture Lending – Circular dated December 6, 2024:Credit Flow to Agriculture – Collateral-free agricultural loans
MSME Lending – Master Direction (Updated June 11, 2024):FIDD.MSME & NFS.12/06.02.31/2017-18
Gold and Silver Lending Norms – RBI Directions dated June 6, 2025:DOR.CRE.REC.26/21.01.023/2025-26
Inclusion of NSDL Payments Bank Limited in the Second Schedule of the RBI Act, 1934
Notification No. RBI/2025-26/67, dated July 17, 2025
Overview
The Reserve Bank of India has officially added NSDL Payments Bank Limited to the Second Schedule of the Reserve Bank of India Act, 1934.
this was done through Notification No. DoR.LIC.No.S2196/16.13.215/2025-26, dated June 19, 2025
The inclusion was published in the Gazette of India on July 10, 2025 (Part III – Section 4)
With this inclusion, NSDL Payments Bank Limited is now recognized as a Scheduled Bank under the RBI Act. This status allows the bank to:
Access RBI’s liquidity support (like repo operations)
Be eligible for loans from the RBI at the bank rate and participate for membership of clearing house arrangements.
Enhance its standing and credibility in the financial system
Reserve Bank of India (Investment in AIF) Directions, 2025
Notification No.: RBI/DOR/2025-26/138, dated July 29, 2025
Overview
The RBI has issued new, consolidated regulatory guidelines for investments in Alternative Investment Funds (AIFs) by its regulated entities (REs), replacing two earlier circulars from December 2023 and March 2024. These directions are aimed at strengthening governance, improving transparency in exposure to debtor companies, and ensuring capital adequacy discipline through provisioning and capital deduction requirements.
Key Provisions
Applicability
These directions apply to AIF investments by the following:
Commercial Banks (including SFBs, RRBs, LABs)
Co-operative Banks (Primary Urban, State, Central)
All-India Financial Institutions
NBFCs (including Housing Finance Companies)
General Requirements
REs must have a board-approved investment policy governing AIF investment, in line with existing laws and RBI norms.
Investment Limits
A single RE cannot invest more than 10% of an AIF scheme’s corpus.
The combined investment by all REs in a single AIF scheme must not exceed 20% of the corpus.
Provisioning Requirements
If an RE invests more than 5% in an AIF scheme that also has non-equity exposure to the RE's debtor company, it must make a 100% provision to the extent of its exposure through the AIF (up to the maximum of its direct exposure to that company).
If the RE’s investment is in subordinated units, it must deduct the full amount from capital funds (Tier 1 and Tier 2, as applicable).
Exemptions
Past investments made with RBI approval under the 2016 Master Direction on Financial Services by Banks are exempt from the 10% and 20% investment caps.
RBI may exempt specific AIFs in consultation with the Government of India (except from the general requirement in paragraph 5).
Repeal and Transition
The following earlier circulars stand repealed from the effective date:
DOR.STR.REC.58/21.04.048/2023-24 (Dec 19, 2023)
DOR.STR.REC.85/21.04.048/2023-24 (Mar 27, 2024)
Investments made under existing commitments before the effective date can choose to follow either the old circulars or the new Directions in full.
Completed investments (fully honoured commitments) will continue to be governed by the older circulars.
SECURITIES EXCHANGE BOARD OF INDIA
Common Contract Note with Single Volume Weighted Average Price (VWAP) - Enhancing Ease of Doing Business for Market Participants
Notification: SEBI Press Release No. 38/2025, dated July 2, 2025
Overview:
SEBI has introduced a Common Contract Note (CCN) mechanism with a Single Volume Weighted Average Price (VWAP), effective June 27, 2025, designed to ease post-trade processes for institutional investors and other market participants.
Earlier, participants received separate trade confirmations from each exchange, making reconciliation, settlement, and compliance more cumbersome. Based on the representation received from market participants, it was decided to provide uniformity in post-trade communication. The new system brings in a single, consolidated contract note for trades executed across multiple venues.
This reform was developed in collaboration with market infrastructure institutions after receiving feedback from stakeholders seeking greater simplicity and uniformity in post-trade communication.
Key Provisions:
Mandatory Implementation:The Common Contract Note (CCN) with a single VWAP is now compulsory for institutional trades executed on or after June 27, 2025.
Single VWAP across exchanges:Trades executed across multiple stock exchanges will now be reported using a uniform volume weighted average price.
Consolidated Documentation:A single CCN replaces multiple contract notes, simplifying documentation and reducing operational complexities.
Benefits to Market Participants:
o Reduces compliance burden
o Enhances post-trade transparency
o Ensures consistency in trade reporting
o Aligned with Clearing Corporation interoperability framework
o Improves cost and operational efficiency
NSEL Settlement Scheme 2025
Overview:
SEBI has introduced the NSEL Settlement Scheme 2025 on July 9, 2025, under Section 15JB of the SEBI Act, 1992, and Regulation 26 of the SEBI (Settlement Proceedings) Regulations, 2018. The scheme offers a one-time opportunity for brokers (against whom SEBI has passed orders related to the NSEL platform and who have filed appeals before SAT/courts) to settle securities law violations.
Importantly, this scheme only applies to securities law-related violations. It has no impact on investigations being carried out by other enforcement agencies like the EOW, ED, MCA, or SFIO or those declared defaulters by stock exchanges.
Key Provisions:
Eligible Applicants:
Brokers against whom SEBI has passed orders related to trading/facilitating trading on NSEL.
Must have filed an appeal that is pending before SAT or any court.
Not Eligible If:
Broker’s name appears in any chargesheet filed by EOW, ED, MCA, SFIO, or any other enforcement agency in the NSEL case.
Broker is a declared defaulter on any stock exchange as of the application date.
Automatic Cancellation Clause:
If a chargesheet is filed after settlement by any agency in relation to NSEL violations, the broker’s settlement under this scheme will automatically become void.
FAQs Availability:
SEBI will publish FAQs on its website on from August 25, 2025, to February 25, 2026 to help brokers understand the scheme in detail.
VCF Settlement Scheme 2025
Scheme Start Date: July 21, 2025
Scheme End Date: January 19, 2026 (both days inclusive)
Last Date for Migration to AIF Regime: July 19, 2025
Overview
When SEBI notified the Alternative Investment Funds (AIF) Regulations in May 2012, the older Venture Capital Funds (VCF) Regulations, 1996, were repealed. However, VCFs already registered under the old rules continued to be regulated by them until their existing funds or schemes were wound up.
Some of these VCFs are still holding unliquidated investments beyond the end of their fund tenure and haven’t yet been able to wind up.
To address this, SEBI allowed such VCFs to migrate to the AIF regime (as per a circular dated August 19, 2024), with an extra year granted to liquidate investments and wind up. The last date to apply for migration is July 19, 2025.
What is the VCF Settlement Scheme 2025?
This scheme allows eligible VCFs, who have completed migration to the AIF regime, to settle any regulatory actions that may arise due to holding on to unliquidated investments after the scheme’s tenure expired.
Eligibility:
VCFs with at least one scheme whose tenure has expired but is not yet wound up
Must have completed migration to AIF regulations
How to Apply:
Submit a Settlement Application in the specified SEBI format
Pay a non-refundable fee of ₹25,000 + 18% GST
Use SEBI’s dedicated payment gateway (details on SEBI website)
Settlement Costs:
Delay Charges for Winding Up Schemes:
₹1,00,000 for delay up to 1 year
Additional ₹50,000 for each additional year or part of it
Charges Based on Unliquidated Investment Value:
Important Conditions:
Migration must be completed before applying for settlement.
All costs related to the settlement must be borne by the Investment Manager/Sponsor not recoverable from the fund or investors.
SEBI may take enforcement action after July 19, 2025, against VCFs who don’t comply. The last date for applying under this settlement scheme shall be 6 months, which is from July 19, 2025 to January 19, 2026 or any other date as may be notified by SEBI.
Ease of Doing Investment – Special Window for Re-lodgement of Transfer Requests of Physical Shares
Circular: SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/97 dated July 02, 2025
Overview:
This SEBI exercising its powers under Section 11(1) of the SEBI Act, 1992, read with Regulation 102 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 and the SEBI (Registrars to an Issue and Share Transfer Agents) Regulations, 1993, issued a circular introducing a special window for investors to re-lodge transfer requests for physical shares that were originally submitted before April 1, 2019, but were rejected, returned, or left unattended due to documentation issues or other deficiencies.
Earlier, March 31, 2021, was set as the final cut-off for such re-lodgements. However, based on industry feedback and expert panel recommendations, SEBI is now offering investors one final opportunity to re-lodge these requests during a six-month window.
Key Provisions:
Special Window Duration
Opens: July 07, 2025
Closes: January 06, 2026
Applies to: Transfer deeds lodged before April 01, 2019 but but returned, not attended or rejected/not processed.
Issuance in Demat Mode Only
All re-lodged shares including pending cases with listed companies or RTAs under this window will be transferred only in demat form. The usual demat process must be followed.
Eligible Requests Include:
Transfer requests rejected or returned due to documentation/process issues
Transfer requests pending with RTAs or listed companies as of the current date
Publicity Requirement
Listed companies, RTAs, and stock exchanges must publicize this special window bi-monthly across print and social media during the six months.
Focused Handling by RTAs/Companies
Dedicated teams must be assigned to process these re-lodgement requests promptly.
Monthly Reporting
RTAs and listed companies must submit monthly reports to SEBI on:
The publicity efforts made
Status of shares re-lodged for transfer-cum-demat (in a format given in Annexure-A)
Master Circular for Real Estate Investment Trusts (REITs)
Circular: SEBI/HO/DDHS-PoD-2/P/CIR/2025/99 dated 11, 2025
Overview
SEBI exercising its powers under Section 11(1) of the SEBI Act, 1992 and Regulation 33 of the SEBI (Real Estate Investment Trusts) Regulations, 2014, has put together all the rules and guidelines for Real Estate Investment Trusts (REITs) into one single Master Circular. This makes it easier for everyone involved REITs, investors, intermediaries, exchanges, and others to find everything they need in one place.
Key points:
Over the years, SEBI has issued several circulars to regulate REITs. This Master Circular brings all of them (up to July 11, 2025) into one document for easier reference.
Effective immediately:
The circular comes into force from the date it’s issued.
What happens to earlier circulars?
They’re now superseded (i.e., replaced) by this one.
But any actions already taken like approvals, investigations, or penalties will remain valid and be treated as if they were done under this new circular.
Applications already submitted will also continue as before, under the new rules.
Ongoing responsibilities:
REITs and related entities must continue to submit reports as laid out in this Master Circular.
Stock exchanges are told to share this circular on their websites.
Legal basis:
This circular is issued under SEBI’s powers from the SEBI Act, 1992, and the REIT Regulations, 2014, to protect investors and regulate the securities market.
Master Circular for listing obligations and disclosure requirements for Non-convertible Securities, Securitized Debt Instruments and/or Commercial Paper
Circular Number: SEBI/HO/DDHS/DDHS-PoD-1/P/CIR/2025/0000000103, dated July 11, 2025
Overview
To make things simpler for issuers and intermediaries, SEBI ), under Sections 11(1) and 11A(2) of the SEBI Act, 1992, Rule 19(7) of the Securities Contracts (Regulation) Rules, 1957, and Regulation 101 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, has bundled all relevant directions, obligations, and disclosure requirements for Non-Convertible Securities (NCS), Securitized Debt Instruments (SDIs) and Commercial Paper (CP) (issued till June 30, 2025) into one Master Circular. This replaces the earlier Operational Circular and becomes the single point of reference.
Key Provisions:
Effective Immediately:
This Master Circular is now in force. The circulars listed in Annex-1 are no longer valid they’ve been superseded.
Continuity of Past Actions:
Any approvals, applications, or actions taken under the now-rescinded circulars will be treated as valid under this new Master Circular.
Pending applications will continue without disruption.
Stock Exchanges, Issuers & Stakeholders Must:
Comply with this circular and align internal systems and processes with the new framework
Share the circular with listed entities
Publish it on their websites
Update internal systems to follow the new rules
Monitor compliance and update by-laws if needed
Create awareness among stakeholders
Legal Authority:
This circular is issued under:
Section 11(1) & 11A(2) of the SEBI Act, 1992
Rule 19(7) of the Securities Contracts (Regulation) Rules, 1957
Regulation 101 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015
Master Circular for Credit Rating Agencies
Circular No.: SEBI/HO/DDHS/DDHS-POD2/P/CIR/2025/101, dated July 11, 2025
Overview
This Master Circular brings together all relevant SEBI circulars for Credit Rating Agencies into one document. These cover the operational procedures, obligations, conduct rules, inspection and investigation methods outlined under the CRA Regulations, 1999.
It’s meant to serve as a one-stop reference for all compliance requirements related to CRAs.
Applies to:
All Registered Credit Rating Agencies
Debenture Trustees
Issuers of listed/proposed Non-Convertible Securities, Securitized Debt Instruments, Municipal Debt Securities, Security Receipts, or Commercial Paper
Recognized Stock Exchanges
All SEBI-registered Depositories
Key Highlights:
Consolidation of Circulars:
All earlier circulars (issued until now) related to CRAs are now combined into this Master Circular.
The older circulars listed in the Appendix are officially superseded.
No Disruption to Past Actions:
Anything already done under the old circulars like approvals, filings, penalties, or investigations remains valid under the new circular.
Ongoing applications, penalties, rights, or obligations will be treated as if filed under this Master Circular.
Organized Content:
The circular is organized chapter-wise, covering different aspects like registration, obligations, and compliance standards for CRAs.
Legal Authority:
o Issued under Section 11(1) of the SEBI Act, 1992 and Regulation 20 of the CRA Regulations, 1999.
SEBI Master Circular for ESG Rating Providers (ERPs)
Circular No.: SEBI/HO/DDHS/DDHS-POD-2/P/CIR/2025/100, dated July 11, 2025
Overview
This Master Circular pulls together all the regulatory directions for ESG Rating Providers (ERPs) into one consolidated document. It outlines the procedural, operational, and disclosure requirements under the SEBI (Credit Rating Agencies) Regulations, 1999, as updated with the ERP framework (effective July 4, 2023).
The goal is to make it easier for ERPs and others in the market to access all applicable rules in one place.
Applies to:
All Registered ESG Rating Providers (ERPs)
Listed Entities
Recognised Stock Exchanges
SEBI-registered Depositories
Key Highlights:
Legal Backing
ERPs are regulated under the CRA Regulations. This circular is issued using powers under Section 11(1) of the SEBI Act, 1992 and Regulation 28H of the CRA Regulations.
What’s in This Circular?
o It replaces all earlier circulars relating to ERPs (listed in the Appendix).
o It details compliance obligations, disclosure norms, and monitoring mechanisms for ERPs.
o The content is updated and organized for clarity, with chapter-wise coverage.
Compliance is Mandatory
ERPs must implement all directions in this circular.
They should have proper systems and infrastructure in place.
The Board of Directors of the ERP is personally accountable for compliance.
What Happens to Past Circulars?
Actions already taken under old circulars remain valid and unaffected.
Any pending applications or enforcement actions also carry forward under this new circular.
Monitoring & Audit
Compliance will be monitored through the annual internal audit mandated under Regulation 28S of the CRA Regulations.
Effective Immediately
The circular takes effect from the date of issuance.
Definition Note
The term “listed entity” has the same meaning as in Regulation 2(1)(p) of the SEBI Listing Regulations, 2015.
SEBI Master Circular for Infrastructure Investment Trusts (InvITs)
Circular No.: SEBI/HO/DDHS-PoD-2/P/CIR/2025/102, dated July 11, 2025
Overview
SEBI has issued this Master Circular to bring together all existing guidelines for InvITs into one consolidated document. This includes every relevant circular issued up to July 11, 2025, to make compliance and reference easier for all stakeholders.
Issued to:
Bharat InvITs Association
All Infrastructure Investment Trusts (InvITs)
All parties to InvITs
Recognised Stock Exchanges
Registered Depositories
Intermediaries (Syndicate Banks, Stock Brokers, R&T Agents, Merchant Bankers, etc.)
Key Highlights:
Consolidation of Rules
All previous SEBI circulars relating to InvITs (listed in the Appendix) are superseded by this Master Circular.
This does not affect past actions anything already done or approved under older circulars remains valid.
Continued Applicability of Guidance
Any additional SEBI circulars, directions or guidance specific to InvITs will continue to apply alongside this circular and other laws.
No Disruption to Past Decisions
Registrations, approvals, inspections, applications, penalties, and legal actions done under the older circulars are still valid.
Ongoing matters will automatically carry forward under this new circular.
Compliance Reporting
InvITs and related entities must submit regular reports as required under this circular.
Stock exchanges must publish the circular on their websites.
Legal Backing
Issued under Section 11(1) of the SEBI Act, 1992
Also, under Regulation 33 of the SEBI (Infrastructure Investment Trusts) Regulations, 2014
SEBI (Certification of Associated Persons in the Securities Markets) (Amendment) Regulations, 2025
Notification: F. No. SEBI/LAD-NRO/GN/2025/251, dated July 14, 2025
Overview
SEBI has amended its 2007 regulations to update rules on certification for people working with registered intermediaries in the securities market, like brokers, portfolio managers, etc. These rules make sure that certain categories of associated persons (employees or professionals linked with intermediaries) are qualified and certified to carry out their roles.
Key Amendments
New Rule on Certification Requirement (Regulation 3(1))
SEBI now has the power to specify:
Who (which categories of people) need to be certified
Which intermediaries must they be certified for
When they need to be certified by
Any previous notifications issued by SEBI under this rule will continue to apply until explicitly withdrawn.
Old Rule Removed (Regulation 3(2))
This sub-regulation has been deleted. (It previously allowed SEBI to require certifications for persons not covered under the existing framework.)
Wording Tweaks (Regulation 3(4))
Slight language change for clarity:
The phrase now reads: “purposes of sub-regulation (1) may” instead of referring to both sub-regulations (1) and (2).
Clarification in Regulation 4(3)
The rule now says certification timelines will be “as may be specified by the Board” instead of referring only to a specific notification.
Updated Regulation 6
Anyone doing work covered under clauses (a) to (f) of Regulation 3(4) must not continue in that role unless they have the required SEBI-specified certification.
Effective Date: These amendments are in force from the date of publication in the Official Gazette i.e., July 14, 2025.
SEBI Master Circular for Portfolio Managers
Circular: SEBI/HO/IMD/IMD-POD-1/P/CIR/2025/104, dated July 16, 2025
Overview
SEBI has issued an updated Master Circular for Portfolio Managers. It combines all relevant rules, guidelines, and directions issued by SEBI up to March 31, 2025, so that everything they need to comply with is available in one place.
Key Highlights:
Why this update?
The previous Master Circular was issued on June 7, 2024 and covered circulars up to March 31, 2024. Since then, SEBI released more directions, so this new circular includes all updates till March 31, 2025.
What happens to the old circulars?
The 2024 Master Circular is now superseded.
Some older circulars (specifically Sr. Nos. 37–39 from the appendix of the previous Master Circular) are now rescinded, but only to the extent they apply to Portfolio Managers.
Other SEBI directions specific to Portfolio Managers that aren’t mentioned still remain in force.
Clarity in references:
SEBI has made formatting consistent throughout. So now, wherever a paragraph is referenced, it will be called “Paragraph/(s)” for clarity.
Legal continuity preserved:
Even though older circulars are rescinded:
Any actions already taken under them (like approvals, penalties, investigations, etc.) will still be valid.
Any applications made before this change will still be processed under the new Master Circular.
Rights, obligations, and legal proceedings under earlier circulars are not affected.'
What Portfolio Managers need to do now:
They must comply with the updated rules in this new circular.
They’re also expected to submit regular reports as mentioned in the circular.
Authority behind this:
This Master Circular is issued under Section 11(1) of the SEBI Act, 1992
Rights of Persons with Disabilities Act, 2016, and rules made thereunder-mandatory compliance by all Regulated Entities
Circular: SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/111, dated July 31, 2025
Overview
SEBI has issued this circular to ensure that persons with disabilities can fully and effectively participate in the securities market. All SEBI-regulated entities (REs) including stock exchanges, depositories, intermediaries like brokers, mutual funds, KYC agencies, and clearing corporations are now required to make their digital platforms accessible in line with the Rights of Persons with Disabilities (RPwD) Act, 2016 and the relevant rules.
This is a step toward inclusivity, ensuring digital access for all investors and users, regardless of disability.
Key Provisions
Scope of Applicability
Applies to all SEBI-regulated entities (REs) and market infrastructure institutions (MIIs).
Legal Basis for Compliance
Entities must align with the following specific provisions of the RPwD Act and Rules:
Section 40: Accessibility
Section 42: Access to ICT (Information & Communication Technology)
Section 46: Time limit for accessibility
Rule 15(1)(c): Accessibility standards under RPwD Rules, 2017
Mandatory Steps & Timelines
Within 1 Month:
Submit a list of all digital platforms offered to investors
Submit compliance/action-taken report
Within 45 Days:
Appoint an IAAP-certified accessibility auditor
Within 3 Months:
Conduct a digital Accessibility Audit
Within 6 Months:
Remediate audit findings and ensure full compliance
Ongoing Annual Compliance
Annual reporting within 30 days after each financial year, to:
Stock Exchanges/Depositories (for brokers/DPs)
BSE Administration & Supervision Limited (BASL) (for Investment Advisers)
SEBI (for all others)
INSOLVENCY AND BANKRUPTCY BOARD OF INDIA
Withdrawal of Form IP-1 for assignments under IBC Processes
Circular No. IBBI/CIRP/86/2025, dated: 14th July 2025
Overview:
The Insolvency and Bankruptcy Board of India (IBBI) has withdrawn Form IP-1, which was originally introduced in 2019 for Insolvency Professionals (IPs) to report assignments under various processes of the Insolvency and Bankruptcy Code, 2016 (IBC). This step aligns with recent digital and procedural changes implemented by the Board, including the rollout of revised reporting modules and forms.
Key Provisions:
Background of Form IP-1:
Form IP-1 was introduced through Circular No. IBBI/CIRP/023/2019 dated 14 August 2019. It was meant for IPs to report appointments under IBC roles like IRP, RP, Liquidator, Bankruptcy Trustee, etc.
Shift to Digital Reporting (Assignment Module):
In February 2025, through Circular No. IBBI/LIQ/82/2025, the Board mandated use of the Assignment Module on the IBBI portal for reporting all such appointments. This covered Corporate Insolvency Resolution Process (CIRP), Liquidation, Voluntary Liquidation, personal guarantor processes, and FSP proceedings.
Revised Forms Framework:
As of 1 June 2025, IBBI introduced new CIRP forms CP-1 to CP-5 via Circular No. IBBI/CIRP/85/2025 (dated 26 May 2025), replacing both Form IP-1 and older CIRP Forms 1–8.
Withdrawal of Form IP-1:
Given these changes, the requirement to submit Form IP-1 across all IBC processes is officially withdrawn from the date of this circular (14 July 2025).
Statutory Basis:
The circular is issued under Section 196 of the Insolvency and Bankruptcy Code, 2016, which empowers the IBBI to specify regulations and monitor insolvency professionals and processes.
Insolvency and Bankruptcy Board of India (Insolvency Resolution Process for Corporate Persons) (Fifth Amendment) Regulations, 2025
Notification No. IBBI/2025-26/GN/REG128, dated 4th July 2025
Overview:
The Insolvency and Bankruptcy Board of India (IBBI) has notified the Fifth Amendment to the CIRP Regulations, 2016, bringing in changes that strengthen the handling of avoidance transactions and ensure greater transparency in resolution plans. These amendments came into force upon publication in the Official Gazette.
Key Provisions:
Update to Information Memorandum (Regulation 36):
The information memorandum must now include subsequent updates after the insolvency commencement date.
It must also disclose details of all identified avoidance transactions, and filings related to fraudulent or wrongful trading, as referred in Regulation 35A(3A).
New Restrictions on Resolution Plans (Regulation 38(2A)):
A resolution plan cannot include assignment of avoidance transactions or fraudulent/wrongful trading claims unless:
(a) They were disclosed in the information memorandum, and
(b) All prospective resolution applicants were informed before the last date for submission of resolution plans.
This condition does not apply to plans that have already been submitted to the Adjudicating Authority under section 30(6) before the commencement of this amendment.
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