Compliance Relaxations by SEBI amidst COVID-19
Amidst unprecedented outbreak of pandemic coronavirus (Covid-19), the Securities and Exchange Board of India (SEBI) has granted temporary relaxation to Equity listed entities in relation to compliance with certain deadlines under various provisions of the SEBI regulations. SEBI has granted the said relaxations vide its circulars dated March 19, 2020, March 23, 2020, March 26, 2020, March 27, 2020, and April 13, 2020.
In this article, an effort has been made to consolidate all the above relaxations and present a brief summary stating the due dates and revised due dates in respect of compliances to be done by the Listed Companies whose equity shares are listed on Stock Exchange(s).
Relaxations from Compliances of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015
| Sr. No. | Regulation | Compliance details | Due date | Revised due date |
| 1 | 7(3) | Compliance Certificate on Share Transfer Facility on maintaining physical and electronic transfer facility. | 30 April, 2020 | 31 May, 2020 |
| 2 | 13(3) | Statement of Investor Grievances | 21 April, 2020 | 15 May, 2020 |
| 3 | 24A read with circular dated February 8, 2019 | Secretarial Compliance Report | 30 May, 2020 | 30, June, 2020 |
| 4 | 27(2) | Corporate Governance report | 15 April, 2020 | 15 May, 2020 |
| 5 | 29(2) | Prior intimation to stock exchanges about meetings of the board | – at least 5 days before the meeting if financial results are to be considered – 2 working days in other cases. | 2 days, for board meetings held till July 31, 2020. |
| 6 | 31 | Shareholding Pattern | 21 April, 2020 | 15 May, 2020 |
| 7 | 33 | Financial Results (Quarterly) | 15 May, 2020 | 30 June, 2020 |
| 8 | 33 | Financial Results (Annually) | 30 May, 2020 | 30 June, 2020 |
| 9 | 40(9) | Certificate from Practicing Company Secretary on timely issue of share certificates | 30 April, 2020 | 31 May, 2020 |
| 10 | 44(5) | Holding of AGM by top 100 listed entities by market capitalization for FY 19-20 (Companies whose FY ends on 31 Dec, 2019 can also hold AGM upto 30 Sep, 2020) | 31 Aug, 2020 | 30 Sep, 2020 |
| 11 | 19(3A) | The Nomination and Remuneration Committee shall meet at least once in a year | 31 March, 2020 | 30 June, 2020 |
| 12 | 20(3A) | The Stakeholders Relationship Committee shall meet at least once in a year. | 31 March, 2020 | 30 June, 2020 |
| 13 | 21(3A) | The Risk Management Committee shall meet at least once in a year. [Applicable only for top 500 listed entities based on market capitalization] | 31 March, 2020 | 30 June, 2020 |
| Regulation | Compliance | Relaxation | |
| 14 | 17(2) | Board Meeting Minimum 4 times in a year. (maximum time gap of 120 days between two board meetings). | Exemption from observing the maximum stipulated time gap between two meetings for the meetings held or proposed to be held between the period December 1, 2019 and June 30, 2020. However, they should meet atleast four times a year, as stipulated. |
| 15 | 18(2)(a) | Audit Committee Meeting Minimum 4 times in a year. (maximum time gap of 120 days between two board meetings). | Exemption from observing the maximum stipulated time gap between two meetings for the meetings held or proposed to be held between the period December 1, 2019 and June 30, 2020. However, they should meet atleast four times a year, as stipulated. |
| 16 | 47 | Publication of advertisements in newspapers | Exemption from publication of advertisements in newspapers for all events scheduled till May 15, 2020 |
Relaxation from Compliances of SEBI (Substantial Acquisition of Shares and Takeovers) Regulations, 2011
| Sr.No. | Regulation | Compliance | Extended due date |
| 1 | 30(1),30(2), 31(4) | Disclosure filings by Persons/Promoters/PAC for FY ending 31 March, 2020 | June 01, 2020 |
Relaxation from Compliances of SEBI (Depositories and Participants) Regulations, 2018
| Sr.No. | Regulation | Compliance | Extended due date |
| 1 | 74(5), 76 | Reconciliation of Share Capital Audit Report | 21 days, over and above the lock down declared by Government of India |
Relaxation from Compliances of SEBI Circular No. HO/DDHS/CIR/P/2018/144 dated November 26, 2018:
| Sr. No. | Compliance details | Due date | Revised due date |
| 1 | Large Corporates Disclosure: | ||
| Initial Disclosure | April 30, 2020 | May 31, 2020 | |
| Annual Disclosure | May 15, 2020 | June 30, 2020 |
Relaxation of the operation of the SEBI circular no. SEBI/HO/CFD/CMD/CIR/P/2020/12 dated January 22, 2020 on Standard Operating Procedure
| Sr. No. | Compliance details | Date of Operation | Revised date of operation |
| 1 | Standard Operating Procedure (SOP) on imposition of fines and other enforcement actions for non-compliances with provisions of the LODR | on or after March 31, 2020 | on or after June 30, 2020 |
Relaxation granted vide SEBI Circular No. SEBI/HO/MIRSD/RTAMB/CIR/P/2020/59 dated April 13, 2020
In wake of the current nationwide lock down of 21 days as directed by Government of India due to Covid-19 and marginal/skeleton staff strength of RTAs / Issuer companies, the following relaxation has been given to Registrars to an Issue and Share Transfer Agents / Issuer Companies.
| Sr. No | Compliance details | Revised Due Date |
| 1 | Processing of Remat Requests, Transmission Requests, Request for Issue of Duplicate Share Certificates, Requests for Name Deletion/ Name Change/ Transposition/ Pending Share Transfers (Re-lodgement cases in the case of share transfers), Requests for Consolidation / Split / Replacement of Share Certificates / Amalgamation of Folios | *Within 21 days, over and above the prescribed time limits. |
| 2 | Handling Investor Correspondence / Grievances / SCORES complaint |
* In the event of further extension in the lock down period as directed by Government of India / State Governments, additional relaxation in prescribed timelines for equal number of extended days in lock down is also being given to intermediaries / market participants.
Referred SEBI Circulars:
- SEBI/HO/CFD/CMD1/CIR/P/2020/3 dated March 19, 2020
- SEBI/HO/DDHS/ON/P/2020/41 dated March 23, 2020
- SEBI/HO/CFD/CMD1/CIR/P/2020/48 dated March 26, 2020
- SEBI/HO/CFD/DCR1/CIR/P/2020/49 dated March 27, 2020
- SEBI/HO/MIRSD/RTAMB/CIR/P/2020/59 dated April 13, 2020
- SEBI/HO/CFD/CMD1/CIR/P/2020/71 dated April 23, 2020