The Securities and Exchange Board of India (SEBI), on November 5, 2026, issued revised comprehensive FAQs on the SEBI (Prohibition of Insider Trading) Regulations, 2015, incorporating regulatory amendments, stakeholder queries and suggestions, and clarifications on various compliance requirements. The revised FAQs supersede the earlier comprehensive FAQs dated December 31, 2024.
The revised FAQs clarify that creation, invocation, and revocation of pledges, as well as borrowing and lending under the Securities Borrowing and Lending (SLB) mechanism, constitute trading under the PIT Regulations. The prohibition on trading while in possession of Unpublished Price Sensitive Information (UPSI) applies to all insiders, including persons who are not designated persons but have access to UPSI. Transmission of shares is also covered, although trading window closure, pre-clearance and contra-trade requirements are exempted.
The FAQs clarify that the requirement to maintain a Structured Digital Database (SDD) applies to listed companies, intermediaries and fiduciaries handling UPSI. The database must record details of UPSI and the persons sharing and receiving it, along with their PAN or other unique identification. SDD records must be updated whenever information is transmitted and preserved for at least eight years after completion of the relevant transactions. The Board of Directors or head of the organisation and the Compliance Officer are responsible for ensuring data confidentiality, integrity and security.
Further clarifications cover pledge-related disclosures, trading plans, pre-clearance, trading window closure and contra-trade restrictions. A trading plan has no prescribed minimum or maximum duration but is subject to a 120-calendar-day cooling-off period after public disclosure. Price limits are optional, while the value or quantity, nature and execution date or period of trades must be specified. Pre-clearance is not required for trades executed under an approved trading plan.
Please refer to the document attached below for more details.
