The SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 impose extensive website disclosure obligations on listed companies to ensure transparency, investor protection, and effective corporate governance. Listed entities are required to publish key information including related party transactions, materiality policies, dividend distribution policies, annual reports, shareholding patterns, financial results, corporate governance reports, credit ratings, analyst meeting schedules, investor presentations, and transcripts of earnings calls. The regulations also mandate disclosure of board and committee composition, independent director appointment terms, vigil mechanism policies, whistleblower framework, related party transaction policies, material subsidiary policies, and details of investor grievance officers. Certain disclosures must remain accessible on company websites for a minimum of five years. Top listed entities are additionally required to disclose dividend distribution policies and subsidiary financial statements. The framework also covers disclosures relating to secretarial compliance reports, employee benefit schemes, deviations in fund utilization, and archival policies, thereby strengthening accountability, governance standards, and investor access to material corporate information.
Mandatory Disclosures required to disclose on website of a listed companies as per SEBI (LODR) 2015
1. The listed entity shall submit to the stock exchanges disclosures of related party transactions in the format as specified by the Board from time to time, and publish the same on its website (Regulation 23(9))
2. The listed entity shall frame a policy for determination of materiality, based on criteria specified in this sub-regulation, duly approved by its board of directors, which shall be disclosed on its website. (Regulation 30(4)(ii))
3. The board of directors of the listed entity shall authorize one or more Key Managerial Personnel for the purpose of determining materiality of an event or information and for the purpose of making disclosures to stock exchange(s) under this regulation and the contact details of such personnel shall be also disclosed to the stock exchange(s) and as well as on the listed entity’s website. (Regulation 30(5))
4. The listed entity shall disclose on its website all such events or information which has been disclosed to stock exchange(s) under this regulation, and such disclosures shall be hosted on the website of the listed entity for a minimum period of five years and thereafter as per the archival policy of the listed entity, as disclosed on its website.
5. The listed entity shall submit to the stock exchange and publish on its website
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- a copy of the annual report sent to the shareholders along with the notice of the annual general meeting on or before the commencement of dispatch to its shareholders;
- in the event of any changes to the annual report, the revised copy along with the details of and explanation for the changes shall be sent not later than 48 hours after the annual general meeting.
6. The top 1000 listed entities based on market capitalization shall formulate a dividend distribution policy which shall be disclosed on the website of the listed entity and a web-link shall also be provided in their annual reports. (Regulation 43A(1))
7. The listed entity shall disseminate the following information under a separate section on its website: (Regulation 46(1)) details of its business;
- Memorandum of Association and Articles of Association;
- Brief profile of board of directors including directorship and full-time positions in body corporates;
- terms and conditions of appointment of independent directors;
- composition of various committees of board of directors;
- code of conduct of board of directors and senior management personnel;
- details of establishment of vigil mechanism/ Whistle Blower policy;
- criteria of making payments to non-executive directors , if the same has not been disclosed in annual report;
- policy on dealing with related party transactions;
- policy for determining ‘material’ subsidiaries;
- details of familiarization programmes imparted to independent directors including the following details:-
- number of programmes attended by independent directors (during the year and on a cumulative basis till date),
- number of hours spent by independent directors in such programmes (during the year and on cumulative basis till date), and
- other relevant details
- the email address for grievance redressal and other relevant details;
- contact information of the designated officials of the listed entity who are responsible for assisting and handling investor grievances;
- financial information including:
- notice of meeting of the board of directors where financial results shall be discussed;
- financial results, on conclusion of the meeting of the board of directors where the financial results were approved;
- complete copy of the annual report including balance sheet, profit and loss account, directors report, corporate governance report etc
- shareholding pattern;
- details of agreements entered into with the media companies and/or their associates, etc;
- Schedule of analysts or institutional investors meet at least two working days in advance (excluding the date of the intimation and the date of the meet)
- Presentations prepared by the listed entity for analysts or institutional investors meet, post earnings or quarterly calls prior to beginning of such events
- Audio recordings, video recordings, if any, and transcripts of post earnings or quarterly calls, by whatever name called, conducted physically or through digital means, in the following manner:
- The audio recordings shall be promptly made available on the website and in any case, before the next trading day or within twenty-four hours from the conclusion of such calls, whichever is earlier;
- the video recordings, if any, shall be made available on the website within forty-eight hours from the conclusion of such calls;
- the transcripts of such calls shall be made available on the website along with simultaneous submission to recognized stock exchanges within five working days of the conclusion of such calls:
- new name and the old name of the listed entity for a continuous period of one year, from the date of the last name change
- items in sub-regulation (1) of regulation 47
- all credit ratings obtained by the entity for all its outstanding instruments, updated immediately as and when there is any revision in any of the ratings.
- separate audited financial statements of each subsidiary of the listed entity in respect of a relevant financial year, uploaded at least 21 days prior to the date of the annual general meeting which has been called to inter alia consider accounts of that financial year
- secretarial compliance report as per sub-regulation (2) of regulation 24A of these regulations;
- disclosure of the policy for determination of materiality of events or information required under clause (ii), sub-regulation (4) of regulation 30 of these regulations;
- disclosure of contact details of key managerial personnel who are authorized for the purpose of determining materiality of an event or information and for the purpose of making disclosures to stock exchange(s) as required under sub regulation (5) of regulation 30 of these regulations;
- disclosures under sub-regulation (8) of regulation 30 of these regulations;
- statements of deviation(s) or variation(s) as specified in regulation 32 of these regulations;
- dividend distribution policy by listed entities based on market capitalization as specified in sub-regulation (1) of regulation 43A;
- annual return as provided under section 92 of the Companies Act, 2013 and the rules made thereunder
- Employee Benefit Scheme Documents, excluding commercial secrets and such other information that would affect competitive position of the listed entity, framed in terms of the provisions of Securities and Exchange Board of India (Share Based Employee Benefits and Sweat Equity) Regulations, 2021:
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