Summary: Participating as a shareholder in the Bajaj Auto buyback led the author to examine how the SEBI (Buy-Back of Securities) Regulations operate in practice. Rather than focusing on gains or the acceptance ratio, the author highlights that every buyback date is driven by prescribed legal timelines. The regulations require the buyback to open within four working days from the Record Date and the tendering period to remain open for five working days. Bajaj Auto announced the Record Date as 24 June, Issue Opening as 1 July, and Issue Closing as 7 July. Although the interval between the Record Date and the opening may initially appear lengthy, the computation is based on working days under the regulations. After excluding weekends and the Muharram stock market holiday, the issue opened on the fourth working day after the Record Date, and the tendering period remained open for exactly five working days. The author states that corporate dates are carefully planned by aligning regulatory timelines, stock exchange holidays, banking schedules, settlement cycles, and statutory requirements, and concludes that understanding the legal basis of corporate announcements provides insight into how compliance operates in practice.
When a listed company announces a share buyback, most investors immediately ask one question:
“How much profit can I make?”
As a Company Secretary, my first question is different:
“How did they arrive at these dates?”
Recently, while participating in the Bajaj Auto Buyback as a shareholder, I got the opportunity to see how the provisions of the SEBI (Buy-Back of Securities) Regulations work not just in theory, but in real life.
What fascinated me wasn’t the acceptance ratio or the gains—it was how every date in the buyback process was carefully driven by law.
The Law
The regulations prescribe strict timelines, including:
The buyback must open within 4 working days from the Record Date.
The tendering period must remain open for 5 working days.
The Reality
Bajaj Auto announced:
- Record Date: 24 June
- Issue Opening: 1 July
- Issue Closing: 7 July
At first glance, it may appear that there is a long gap between the Record Date and the opening of the issue.
But compliance is never based on a simple calendar.
It is based on “working days” as recognized under the regulations.
Once weekends and the Muharram stock market holiday are excluded, everything fits perfectly:
The issue opened on the 4th working day after the Record Date.
The tendering period remained open for exactly 5 working days, fully complying with the regulations.
The Bigger Learning
This experience reminded me that corporate dates are not randomly selected.
Behind every public announcement lies careful planning by professionals who align regulatory timelines, stock exchange holidays, banking schedules, settlement cycles, and statutory requirements.
As Company Secretaries, we often study these provisions in books. But witnessing the entire buyback process—from the public announcement and record date to tendering, acceptance, settlement, and receipt of consideration—made me appreciate how compliance comes alive in practice.
The biggest lesson?
Don’t just read corporate announcements.
Read the law behind the dates.
That’s where the real story of corporate governance begins.
#CompanySecretary #SEBI #Buyback #CorporateLaw #CorporateGovernance #Compliance #StockMarket #LegalCompliance #CSLife #CS #CorporateAction
CS Anant Agarwal

