COVID-19: A Pandemic has proved to be disruption to all the Countries around. The Government of India, considering the situation has locked down the country for 21 days commencing from March 25,2020. This lockdown and disease has stand stilled the country and has affected the Business Activities.
By understanding the disruption of the business activities, the Government of India has announced certain relaxations with relation to the statutory compliances under various laws, which will help the business organizations to deal with the compliances considering the threat of novel Coronovirus during such lockdown situations. The following Article only covers the relaxation granted by SEBI under SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 (‘LODR’)
Page Contents
- 1. Filings w.r.t SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 (‘LODR’)
- 2. Relaxation of time gap between two board / Audit Committee meetings:
- 3. Conduct of Committee meetings –Nomination and Remuneration Committee, Stakeholders Relationship Committee and Risk Management Committee
- 4. Publication of advertisements in the newspapers:
1. Filings w.r.t SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 (‘LODR’)
| Sl.No | Regulation and associated filling | Filings | Relaxation w.r.t the quarter/half year/yearly ending March 31,2020 | |||
| Frequency | Due within | Due Date | Extended Date | Period of Relaxation | ||
| a) | Regulation 7(3)- Compliance Certificate on share transfer facility | Half yearly | One month of the end of each half of the financial year | April 30, 2020 | May 31, 2020 | 1 month |
| b) | Regulation 13(3)- Statement of Investor complaints | Quarterly | 21 days from the end of each quarter | April 21,2020 | May 15, 2020 | 3 weeks(appx.) |
| c) | Regulation 24A- Secretarial Compliance report | Yearly | 60 days from the end of the financial year | May 30, 2020 | June 30, 2020 | 1 month |
| d) | Regulation 27(2)-Corporate Governance report | Quarterly | 15 days from the end of the quarter | April 15, 2020 | May 15, 2020 | 1 month |
| e) | Regulation 31-Shareholding Pattern | Quarterly | 21 days from the end of the quarter | April 21, 2020 | May 15, 2020 | 3 weeks (appx.) |
| f) | Regulation 33 -Financial Results | Quarterly | 45 days from the end of the quarter for quarterly results | May 15, 2020 | June 30, 2020 | 45 days |
| Annual | 60 days from the end of Financial Year for Annual Financial Results | May 30, 2020 | June 30, 2020 | 1 month | ||
| g) | Regulation 40(9)-Certificate from Practicing Company Secretary on timely issue of share certificates | Half yearly | 1month of the end of each half of the financial year | April 30, 2020 | May 31,2020 | 1 month |
| h) | Regulation 44(5) -Holding of AGM by top 100 listed entities by market capitalization for FY 19-20 | Annual | Within a period of 5 months from the date of closing of the financial year | August 31, 2020 | September 30, 2020 | 1 month |
2. Relaxation of time gap between two board / Audit Committee meetings:
| Provision | Requirement | Relaxation |
| Regulation 17(2) | The board of directors shall meet at least four times a year, with a maximum time gap of one hundred and twenty days between any two meetings. | The board of directors and Audit Committee of the listed entity are exempted 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 the board of directors /Audit Committee shall ensure that they meet atleast four times a year, as stipulated under regulations 17(2) and 18(2)(a) of the LODR Regulations. |
| Regulation 18(2)(a) | The audit committee shall meet at least four times in a year and not more than one hundred and twenty days shall elapse between two meetings |
3. Conduct of Committee meetings –Nomination and Remuneration Committee, Stakeholders Relationship Committee and Risk Management Committee
| Sl No | Regulation | Requirement | Frequency | Due Date | Extended Date | Period of Relaxation |
| a. | Regulation 19(3A) | The nomination and remuneration committee shall meet at least once in a year | Yearly | March 31, 2020 | June 30, 2020 | 3 months |
| b. | Regulation 20(3A) | The Stakeholders Relationship committee shall meet at least once in a year. | ||||
| c. | Regulation 21(3A) | The Risk Management Committee shall meet at least once in a year. |
4. Publication of advertisements in the newspapers:
To exempt publication of advertisements in newspapers for information such as notice of the board meeting, financial results etc. as required under regulation 47 for all events scheduled till May 15, 2020.
In the current lockdown, the relaxations granted by SEBI from a few of the compliance requirements will definitely grant temporary immunity to the management and the concerned/ responsible person of the Companies .
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