BSE issued relaxations granted in relation to compliance with various provisions on account of COVID-19 pandemic
Considering the hardships faced by the listed entities due to the lockdown pursuant to the COVID-19 Pandemic, SEBI has issued various circulars notifying relaxations in the timelines by which the compliance filing required under certain provisions of the aforementioned regulations, is to be reported.In view of the developments arising due to the spread of the COVID-19 pandemic, a need for temporary relaxations in compliance with certain deadlines in various SEBI Regulation is warranted by the Board, due to the prevailing travel restrictions and various other logistical challenges.
The details of the reliefs provided by BSE to listed entities in reference to compliance requirements are explained here under. Also, SEBI feels to amend various regulations as per the need of the time. Also, in the wake of current scenario of lockdown in country, SEBI has issued relaxations granted in relation to compliance with various provisions on account of COVID-19 pandemic for processing various investor requests pertaining to Compliance and disclosures to be made under SEBI Regulations and various SEBI circulars.
Thus, BSE vide Circular No. LIST/COMP/9/2020-21 dated 27.04.2020 after considering the current situation due to COVID 19 states relaxations granted in relation to compliance with various provisions on account of COVID-19 pandemic
Thus, BSE vide Circular No. LIST/COMP/9/2020-21 dated 27.04.2020 states:
SEBI (LODR) Regulations, 2015, SEBI (SAST) Regulations, 2011 and SEBI (D&P) Regulations, 2018 require listed entities to submit various disclosures to the Exchange on various due dates.
Considering the hardships faced by the listed entities due to the lockdown pursuant to the COVID-19 Pandemic, SEBI has issued various circulars notifying relaxations in the timelines by which the compliance filing required under certain provisions of the aforementioned regulations, is to be reported.
A comprehensive list of the revised timelines based on the compilation of various circulars is enclosed as Annexure I for your ease of reference. We hope that this ready reckoner would assist your company to comply in a timely manner.
Annexure 1- Calendar for revised timelines for submission of compliance filings under various Regulations due to COVID-19 pandemic
| S. No | Regulation | Due Date | Revised Due Date |
| 1 | LODR Regulation 7 (3) – Share Transfer Agent | April 30,2020 | May 31,2020 |
| 2 | LODR Regulation 13 (3) – Statement of Grievance Redressal Mechanism | April 21,2020 | May 15,2020 |
| 3 | LODR Regulation 24A – relating to filing of Secretarial Compliance Report | May 30,2020 | June 30, 2020 |
| 4 | LODR Regulation 27(2) – filing of Corporate Governance Report | April 15, 2020 | May 15, 2020 |
| 5 | LODR Regulation 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. | Board meetings in all cases – 2 working days in respect of Board Meetings held till July 31, 2020. |
| 6 | LODR Regulation 31 relating to Shareholding Pattern | April 21, 2020 | May 15, 2020 |
| 7 | LODR Regulation 33 relating to Financial Results (Quarterly) | May 15, 2020 | June 30, 2020 |
| 8 | LODR Regulation 33 relating to Financial Results (Annually) | May 30, 2020 | June 30, 2020 |
| 9 | LODR Regulation 39 (3) relating to Intimation to Stock Exchanges regarding loss of share certificates and issue of the duplicate certificates | 2 days from getting information | No penalty for delay in intimation made between March 1 to May 31, 2020 |
| 10 | LODR Regulation 52 relating to Financial Results (half yearly) for Debt Listed Companies | May 15, 2020 | June 30, 2020 |
| 11 | LODR Regulation 40(9) – Certificate from Practicing Company Secretary on timely issue of share certificates | May 30, 2020 | June 30, 2020 |
| 12 | LODR Regulation 44(5) relating to holding of AGM by top 100 listed entities by market capitalization for FY 19-20 | April 30, 2020 | May 31, 2020 |
| 13 | having financial year end as March 31, 2020 | August 31, 2020 | September 30, 2020 |
| 14 | having financial year end as December 31, 2019 | May 31, 2020 | September 30, 2020 |
| 15 | SAST Disclosure filings for the financial year ending March 31, 2020 under Regulations 30(1), 30(2) and 31(4) of the SEBI (SAST Regulations). | Extended to June 01, 2020. | |
| 16 | SEBI (D & P) Regulations, 2018 – Regulation 74(5) | Equivalent period of lock down declared by Government of India i.e. 21 days, over and above the prescribed time limits | |
| 17 | SEBI (D & P) Regulations, 2018 – Regulation 76 regarding Reconciliation of share capital audit report | Equivalent period of lock down declared by Government of India i.e. 21 days, over and above the prescribed time limits | |
| 18 | SEBI (Buy-back of Securities) Regulations, 2018 – Regulation 24(i)(f) relating to minimum time between buy back and raising of funds | Temporary relaxation in the period of restriction provided in Regulation 24(i)(f) from “one year” to “six months” Applicable up to December 31, 2020 only | |
Disclaimer: The Article is based on the Relevant Provisions and as per the information existing at the time of the preparation. In no event I shall be liable for any direct and indirect result from this Article. This is only a knowledge sharing initiative.
The Author – CS Deepak Seth (Associate Partner at Helpinghands Professionals LLP) and can be reached at [email protected] or 9910248911.
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