SEBI inserted a new regulation i.e. Regulation 24A and made effective for the financial year ended March 31, 2019 in the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 (SEBI (LODR) Regulations) which mandated the requirements of annexing a Secretarial Audit report in a specified format for the listed entity and all its material unlisted subsidiaries.
Further, all listed companies in addition to Secretarial Audit Report, required to submit Annual Secretarial Compliance Report to the stock exchanges within 60 days of closure of financial year in such form as may be prescribed with effect from the year ended March 31, 2019 i.e. on or before 30th May every year.
Annual Secretarial Compliance Report (“ASCR”) restricts itself to only SEBI Act and its regulations, circulars issued thereunder.
Important Point: (“ASCR”) unlike Secretarial Audit is applicable only to Listed Entities (Not applicable to Material Unlisted Subsidiary)
For Format for annual secretarial audit report and annual secretarial compliance report click the below mentioned link
In terms of Regulation 15 of SEBI(LODR) Regulations, following listed entities are not required to submit Annual Secretarial Compliance Report
Listed entity having paid up equity share capital not exceeding rupees ten crore and net worth not exceeding rupees twenty five crore, as on the last day of the previous financial year:
Provided that where the provisions of regulations 24A become applicable to a listed entity at a later date, it shall ensure compliance with the same within six months from such date]
[Provided further that once the above regulations become applicable to a listed entity, they shall continue to remain applicable till such time the equity share capital or the net-worth of such entity reduces and remains below the specified threshold for a period of three consecutive financial years.]
Listed entity which has listed its specified securities on the SME Exchange:
[Provided that for other listed entities which are not companies, but body corporate or are subject to regulations under other statues, the provisions of corporate governance provisions as specified in regulation [24A] shall apply to the extent that it does not violate their respective statutes and guidelines or directives issued by the relevant authorities.]
INFORMATION REQUIRED FOR ISSUING ANNUAL SECRETARIAL COMPLIANCE REPORT:-
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