SEBI has proposed amendments to the SEBI (Infrastructure Investment Trusts) Regulations, 2014, and SEBI (Real Estate Investment Trusts) Regulations, 2014, to enhance ease of doing business (EoDB) and investor protection for Infrastructure Investment Trusts (InvITs) and Real Estate Investment Trusts (REITs). These measures include revising compliance requirements and operational guidelines, as recommended by SEBI’s Hybrid Securities Advisory Committee (HySAC), the Indian REIT Association (IRA), Bharat InvIT Association (BIA), and feedback from public consultations. SEBI’s proposals aim to streamline regulatory provisions such as transferring locked-in units among sponsor groups and align with best practices for hybrid securities. The amendments are part of SEBI’s broader efforts to facilitate growth and safeguard investments in a sector cumulatively managing assets worth over ₹6.82 lakh crores as of March 2024. The Board will consider these proposals and issue the necessary amendments and guidelines to implement these changes.
Securities Exchange Board of India
Measures towards Ease of Doing Business and Investor Protection for Infrastructure Investment Trusts and Real Estate Investment Trusts
1. Objective
1.1. This Board Memorandum proposes amendments to the SEBI (Infrastructure Investment Trusts) Regulations, 2014 (“InvIT Regulations“) and the SEBI (Real Estate Investment Trusts) Regulations, 2014 (“REIT Regulations“) to introduce measures for Ease of Doing Business (“EoDB”) and Investor Protection for Infrastructure Investment Trusts (“InvITs”) and Real Estate Investment Trusts (“REITs”).
This Board Memorandum also proposes to apprise the Board of the guidelines to be issued by SEBI by way of circulars to give effect to measures for EoDB and Investor Protection for InvITs and REITs.
2. Background
2.1. SEBI notified InvIT Regulations and REIT Regulations on September 26, 2014. As at March 31, 2024, the value of assets under REITs is Rs. 1,39,992 crores (4 REITs) and under InvITs is Rs. 5,42,385 crores (19 InvITs), cumulatively amounting to Rs. 6,82,377 crores.
2.2. SEBI Hybrid Securities Advisory Committee (“HySAC”) provides recommendations, inter-alia, on development and regulation of Hybrid Securities (i.e. InvITs and REITs) in India.
3. Recommendations on EoDB and Investor Protection
3.1. SEBI is in receipt of a series of recommendations from various forums, including but not limited to the working group for review of compliance requirements and EoDB for REITs and InvITs, the Indian REIT Association (“IRA”), Bharat InvIT Association (“BIA”) and HySAC. The recommendations received from these forums are primarily in the nature of promoting EoDB and enhancing investor protection.
3.2. Accordingly, considering the importance of such measures for EoDB and investor protection, the recommendations of the working group on EoDB (“Working Group”) were placed before the HySAC and based on the recommendations of HySAC and internal deliberations, SEBI issued a consultation paper titled “Consultation Paper on proposals for REITs and InvITs” seeking comments / views / suggestions from the public on the EoDB and investor protection measures. The recommendations of the HySAC along with public feedback have been considered for the proposals made to the Board.
4. Consultation
4.1. A total of 17 entities responded to the consultation paper with their views/ inputs/ suggestions. The respondents include industry associations, market participants, practicing company secretaries and investors. The respondents are broadly in agreement with the proposed measures and a summary of the respondents agreeing / partially agreeing / disagreeing to the proposals made in the consultation paper is placed at Table 1 of Annexure-A.
4.2. The suggestions received from various forums, HySAC recommendations on the same, feedback received pursuant to public consultation and views of SEBI thereon are summarized at Annexure A (Table 2 to Table 14). The reference to relevant tables of Annexure A has been made in the proposals mentioned in subsequent paras.
PART – A: Ease of Doing Business Measures
5. Permitting transfer of locked-in units amongst sponsor and sponsor group for REITs and InvITs (Table No. 2) Extant Regulatory Provision
5.1. Regulation 11(3) of REIT Regulations and Regulations 12(3), 12(3A), and 12(5) of InvIT Regulations mandate minimum unitholding requirements for sponsors and sponsor groups in case of initial offer which cannot be encumbered or transferred.
5.2. Further, Master Circulars for REITs and InvITs mandate a three-year lock-in for units allotted to sponsor through preferential issue, with specific provisions for excess holdings (Para 10.6.1 of the Master Circular for REITs and Para 7.6.1 of the Master Circular for InvITs).
5.3. SEBI (Issue of Capital and Disclosure Requirements) Regulations, 2018 (“ICDR Regulations”) on Transferability of Locked-In Units: Locked-in specified securities held by promoters can be transferred to another promoter or any person of the promoter group or a new promoter, subject to continuation of lock-in with the transferee (Regulations 14, 16, 22, 167, and 168 of the ICDR Regulations).
5.4. In contrast, REIT and InvIT regulations do not currently allow inter-se transfer of locked-in units among sponsors or sponsor groups, unlike the ICDR Regulations.
Proposal
5.5. In order to improve the ease of doing business, it is proposed to specify that locked-in units held by a sponsor or sponsor group entities at the time of initial offer or preferential issue under the REIT Regulations and InvIT Regulations and circulars issued thereunder may be transferred within the sponsor group entities subject to the condition that lock-in on such units shall continue for the remaining period with the transferee and such transferee shall not be eligible to transfer the units till the lock-in period stipulated under the regulations has expired.
5.6. Further, in case of a REIT / InvIT with multiple sponsors, to prevent any risk of name-lending and mis-selling, it is proposed that the locked in units held by a particular sponsor or its sponsor group entities can be transferred only within such sponsor or its own sponsor group entities, and not to the other sponsor or their sponsor group entities.
5.7. However, in case of a change in sponsor or conversion of Manager/ Investment Manager into self-sponsored Manager/ Investment Manager in compliance with the regulations, the outgoing sponsor or its sponsor group entities can transfer the locked in units to the incoming sponsor or its sponsor group entities or the self-sponsored Manager/Investment Manager or its shareholders or group entities of self-sponsored Manager/Investment Manager subject to the condition that the incoming sponsor or its group entities or the self-sponsored manager or its shareholders or group entities of self-sponsored Manager/Investment Manager shall meet the minimum unitholding requirements after the transfer.
6. Definition of common infrastructure under REIT Regulations (Table No. 3) Extant Regulatory Provision
6.1. REIT Regulations permit to hold common infrastructure for composite real estate projects, industrial parks and SEZ. However, the term common infrastructure is not defined in the REIT Regulations. Since the term common infrastructure is not defined, one interpretation which is possible is that these common infrastructure assets need to be necessarily co-located inside the composite real estate project.
6.2. The industry has requested that in order to allow REITs to provide green power to the occupants of the properties owned by REITs and also contribute on environmental and sustainability business initiatives and growth, it may be clarified that REITs are allowed to set up, invest in and acquire assets that provide common infrastructure facilities and amenities exclusively servicing one or more REIT portfolio assets such as captive power plants, district/retail heating and cooling systems, water treatment/ processing plants and waste treatment/processing plants, etc. regardless of whether such facilities or amenities are co-located within any single project.
Proposal
6.3. In order to promote ease of doing business amongst REITs, it is proposed to clarify that facilities or amenities such as power plants, district/retail heating and cooling systems, water treatment/ processing plants and waste treatment/processing plant and any facilities or amenities incidental to real estate business which exclusively supply or cater to, or are exclusively consumed by the REIT, its HoldCo(s) or SPV(s), irrespective of whether such facilities / amenities are co-located within any projects would be considered as common infrastructure.
6.4. Further it is proposed to clarify that the abovementioned facilities and amenities must be exclusively supplied and consumed by the REIT assets. However in case of common infrastructure any excess production / capacity, not consumed by the REIT, its HoldCo(s) or SPV(s), may be sold / supplied to a central or state grid / utility in accordance with the relevant central and state regulations, subject to the following conditions:
6.4.1. the manager shall make adequate disclosures in the annual report to demonstrate that the excess production / capacity could not be consumed by the REIT, its HoldCo(s) and SPV(s);
6.4.2. the credits or payments received from such sale / supply of excess production / capacity are applied towards the payments to be made by the REIT, its HoldCo(s) or SPV(s);
6.4.3. the manager shall make adequate disclosures related to sale / supply of such excess production / capacity in the annual report, including disclosures related to utilization of credits / payments received against such sale / supply, and the same shall be audited by the auditor of the REIT.”
6.5. Also in order to address the feedback of public to permit holding a common infrastructure projects in a company without any real estate or property, it is proposed to permit that common infrastructure projects can be held by REIT in a new company exclusively holding the common infrastructure, subject to the condition that the REIT and/or its underlying HoldCos / SPVs should own entire shareholding and interest in such company.
7. Inclusion of Non-Executive Directors in the Nomination and Remuneration Committee (NRC) of Managers/Investment Managers of REITS, InvITs and SM REITs (Table No. 4) Extant Regulatory Provision
7.1. As per Regulation 19(1) of LODR Regulations, Nomination and Remuneration Committees (NRC) must have at least three non-executive directors, with at least two-thirds being independent directors.
7.2. However, under Explanation (v) of Regulation 26A of REIT Regulations and Regulation 26G of InvIT Regulations, “non-executive director” is interpreted as “independent director,” requiring all NRC members for Managers/Investment Managers of REITs, including SM REITs and InvITs, to be independent directors.
7.3. This interpretation creates a stricter requirement for REITs and InvITs than LODR Regulations, mandating only independent directors on NRCs.
Proposal
7.4. It is proposed to modify the above provision thereby allowing for a mix of independent and non-executive directors in line with LODR Regulations. The same may be carried out by revising Explanation (v) of 26A of REIT Regulations and 26G of InvIT Regulations as under:
“(v) the expression “non-executive director” wherever it occurs, shall be read as “independent director” except for the purpose of Regulation 19(1) of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 as applicable to the manager/investment manager under the regulations.”
7.5. The proposed changes will also align the composition of NRCs in Managers/ Investment Managers of REITs including SM REITs and InvITs with the composition applicable for listed companies.
8. Amendment of Governance Norms for Quarterly Results Reporting – InvITs (Table No.5) Extant Regulatory Provision
8.1. Extract from Part A of Schedule VII (Governance Norms) of the InvIT Regulations reads as follow:
“The following minimum information to be placed before Board of Directors of the investment manager:
…..
(c)Quarterly results for the investment manager and its operating divisions or business segments.”
Proposal
8.2. It is proposed to amend the governance norms to provide clarity that the quarterly results specifically pertain to the InvITs rather than their investment managers, which is actually the intent of the regulations. This aims to ensure that quarterly reporting directly reflects the performance and financial health of the InvITs.
8.3. The proposed change will bring InvIT regulations in alignment with the REIT regulations wherein the corresponding provision clearly mention about the quarterly results of REIT (and not the Manager).
9. Allowing REITs, SM REIT Schemes and InvITs to deal in interest rate derivatives for hedging (Table No. 6) Extant Regulatory Provision
9.1. REIT Regulations and InvIT Regulations do not include any instrument to hedge the interest rate risk on the existing borrowings or future borrowings through interest rate swaps.
Proposal
9.2. In order to provide EoDB, it is proposed to permit REITs, SM REITs and InvITs to participate in Interest Rate Derivatives including Interest rate Futures, Forward rate Contracts and Interest Rate Swaps, solely with an objective of hedging an underlying interest rate risk in the existing borrowings, subject to the conditions that the hedge shall be an effective hedge as per the applicable Indian Accounting Standards, and relevant disclosures are made in the Annual Report.
9.3. Further in this regard, for valuation, the REITs, SM REITs and InvITs shall follow the norms applicable for Mutual Fund industry.
10. Review of conditions for enhanced borrowings beyond 49% by InvITs (Table No.7) Extant Regulatory Provision
10.1. As per Regulations 20 of InvIT Regulations, Borrowings above 49% are permitted only for project acquisition/development subject to certain conditions which inter-alia include track record of six continuous distributions in preceding financial years.
10.2. However, a feedback has been received that given the requirement of track record of six continuous distributions to be completed in preceding financial years, InvITs are required to wait till the completion of the financial year in which the 6th distribution was made, before accessing the debt capital to expand their assets base
Proposal
10.3. It is proposed to specify the following to be ensured by InvIT with regard to the six continuous distributions:
10.3.1. The six continuous distributions should be achieved across minimum six quarters (i.e. maximum one distribution per quarter shall be considered for computing six continuous distributions).
10.3.2. The track record of at least six continuous distributions should be met as at the end of the quarter preceding the date on which the enhanced borrowings are proposed to be made.
10.3.3. The distributions should be consistent with the distribution policy disclosed to the unitholders.
10.4. Further, it is proposed that w.r.t. distributions made by an InvIT, the cash flows generated from all assets, whether held by InvIT or any of the underlying SPVs or HoldCos has to be taken into consideration, irrespective of leverage.
10.5. Furthermore, since the proposal stated at para 10.4 above is relevant for REITs as well, it is proposed to make it applicable for REITs also.
11. Timeline for filling up of vacancy in the office of the board of directors of manager of REIT (including SM REIT) / investment manager of InvIT (Table No. 8) Extant Regulatory Provision
11.1. Board Composition Requirements for REITs and InvITs:
a) Regulations 26H(1) of InvIT Regulations / 26B(1) of REIT Regulations requires that Managers/Investment Managers of REITs/InvITs must have at least six directors, including a woman independent director.
b) At least half the board must consist of independent directors, as per Regulations 4(2)(e)(v) of InvIT Regulations / 4(2)(e)(iv) of REIT Regulations.
11.2. LODR Regulations (Regulations 25(6) and 17(1E)) allow up to three months to fill director vacancies caused by resignation, removal, or other reasons, provided the entity remains compliant with board composition requirements.
11.3. However, REIT and InvIT Regulations do not specify a timeline for filling board vacancies, making compliance difficult in cases of unforeseen circumstances like sudden resignation or death.
Proposal
11.4. It is proposed to specify the following provisions in the REIT Regulations and InvIT Regulations, in alignment with LODR Regulations:
11.4.1. For any vacancy in the office of a director of the manager / investment manager due to which the manager / investment manager becomes noncompliant with the requirement pertaining to composition of the Board of Directors specified in the REIT Regulations / InvIT Regulations, such vacancy shall be filled by the manager / investment manager as under:
a) if such vacancy arises due to expiration of the term of office of the director, then the resulting vacancy shall be filled not later than the date such office is vacated:
b) if such vacancy arises due to any reason other than as mentioned above,
then the resulting vacancy shall be filled at the earliest and not later than three months from the date of such vacancy.
12. Clarification on credit rating required to be obtained by REITs, InvITs and SM REITs for borrowings (Table No. 9) Extant Regulatory Provision
12.1. REIT Regulations and InvIT Regulations requires the Credit Rating Requirements for REIT and InvIT if borrowings exceed 25% of asset value. In case of SM REITs, similar provisions apply for borrowings beyond 25% at the scheme level.
12.2. For InvITs, borrowings above 49% require an “AAA” rating or equivalent and compliance with additional conditions, including specific fund utilization and distribution track records.
12.3. However, the current regulations do not specify whether the required credit rating is a loan-specific rating or a trust-level (issuer) rating.
Proposal
12.4. In order to provide explicit clarity in the REIT and InvIT Regulations, it is proposed to clarify that the credit rating required to be obtained under the REIT Regulations and InvIT Regulations is the issuer rating of the REIT / InvIT / scheme of SM REIT.
13. (Withdrawn, hence excised) (Table No. 10)
14. Expanding the asset base for REITs (including SM REITs) (Table No. 11) Extant Regulatory Provision
14.1. Regulation 2(1)(zi) of the REIT Regulations defines “real estate” or “property” as land and attached improvements, excluding assets mentioned under the “Harmonized Master List of Infrastructure Sub-sectors”, Ministry of Finance notification. Exceptions include hotels, hospitals, and common infrastructure forming part of composite real estate projects.
14.2. From the assets outlined in the Harmonized Master List of Infrastructure and sub-sectors therein, it is noted that certain assets fall either under definition of real estate under the REIT Regulations or under the definition of infrastructure under the InvIT Regulations, depending on certain criteria as to investment, location, size etc (e.g. Warehouses, Hotels, Data Centers, Hospitals, etc).
14.3. The feedback has been received is that the challenge faced by industry and market participants is that whether such assets falls under the definition of real estate under the REIT Regulation or infrastructure under the InvIT Regulations. Further, since REITs are presently not allowed to invest in assets forming part of Harmonized Master list of Infrastructure, it limits the scope of assets that can be housed under a REIT under the REIT Regulations and hamper the growth of REIT market in India.
Proposal
14.4. In order to expand the assets base for REITs from the existing list of assets under REIT Regulations, it is proposed to amend the REIT Regulations to provide that any asset that falls under the definition of ‘infrastructure’ can be considered as ‘real estate’ or ‘property’ (and hence eligible to be held as part of the REIT or SM REIT assets) if the following principle is met:
“Holding of such asset by the REIT (either directly or through underlying HoldCos / SPVs) shall be to earn fixed rental income from leasing out such asset and without assumption of any risk or reward arising out of or related to the operation of such asset.”
14.5. The following is a list of illustrative pre-conditions to ensure conformity with the aforementioned principle:
14.5.1. The business of REIT should be leasing out such assets and not operating such assets;
14.5.2. REIT / SPV / HoldCo shall carry no risk or return of the operating model directly / indirectly in any form or manner;
14.5.3. The income from such asset should be fixed rental income from leasing out such asset and not operating income from such asset;
14.5.4. The lease tenure on such assets should be long term in nature;
14.5.5. The rentals generated on such assets should be based on leasable area (such as Rs. X per square feet);
14.5.6. The assets should be leased out in cold shell conditions or in warm shell conditions with basic utilities only;
14.5.7. Since the REIT/HoldCo/SPV is simply leasing the asset and the asset is operated by the tenant, the license for operation of such assets should not be in the name of the REIT / SPV / HoldCo.
It may be noted that the pre-conditions stated above are illustrative in nature and the Investment Manager/Manager should ensure conformity with the principle stated.
PART – B: Investor Protection Measures
15. Review of investment in unlisted equity shares by REITs (Table No. 12) Extant Regulatory Provision
15.1. As per Regulations 18(4) and 18(5) of the REIT Regulations:
a) 80% of REIT assets: Must be invested in completed, income-generating properties.
b) 20% of REIT assets: Can be invested in other assets, including unlisted equity shares of companies deriving at least 75% of their operating income from real estate activity.
15.2. REITs can invest in unlisted equity shares outside HoldCos/SPVs
Proposal
15.3. Investment in unlisted equity shares other than the equity shares of HoldCo and SPVs is not permitted for InvITs under the InvIT Regulations. The proposal to not permit investment in unlisted equity shares of companies other than HoldCo and/or SPV as part of investment in real estate or property is taken as investor protection measure.
15.4. In order to align REIT Regulation with InvIT Regulations, it is proposed that REITs also shall not be permitted to invest in unlisted equity shares of companies other than HoldCo and/or SPV as part of investment in real estate or property.
15.5. Further, for any existing investment in the unlisted equity shares by the REITs, it is proposed to provide that any existing investment in unlisted equity shares shall be grandfathered and REITs may be allowed to hold on to such investments.
15.6. Further, as a carve out, it is proposed to allow REIT/InvIT to invest in unlisted equity shares of a company in the following cases mentioned in Paragraphs 15.7 and 15.8 below.
15.7. REIT/InvIT may be permitted to invest in an equity shares of a company which provides property management / property maintenance / housekeeping / project management and other incidental services to REIT/InvIT assets subject to the following conditions:
15.7.1. such services are exclusively provided to the REIT/InvIT and its HoldCo(s) and SPV(s)
Provided that in case of business parks, townships and other real estate projects, such services may be provided to other entities which are contiguous within the project subject to the following conditions:
15.7.1.1. revenue earned from other entities shall not exceed 20% of the total revenue of the company providing such services;
15.7.1.2. the basis for fees/charges charged to other entities and charged to the REIT and its HoldCo(s) and SPV(s) shall be identical and uniform; and
15.7.1.3. appropriate disclosure are made in the annual report in this regard.
15.7.2. The entire shareholding or interest in such company is held by REIT/InvIT either directly or through its underlying HoldCos/SPVs.
15.8. Further, it is proposed that REIT may also be permitted to invest in equity shares of a company holding common infrastructure subject to the following conditions:
15.8.1. Such common infrastructure investment is in compliance with REIT regulations
15.8.2. The entire shareholding or interest in such company is held by REIT and/or its underlying HoldCos/SPVs.
16. Review of investment in liquid mutual funds – REITs and InvITs (Table No. 13) Extant Regulatory Provision
16.1. Investment Limits for Liquid Instruments:
a) As per Regulations 18(5) of InvIT Regulations, InvITs may invest up to 20% of asset value in money market instruments, liquid mutual funds, or cash equivalents.
b) As per Regulation 18(5) of the REIT Regulations, REITs (excluding SM REITs) may invest up to 20% of asset value in money market instruments or cash equivalents but not in liquid mutual funds.
c) As per Regulation 26T(2) of the REIT Regulations, SM REITs may invest up to 5% of asset value in liquid assets, including liquid mutual funds.
16.2. Definition of Liquid Assets under Regulation 2(1)(ta) of the REIT regulations includes cash, liquid mutual funds, fixed deposits, government securities, treasury bills, repos, etc.
Rationale for change
16.3. REITs (excluding SM REITs) are not permitted to invest in liquid mutual funds, whereas the list of permitted investment instruments for InvITs in the InvIT Regulations inter-alia include liquid mutual funds. Further, as per REIT Regulations, upto five percent of the value of scheme of SM REIT assets are permitted to be invested in liquid assets which include liquid mutual funds.
16.4. Further, considering that the investment in liquid mutual funds would be a temporary deployment of funds by REITs and InvITs pending investment in suitable real estate or infrastructure opportunities, the investment in such funds should carry minimum credit risk.
Proposal
16.5. In order to align REIT Regulations with InvIT Regulations, it is proposed to permit REITs to invest in liquid mutual funds under permitted list of investments which should not be more than twenty percent of the value of REIT assets.
16.6. It is further proposed to permit investment by REITs (including SM REITs) and InvITs only in such liquid mutual fund schemes where the credit risk value is at least 12 and which falls under the Class A-I in the potential risk class matrix as specified by SEBI.
17. Roles and responsibilities of trustee for REITs, InvITs and SM REITs (Table No. 14) Extant Regulatory Provision
17.1. Regulation 9, under Chapter III, of the REIT Regulations provides the Rights and responsibilities of trustee which broadly includes:
a) Hold assets in trust for unitholders and oversee compliance with regulations, trust deed, and offer documents.
b) Monitor the manager’s activities, including regulatory compliance, conflict of interest, and financial disclosures.
c) Ensure timely distributions and maintain proper administration of trust property.
d) Facilitate unitholder meetings, review complaints, and oversee changes in manager control or appointment.
17.2. Similarly, Regulation 9, under Chapter III, of the InvIT Regulations provides the Rights and responsibilities of trustee of InvIT.
Proposal
17.3. In order to specify principles for trustees of REITs (including SM REITs) and InvITs to hold REIT/InvIT assets in trust for the benefit of the unitholders, it is proposed to amend the REIT Regulations and InvIT Regulations as under:
“Principles governing the trustees
“The core principles defining the role and responsibilities of trustees shall encompass transparency, accountability, due diligence, and compliance with REIT/InvIT regulations. Trustees are expected to act impartially in their fiduciary capacity, prioritize protection of the interests of unitholders, ensure effective management oversight over the Manager/Investment manager and the REIT/ InvIT, and maintain high standards of governance of the Manager/Investment manager and the REIT/InvIT.”
17.4. Further, it is proposed to provide an illustrative list of roles and responsibilities as mentioned in proposed Schedule XII and Schedule X as part of draft amendment notification placed at Annexure B and Annexure C respectively to guide the trustees.
17.5. However, it is reiterated that roles and responsibilities listed in proposed Schedule XII and Schedule X of Annexure B and Annexure C respectively are illustrative and not exhaustive. Trustees shall adopt additional measures or responsibilities crucial for meeting the overarching principles of their role and responsibilities stated in para 17.3 above.
17.6. Further, to ensure that trustees have adequate time to adapt to their expanded roles and responsibilities and to complete the necessary training and preparation, it is proposed that the expanded roles and responsibilities outlined above shall come into effect after the completion of six months from the date of official notification.
17.7. Furthermore, in the direction of capacity building and to enable trustees to develop necessary skills and expertise that align with their expanded role and responsibilities, it is proposed that the trustees shall be allowed to engage external consultants for meeting the expanded roles and responsibilities under the REIT / InvIT regulations during the period of eighteen months from the date of official notification.
18. Proposal to the Board:
18.1. The Board is requested to;
18.1.1. consider and approve the proposals as detailed under para no’s 5 to 17 above and the consequent draft amendment notifications placed at Annexure B and Annexure C;
18.1.2. authorize the Chairperson to make consequential and incidental changes and take necessary steps to give effect to the decisions of the Board.
Source: SEBI Board Meeting Dated: Wednesday 18th December 2024
