Securities and Exchange Board of India


September 23, 2020


All Depositories
All Recognized Stock Exchanges
All Registered Registrar & Share Transfer Agents

Dear Sir/Madam,

Sub: System-Driven Disclosures (SDD) under SEBI (SAST) Regulations, 2011

1. Please refer to SEBI circular dated December 01, 2015 and December 21, 2016 pertaining to processes to be followed by Depositories, Exchanges and Registrar & Share Transfer Agents (“RTAs”) for implementation of SDD. Subsequently, SEBI vide circular dated September 09, 2020 under Regulation 7(2) SEBI (PIT) Regulations, 2015 has provided a detailed procedure for SDD implementation. The circular dated September 09, 2020 requires that the capture of the PAN of the entities be done from the listed company itself, rather than through the RTAs as provided in the circular dated December 01, 2015.

2. In order to align the practices, it has been decided to use the procedure of capturing the PAN of the promoters from listed companies as mentioned in para 2,3 & 4 of the Annexure A of the circular dated September 09, 2020 for SAST disclosures too. The referred paras are quoted here for convenience: –

“2. Listed company shall provide the information including PAN number of Promoter(s) including member(s) of the promoter group, designated person(s) and director(s) (hereinafter collectively referred to as entities) as per PIT Regulations to the designated depository (selected in terms of SEBI circular ref. no. SEBI/HO/CFD/DCR1/CIR/P/2018/85 dated May 28, 2018) in the format and manner prescribed by the Depositories. For PAN exempt entities, the Investor’s Demat account number(s) shall be specified by the listed company. The information shall be provided within 10 days from the date of this circular.

3. The designated depository shall share the information received from the listed company with other depository.

4. In case of any subsequent update in the details of the entities, the listed company shall update the information with the designated depository on the same day. The designated depository shall share the incremental changes with the other depository on the day of receipt from the listed company.”

3. The other requirements of SEBI circular dated December 01, 2015 on the subject shall remain in force.

4. This circular is issued in exercise of powers conferred by Section 11(1) of the Securities and Exchange Board of India Act, 1992.

5. A copy of this circular is available on SEBI website at under the categories “Legal Framework/Circulars”.

Yours faithfully,
Rajesh Gujjar
General Manager
Division of Corporate Restructuring-1
Corporation Finance Department
Email id: [email protected]

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