Circular No.: NSE/CML/2026/19 dated August 7, 2026
Applicable Act/Rule: SEBI (Prohibition of Insider Trading) Regulations, 2015 (PIT Regulations)
The SEBI (Prohibition of Insider Trading) Regulations, 2015 (PIT Regulations), as amended from time to time, and relevant circulars issued by SEBI and the Stock Exchanges, detail the manner in which listed companies are required to deal with Unpublished Price Sensitive Information (UPSI). The provisions of the PIT Regulations are supplemented through Frequently Asked Questions (FAQs) issued by SEBI. NSE has issued this circular in light of observations made in certain cases, to convey suggested best practices for listed companies under the PIT Regulations.
This circular does not amend the PIT Regulations. It sets out suggested best practices for listed entities in relation to the Structural Digital Database (SDD) and handling of UPSI, as follows:
1. Structural Digital Database: Listed companies are to maintain a structured digital database containing the nature of UPSI, the names and PANs (or any other identifier authorized by law) of persons who have shared the information, and the names and PANs of persons with whom such information has been shared. Where UPSI is shared with a listed company, intermediaries, or fiduciaries, the names and identifier of the individuals handling such information are to be recorded.
2. Internal Policies: Listed companies are to diligently implement and periodically review internal policies designed to prevent the leakage of UPSI. Such measures are to be in alignment with the statutory and regulatory provisions prescribed under the PIT Regulations.
3. Training and Awareness: Companies are to conduct periodic training and awareness programs for all employees and fiduciaries regarding the prescribed manner of handling UPSI.
4. Code of Conduct: Listed companies are to ensure compliance with the Code of Conduct formulated by the company with respect to the PIT Regulations, ensuring that the same is effectively operationalized.
5. Other Measures: Listed entities are advised to implement any other measures as may be necessary to ensure that the objectives of the PIT Regulations are achieved.
All listed entities on NSE are impacted by this circular.
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