CS Pratima Agarwal
Quick Summary
Due to the CoVID-19 virus pandemic the SEBI provides some relaxation in the compliances of various regulations as SAST Regulations, LODR etc. Here we tried to combine all the relaxation provided by SEBI which affect a Listed Company. The list of relaxation is as follows:
| Sr.No | Regulation No. | Compliance Quarterly/Half Yearly/Annually | Time Period | Due Date | Extended Date on which to be filled |
| 1 | Regulations 30(1), 30(2) and 31(4) | Disclosures | 7 working days from end of financial year | By 15- April-2020 | 1.06.2020 |
| 2 | PIT Regulation | Closure of trading window Disclosure | The trading window will be closed from end of quarter till 48 hours after announcement of financial results | Intimation should be send before closure of trading window | Not extended |
| 3 | Regulation 31 (1) (b)- : | Shareholding Pattern | Within 21 days from the end of the quarter | By 21-April | 15.05.2020 |
| 4 | Regulation 13 (3) | Statement of Grievance Redressal Mechanism | Within 21 days from the end of the quarter. | By 21-April | 15.05.2020 |
| 5 | 27(2)(a) | Corporate Governance Report | Within 15 days from the end of the quarter. | By 15-April | 15.05.2020 |
| 6 | Reconciliation of share capital audit report | Within 30 days from the end of the quarter | By 30-April | Not extended | |
| 7 | Regulation 32 (1) | Statement of deviation(s) or variation(s). | Within 60 days from the end of the financial year | By 30-May | Not extended specifically but will be filed till 30.06.2020 |
| 8 | Regulation 7 (3) | Certificate from RTA and Compliance officer | Within 1 month of end of each half of the financial year | By 30-April | 31.05.2020 |
| 9 | Regulation 40 (10) | Transfer or transmission or transposition of securities | Within 1 month of end of each half of the financial year | By 30-April | 31.05.2020 |
| 10 | Regulation 14 | Fees and other charges to be paid to the recognized stock exchange(s | Within 1 month of end of the financial year | By 30-April | Not extended |
| 11 | Regulation 24A | Secretarial Compliance Report | within 60 days of the end of the financial year | By 30-May | 30.06.2020 |
| 12 | Regulation 33 (3) (d) | Financial Results along with Auditor’s Report | Within 60 days from the end of the financial year | By 30-May | 30.06.2020 |
| 13 | Regulation 34(1) & 36(2) | Annual Report | Not later than the day of commencement of dispatch to its shareholders and not less than 21 days before the annual general meeting | Not extended | |
| 14 | Regulation 47 | publishing newspapers | advertisements in newspapers as required under regulation 47 for all events has been exempted publication of scheduled till 5/15/2020 | ||
| 15 | Conduct of Committee meetings – Nomination and Remuneration Committee, Stakeholders Relationship Committee and Risk Management Committee | ||||
| a | Regulation 19(3A) | The nomination and remuneration committee shall meet at least once in a year | Yearly | By 3/31/2020 | 30.06.2020 |
| b | Regulation 20(3A) | The Stakeholders Relationship committee shall meet at least once in a year. | Yearly | By 3/31/2020 | 30.06.2020 |
| c | Regulation 21(3A) | The Risk Management Committee shall meet at least once in a year. | Yearly | By 3/31/2020 | 30.06.2020 |
FAQ :
SEBI has provided exemptions and relaxations in compliance regulations for listed companies to help them navigate the challenges posed by the COVID-19 pandemic.
Extended deadlines have been provided for regulations concerning disclosures (30(1), 30(2), and 31(4)), shareholding patterns (31(1)(b)), grievance redressal mechanism (13(3)), corporate governance reports (27(2)(a)), statement of deviation(s) or variation(s) (32(1)), certificate from RTA and compliance officer (7(3)), transfer or transmission or transposition of securities (40(10)), secretarial compliance report (24A), financial results (33(3)(d)), and committee meetings (Nomination and Remuneration, Stakeholders Relationship, Risk Management).
Yes, the closure of the trading window (PIT Regulation), reconciliation of share capital audit report, fees and other charges to be paid to stock exchanges, and the annual report (Regulation 34(1) & 36(2)) have not had their deadlines extended.
The deadline for filing financial results along with the Auditor’s Report (Regulation 33(3)(d)) has been extended to 30.06.2020.
The extended due date for filing the shareholding pattern (Regulation 31 (1) (b)) is 15.05.2020.
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