06 December 2025
Dear Sirs/ Madams Company A ceased to be a small company during FY 2023–24 and, accordingly, applied for and obtained an ISIN. It has not yet completed the dematerialisation of its shares. However, due to the amended definition of a small company, Company A now falls under the revised criteria and again qualifies as a small company.
In this situation, is Company A still required to proceed with the dematerialisation of its shares, or can it discontinue the process since the revised definition no longer makes dematerialisation applicable to it?
06 December 2025
No, the company cannot stop or reverse the dematerialisation process. Since Company A ceased to be a small company in FY 2023–24 and obtained an ISIN, Rule 9B compliance has already been triggered. Therefore, it must complete dematerialisation, even if it now again qualifies as a small company due to the amended definition.