CIRCULAR
SEBI/HO/DDHS/RACPOD1/CIR/P/2023/003 January 05, 2023
To,
Issuers who have listed and/ or propose to list Non-Convertible Securities, Securitised
Debt Instruments, Security Receipts, Municipal Debt Securities or Commercial Paper;
Recognized Stock Exchanges;
All Debenture Trustees registered with SEBI;
All Credit Rating Agencies registered with SEBI;
All Depositories registered with SEBI
Madam/ Sir,
Sub: Extension of timelines for entering and verification of the details of the existing
outstanding non-convertible securities in the ‘Security and Covenant Monitoring’
system hosted by Depositories
1. SEBI vide Circular SEBI/HO/MIRSD/MIRSD_CRADT/CIR/P/2021/618 dated August 13,
2021 specified the manner of recording of charges by Issuers and manner of monitoring
and other responsibilities of stakeholders for ‘Security and Covenant Monitoring’ using
Distributed Ledger Technology (DLT). Further, vide circular
SEBI/HO/MIRSD/CRADT/CIR/P/2022/38 dated March 29, 2022 the Operating
Guidelines of the said system using DLT, including roles and responsibilities of the
various stakeholders involved, were specified.
2. Pursuant to receipt of representations from depositories for extension in the timeline of
entering the legacy data being requested by the issuers, para 8.d of the SEBI Circular
dated March 29, 2022 was accordingly modified providing that for existing outstanding
non-convertible securities, issuers shall ensure that they enter the details into the system
on or before October 31, 2022 and Debenture Trustees (DTs) shall verify the same by
December 31, 2022.
3. SEBI is in receipt of further representations from DTs citing operational/ technical
difficulties owing to the advanced nature of the technology involved and seeking
extension of timeline for verifying the entries made by issuer. Accordingly, it has been
decided that for existing outstanding non-convertible securities, issuers shall ensure that
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they enter the details into the system on or before January 31, 2023 and DTs shall verify
the same by February 28, 2023. DTs shall submit a fortnightly progress report of status
of compliance regarding the details pertaining to existing outstanding non-convertible
securities being entered in the system by the issuers and verification of the same by DT,
till the extension of the timeline for compliance is in place. The progress report shall be
submitted within five days of the end of the fortnight.
4. This circular is issued in exercise of the powers conferred upon SEBI under Section 11
(1) of the Securities and Exchange Board of India Act, 1992 read with the provisions of
Regulation 2A of the Securities and Exchange Board of India (Debenture Trustees)
Regulations, 1993, Regulation 55 of the Securities and Exchange Board of India (Issue
And Listing Of Non-Convertible Securities) Regulations, 2021, Regulation 29 of the
Securities and Exchange Board of India (Issue and Listing of Municipal Debt Securities)
Regulations, 2015, Regulation 48 of SDI Regulations, 2008 and Regulation 20 of SEBI
(Credit Rating Agencies) Regulations, 1999 to protect the interest of investors in
securities and to promote the development of, and to regulate, the securities market.
5. This circular is available on SEBI website at www.sebi.gov.in under the categories
“Legal Framework” and “Circulars”.
Yours faithfully,
Pradeep Ramakrishnan
General Manager
Department of Debt & Hybrid Securities
Email id: pradeepr@sebi.gov.in
Phone: +91-22-26449246
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