BSE has issued FAQs to clarify the inclusion of immediate relatives in trading window closures under SEBI’s Insider Trading Regulations, 2015. Immediate relatives include spouses, parents, children, or siblings (of self or spouse) who are financially dependent or consulted before trading.
Listed companies must update PAN details of such individuals, regardless of their shareholding. PAN freezing for immediate relatives will apply from July 1, 2025, for the top 500 companies and from October 1, 2025, for others. Only individuals can be considered immediate relatives, and changes must be updated promptly.
This move strengthens compliance and ensures better oversight of trades linked to Unpublished Price Sensitive Information (UPSI).
FAQs-Immediate Relatives:
- What is the definition of Immediate Relatives?
As per SEBI (Prohibition of Insider Trading) Regulations, 2015 (“PIT Regulations”) “Immediate relative” means a spouse of a person, and includes parent, sibling, and child of such person or of the spouse, any of whom is either dependent financially on such person or consults such person in taking decisions relating to trading in securities. - Is it necessary to provide details of immediate relatives for each Designated Person?
Details of immediate relatives should be provided wherever applicable. - Should immediate relatives be added if they do not hold any shares in the listed entity?
Irrespective of holdings, issuer needs to update PANs of immediate relatives. - Should the details of immediate relatives without a PAN or Demat account be included?
In this regard, kindly note that you must include only the PANs of promoters / promoter groups and Designated persons and their immediate relatives in system. In case an entity is PAN exempted then you need to upload the Demat account number. In case both are not present then details of such entities need to be managed by issuer through offline mode. - How frequently the issuer should update immediate relatives’ details?
The details should be updated promptly whenever there are any changes. - How do we map immediate relatives for non-individuals?
Immediate relatives can be only individual. - Should the PAN of immediate relatives be frozen for the top 500 companies from the quarter ending June 30, 2025, or should their details be added for designated persons starting July 1, 2025?
Pan of immediate relatives needs to be updated promptly whenever there are any changes. However, freezing of pan of immediate relatives are applicable for top 500 companies from July 1, 2025. For rest of the companies freezing will be applicable from October 1, 2025. - If PAN already exists in any other Category, can it be migrated or transferred to Category of immediate relative?
Yes, the PAN can be added by deleting/modifying to the immediate relative category. - Should immediate relatives of personnel from our auditors, RTA, and other related entities be included in the records?
Individuals who possess Unpublished Price Sensitive Information (UPSI) should be included. - What is the difference between exemption and removal?
Exemption can be provided on basis of regulatory reason. Removal is for those PAN for whom UPSI is not applicable.
Disclaimer: This article provides general information existing at the time of preparation and we take no responsibility to update it with the subsequent changes in the law. The article is intended as a news update and Affluence Advisory neither assumes nor accepts any responsibility for any loss arising to any person acting or refraining from acting as a result of any material contained in this article. It is recommended that professional advice be taken based on specific facts and circumstances. This article does not substitute the need to refer to the original pronouncement.
