System route
stock exchange mechanism; RTA; depositories; escrow bank
Acknowledgement confirms submission or processing; it does not cure wrong applicability, authority, content or timing.
Finin2min Summary — in 2 Minutes
Decision: Test issuer, promoter, default, capital, leverage, minimum public shareholding and cooling-period conditions.
Legal owner and source control
Practical workflow
- Identify the exact eligibility and limits and transaction date.
- Assign the legal, business and system owner for eligibility and limits.
- Reconcile approvals, filing evidence and post-event monitoring for eligibility and limits.
Who should sign off
board; promoters; merchant banker; compliance officer; exchange; escrow bank; RTA; shareholders
The responsible-person map must match the actual transaction, delegation, committee and system access—not only job titles.
Evidence checklist
- eligibility certificate
- capital/leverage model
- MPS and promoter analysis
- Applicable legal version, circular and event date.
- Maker-checker, exception, escalation and post-event reconciliation evidence.
Common failure
Avoid: Using pre-transaction numbers that omit contingent or connected holdings.
Portal and cross-law boundary
Other legal owners
Companies Act; LODR; SAST; PIT; tax; Depositories Act
Complete each approval and filing under its own legal regime.
Finin2min Q&A
What is the first document to prepare?
For Buy-backs and Delisting — Eligibility, limits and post-transaction capital, prepare a dated decision memorandum identifying the entity, transaction or service, legal owner, applicable provision, current circulars, responsible persons and unresolved conditions.
Can the official portal decide legal eligibility?
No. The portal applies configured validations. Legal eligibility, facts, approvals, exceptions and evidence remain the responsibility of the regulated persons.
What changes after a later SEBI instrument?
For Buy-backs and Delisting, recheck the effective date, saved actions, open transactions, policies, agreements, forms, system rules, disclosures and client or investor communications affected by this control.