System route
stock exchange mechanism; RTA; depositories; escrow bank
Acknowledgement confirms submission or processing; it does not cure wrong applicability, authority, content or timing.
SEBI Hub › Workflows › Buy-backs and Delisting › Promoter dealing, holding freeze and information controls
Finin2min Summary — in 2 Minutes
Decision: Apply promoter dealing, freeze, UPSI and conflict controls from proposal through completion.
Legal owner and source control
Practical workflow
- Identify the exact promoter conduct and transaction date.
- Assign the legal, business and system owner for promoter conduct.
- Reconcile approvals, filing evidence and post-event monitoring for promoter conduct.
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
- promoter holding reconciliation
- freeze and trading records
- UPSI controls
- Applicable legal version, circular and event date.
- Maker-checker, exception, escalation and post-event reconciliation evidence.
Common failure
Avoid: Promoter or connected dealing during a restricted transaction window.
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 — Promoter dealing, holding freeze and information controls, 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.