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NCS · R-03

Intermediary and responsibility matrix

Allocate issuer, lead manager, debenture trustee, registrar, CRA, exchange and depository responsibilities.

Source review: 21 January 2026Debt issuers, merchant bankers, debenture trustees, stock exchanges, rating agencies and investorsProfessional control guide
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Finin2min Summary — in 2 Minutes

Decision: Allocate issuer, lead manager, debenture trustee, registrar, CRA, exchange and depository responsibilities.

Legal owner and source control

RegulationIssue and Listing of Non-Convertible Securities Regulations, 2021
Current source date21 January 2026
Numbered anchorsRegulations 1–4, 50, 50A, 50B, 51, 51A, 52–54 and Schedules I–VI; issue-specific Chapters II–VIB.
Official sourceSEBI Regulation record

How to apply this control

1. Freeze the facts

Record the entity, security or product, transaction, decision-maker, counterparty, amount and event date.

2. Locate the provision

Open the official consolidated Regulation and identify the exact numbered provision, proviso, explanation and Schedule.

3. Add subordinate implementation

Map the current Master Circular, later circular, exchange/depository specification and filing format without treating them as the Regulation itself.

4. Preserve evidence

Engagement letters, responsibility matrix, due diligence and issue chronology.

Evidence checklist

  • Applicable legal version and amendment date.
  • Named business and compliance owner.
  • Approval, filing, acknowledgement and communication trail.
  • Maker-checker, exception and escalation evidence.
  • Post-event reconciliation and breach assessment.

Common failure

Avoid: Treating a credit rating or trustee appointment as a substitute for issuer disclosure and security creation.

Finin2min Q&A

Is this page the legal text?

No. It is an implementation guide. Use the official SEBI consolidated Regulation for the exact wording and numbering.

Does a successful exchange or portal filing prove compliance?

No. Acceptance proves a system transaction; it does not cure wrong applicability, approvals, disclosures, timing or evidence.

What should be checked after an amendment?

Effective date, saved actions, forms, policies, system rules, open transactions, board approvals and investor/client communications.