BSE
issued relaxations granted in relation to compliance with various provisions on
account of COVID-19 pandemic
Considering
the hardships faced by the listed entities due to the lockdown pursuant to the
COVID-19 Pandemic, SEBI has issued various circulars notifying relaxations in
the timelines by which the compliance filing required under certain provisions
of the aforementioned regulations, is to be reported.
In
view of the developments arising due to the spread of the COVID-19 pandemic, a
need for temporary relaxations in compliance with certain deadlines in various
SEBI Regulation is warranted by the Board, due to the prevailing travel
restrictions and various other logistical challenges.
The details of the reliefs provided by BSE
to listed entities in reference to compliance requirements are explained here
under. Also, SEBI feels to amend various regulations as per the need
of the time.
Thus, BSE vide Circular No. LIST/COMP/9/2020-21
dated 27.04.2020 after considering the current situation due
to COVID 19 states relaxations
granted in relation to compliance with various provisions on account of
COVID-19 pandemic
Thus, BSE vide Circular No. LIST/COMP/9/2020-21
dated 27.04.2020 states:
SEBI (LODR)
Regulations, 2015, SEBI (SAST) Regulations, 2011 and SEBI (D&P)
Regulations, 2018 require listed entities to submit various disclosures to the
Exchange on various due dates.
Considering the
hardships faced by the listed entities due to the lockdown pursuant to the
COVID-19 Pandemic, SEBI has issued various circulars notifying relaxations in
the timelines by which the compliance filing required under certain provisions
of the aforementioned regulations, is to be reported.
A comprehensive
list of the revised timelines based on the compilation of various circulars is
enclosed as Annexure I for
your ease of reference. We hope that this ready reckoner would assist your
company to comply in a timely manner.
Annexure
1- Calendar for revised timelines for submission of compliance filings under
various Regulations due to COVID-19 pandemic
|
S. No
|
Regulation
|
Due Date
|
Revised Due Date
|
|
1
|
LODR Regulation 7 (3) - Share Transfer Agent
|
April 30,2020
|
May 31,2020
|
|
2
|
LODR Regulation 13 (3) - Statement of Grievance Redressal
Mechanism
|
April 21,2020
|
May 15,2020
|
|
3
|
LODR Regulation 24A - relating to filing of Secretarial
Compliance Report
|
May 30,2020
|
June 30, 2020
|
|
4
|
LODR Regulation 27(2) – filing of Corporate Governance
Report
|
April 15, 2020
|
May 15, 2020
|
|
5
|
LODR Regulation 29 (2) - Prior intimation to stock
exchanges about meetings of the board
|
• at least 5 days before the meeting if financial results
are to be considered • 2 working days in other cases.
|
Board meetings in all cases – 2 working days in respect of
Board Meetings held till July 31, 2020.
|
|
6
|
LODR Regulation 31 relating to Shareholding Pattern
|
April 21, 2020
|
May 15, 2020
|
|
7
|
LODR Regulation 33 relating to Financial Results
(Quarterly)
|
May 15, 2020
|
June 30, 2020
|
|
8
|
LODR Regulation 33 relating to Financial Results
(Annually)
|
May 30, 2020
|
June 30, 2020
|
|
9
|
LODR Regulation 39 (3) relating to Intimation to Stock
Exchanges regarding loss of share certificates and issue of the duplicate
certificates
|
2 days from getting information
|
No penalty for delay in intimation made between March 1 to
May 31, 2020
|
|
10
|
LODR Regulation 52 relating to Financial Results (half
yearly) for Debt Listed Companies
|
May 15, 2020
|
June 30, 2020
|
|
11
|
LODR Regulation 40(9) - Certificate from Practicing
Company Secretary on timely issue of share certificates
|
May 30, 2020
|
June 30, 2020
|
|
12
|
LODR Regulation 44(5) relating to holding of AGM by top
100 listed entities by market capitalization for FY 19-20
|
April 30, 2020
|
May 31, 2020
|
|
13
|
having financial year end as March 31, 2020
|
August 31, 2020
|
September 30, 2020
|
|
14
|
having financial year end as December 31, 2019
|
May 31, 2020
|
September 30, 2020
|
|
15
|
SAST Disclosure filings for the financial year ending
March 31, 2020 under Regulations 30(1), 30(2) and 31(4) of the SEBI (SAST
Regulations).
|
Extended to June 01, 2020.
|
|
|
16
|
SEBI (D & P) Regulations, 2018 - Regulation 74(5)
|
Equivalent period of lock down declared by Government of
India i.e. 21 days, over and above the prescribed time limits
|
|
|
17
|
SEBI (D & P) Regulations, 2018 - Regulation 76
regarding Reconciliation of share capital audit report
|
Equivalent period of lock down declared by Government of
India i.e. 21 days, over and above the prescribed time limits
|
|
|
18
|
SEBI (Buy-back of Securities) Regulations, 2018 -
Regulation 24(i)(f) relating to minimum time between buy back and raising of
funds
|
Temporary relaxation in the period of restriction provided
in Regulation 24(i)(f) from “one year” to “six months” Applicable up to
December 31, 2020 only
|
|
DISCLAIMER: THE ARTICLE IS BASED ON THE
RELEVANT PROVISIONS AND AS PER THE INFORMATION EXISTING AT THE TIME OF THE
PREPARATION. IN NO EVENT I SHALL BE LIABLE FOR ANY DIRECT AND INDIRECT RESULT
FROM THIS ARTICLE. THIS IS ONLY A KNOWLEDGE SHARING INITIATIVE.
THE
AUTHOR – CS DEEPAK SETH (ASSOCIATE PARTNER HELPINGHANDS PROFESSIONALS
LLP) AND CAN BE REACHED AT CONTACTHHPRO@GMAIL.COM OR 9910248911.
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