Takeaways from SEBI LODR (Fourth and Fifth) Amendments - MMJC

Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) (Fourth and Fifth Amendments) Regulations, 2021 dated August 13, 2021 and September 7, 2021

SEBI vide its amendment notifications dt: August 13, 2021 and dt: September 7, 2021 amended mainly Chapter V and various other provisions of Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 (“SEBI LODR Regulations”) [hereinafter referred to as 4^th amendment and 5^th amendment respectively]. Both these amendments are mainly with regard to such entities which have their non-convertible debt securities listed on the stock exchange (“debt listed entities”) and some amendments are with regard to entities that have any of their non-convertible securities (not necessarily debt securities only) listed on a stock exchange. The 5^th Amendment is also in order to align the LODR Regulations in line with the SEBI (Issue and Listing of Non-Convertible Securities) Regulations 2021 (“SEBI ILNCS Regulations, 2021”). Thereafter in the month of October 2021, SEBI has released various circulars for prescribing formats for some of the amended provisions.

Some of these amendments have overlapping implications on other provisions, hence it is important to read both these amendments collectively in the below paras:

1. Regulation 49 – Applicability of Chapter V of SEBI LODR Regulations

Regulation 49 has been amended to align SEBI LODR Regulations with SEBI ILNCS Regulations 2021. Earlier as per Regulation 49(1) and (2), the Chapter V of SEBI LODR Regulations were applicable to the following:-

• listed entity which has listed its ‘Non-convertible Debt Securities’ and/or ‘Non-Convertible Redeemable Preference Shares’ on a recognised stock exchange in accordance with SEBI (Issue and Listing of Debt Securities) Regulations, 2008 or SEBI (Issue and Listing of Non-Convertible Redeemable Preference Shares) Regulations, 2013 respectively
• Perpetual debt instruments and Perpetual non-cumulative preference shares listed by banks.

As per the 5^th Amendment, this chapter shall apply only to a listed entity which has listed its non-convertible securities on a recognised stock exchange in accordance with SEBI ILNCS Regulations, 2021

2. Regulation 52 – Financial Results

A. Frequency of submission:

Earlier Regulation 52(1) prescribed listed entities which have listed any of its non-convertible securities to prepare and submit to stock exchanges, the un-audited or audited financial results on a half yearly basis. As per 5^th Amendment, the frequency to submit , the un-audited or audited financial results has been changed from half-yearly to quarterly basis. This amendment is applicable from the date of its publication in Official Gazette, i.e., from September 7, 2021. Hence, the quarterly results will have to be submitted by such entities with effect from the quarter ending September 30, 2021 within 45 days from end of quarter, other than last quarter which is explained in Para F below. The formats for disclosure of quarterly / year-to date financial statements under Regulation 52(1) are now prescribed by SEBI vide its Circular dated October 5, 2021. Banking Companies and Insurance Companies are required to disclose financial information as per the formats prescribed under the respective Acts/Regulations as specified by their Regulators.

As per this SEBI Circular dated October 5, 2021,

• In case of non-submission/ delayed submission of financial results within the timelines prescribed under Regulation 52 of the Listing Regulations, the listed entity  shall  disclose  detailed  reasons  for  such non-submission/delay  to  the stock exchanges within one working day of the due date of submission of the financial results.
• In case the decision to delay the results was taken by the listed entity prior to the due date, the listed entity shall disclose detailed reasons for such delay to the stock exchanges within one working day of such decision.

B. Line items / Disclosures in notes to financial results:

Regulation 52(4) provides for line items to be provided along with financial results by entities having their non-convertible securities listed, whose equity shares may or may not be listed. Now with the 4^th amendment SEBI has deleted few points from disclosure requirement under line items.

Further as per 5^th amendment, Regulation 52(4) was again amended wherein SEBI has added some more items to be disclosed under line items.

Hence, with effect from the quarter year ending on September 30, 2021 and thereafter for all quarters, the disclosure of line items shall be as follows:  

Line items need not be disclosed [deleted by 4th amendment]	Line items need to be disclosed [inserted by 5th amendment]	Line items need to be disclosed [no change in these amendments]
Credit rating and changes in credit rating.	Current Ratio Long term debt to working capital Bad debts to Account receivable ratio Current Liability ratio Total Debts to Total assets Debtors Turnover Interest Coverage Ratio Inventory turnover	Debt-equity ratio Debt service coverage ratio Interest service coverage ratio Outstanding redeemable preference shares (quantity and value) Capital redemption reserve/ debenture redemption reserve Net worth Net profit after tax Earnings per share
Asset cover available (in case of non-convertible debt securities),	Operating profit margin (%) Net profit margin Sector specific equivalent ratios, as applicable
Previous due date for payment of interest/dividend for non-convertible redeemable preference/repayment of principal of non-convertible preference shares / non-convertible debt securities and
The next due date for the payment of interest/ dividend of non-convertible preference shares /principal along with the amount of interest/ dividend of non-convertible preference shares payable and the redemption amount need not be disclosed.

C.  Other amendments with regard to line items in financial results:

• Earlier there was a relaxation given by way of second proviso to Regulation 52(5) for unsecured debt securities issued by regulated financial sector entities eligible for meeting capital requirements as specified by respective regulators, which were listed on stock exchange and they were exempted from the requirement to disclose any of these line items in their financial results. As per 5^th Amendment, this relaxation has been removed. Hence in respect of such unsecured debt instruments issued by regulated financial sector entities eligible for meeting capital requirements as specified by respective regulators will also now have to present line items as detailed in above table.

• Earlier the requirement to disclose debt service coverage ratio, asset cover and interest service coverage ratio was not applicable for banks and non-banking financial companies registered with RBI as per first proviso to Regulation 52(5). Now, as per 5^th Amendment, the exemption of disclosure of ‘asset cover’ has been removed from this relaxation, whereas the exemption from requirement to disclose debt service coverage ratio and interest service coverage ratio has been extended to housing finance companies also.

• Regulation 52(6) prescribes additional disclosures to be done as notes to financials by entities which have listed their non-convertible redeemable preference shares. One of those requirements was to mention “profit for the half year and cumulative profit for the year”. This requirement is now deleted as per 5^th Amendment.

D.  Statement of Assets/ Liabilities and Cash flow statement:

The 5^th Amendment has inserted a new requirement for entities submitting financial results under Regulation 52 (2)(f) to submit the following on half-yearly basis (similar to the requirement for equity listed entities submitting financial results under Regulation 33):-

• Statement of Assets and Liabilities
• Statement of cash flows

The requirement to submit these statements on the half-yearly basis is prescribed on a standalone basis as well as a consolidated basis. The formats for disclosure of these statements under Regulation 52(2)(f) are now prescribed by SEBI vide its Circular dated October 5, 2021. Banking Companies and Insurance Companies are required to disclose financial information as per the formats prescribed under the respective Acts/Regulations as specified by their Regulators.

E.  Requirement to submit consolidated financial results:

Earlier Regulation 52 did not mention anything about the submission of consolidated financial results. As per the 5^th Amendment, similar to the requirement for equity listed entities submitting financial results under Regulation 33, the following clauses in Regulation 52(2) speak about submission of consolidated financial results:-

• Regulation 52(2)(d) speaks about submission of annual audited standalone and consolidated financial results
• Regulation 52(2)(f) speaks about submission of statements mentioned in point D above as part of standalone or consolidated financial results for the half year

Regulation 33(3)(c) mentions that if the entity which has listed its specified securities (equity shares and convertibles) has subsidiaries, then in addition to submission of standalone financial results, the listed entity shall also submit quarterly/year-to-date consolidated financial results. However, Regulation 52 does not mention anything similar to the above Regulation 33(3)(c).

Hence, there was an ambiguity that in case of entities, which have any of their non-convertible securities listed but equity shares are unlisted, have subsidiaries, whether they are expected to submit quarterly/year-to-date consolidated financial results also OR are expected to submit consolidated financial results on a half-yearly and annual basis only (as envisaged in Regulation 52(2)(f) and 52(2)(d) respectively). However, SEBI Circular dated October 5, 2021 which prescribes the format for disclosure of financial results under Regulation 52(1) indicates that Standalone financial results are to be submitted on a quarterly basis and Standalone and Consolidated financial results are to be submitted on an annual basis.

F.  Option of submitting un-audited results for the last quarter/half year:

Earlier all entities submitting financial results under Regulation 52(2)(d) had the option submit un-audited financial results for the last half year accompanied by limited review report, followed by audited financial results for the entire financial year, as soon as they are approved by the board of directors.

As per 5^th Amendment, this option shall not be available for any such listed entity, and all listed entities shall be mandatorily required to submit audited financial results on standalone and consolidated basis for the financial year within 60 days from the end of financial year along with audit report.

G.  Limited Review Report:

Earlier all entities submitting financial results under Regulation 52 were required to take limited review report on financial statements from statutory auditors except public sector undertakings who could take limited review report from any practising Chartered Accountant.

As per 5^th Amendment, Regulation 52(2)(d) has been modified and now the relaxation to take limited review report from any practising Chartered Accountant (and not necessarily from statutory auditor) is available only in case of such entities whose accounts are audited by the Comptroller and Auditor General of India, and not for any other public sector undertaking.

The revised formats for limited review reports / Audit reports for issuers of non-convertible securities is prescribed by SEBI Circular dated October 14, 2021.

H.  Two-step process for certain listed entities:

For the entities submitting financial results under Regulation 52, which are audited by the Comptroller and Auditor General of India, the following two-step process is prescribed under Regulation 52(2)(d) to be adopted for disclosure of the annual audited financial results as per 5^th Amendment:

(i) The first level audit shall be carried out by the auditor appointed by the Comptroller and Auditor General of India, who shall audit the financials of the listed entity and such financial results shall be submitted to the Stock Exchange(s) within sixty days from the end of the financial year.

(ii) After the completion of audit by the Comptroller and Auditor General of India, the financial results shall be submitted to the Stock exchange(s) within nine months from the end of the financial year.

I.  Publication of results in newspapers:

Earlier as per Regulation 52(8), the requirement to publish financial results in in at least one English national daily newspaper circulating in the whole or substantially the whole of India newspapers was to be done within 2 calendar days of the conclusion of board meeting held to approve the financial results. As per 5^th Amendment, the timeline has been changed from 2 calendar days to 2 working days. The format for publication of financial results in newspapers under Regulation 52(8) is given under SEBI Circular dated October 5, 2021.

J.  Submission of the statement of utilisation of issue proceeds of non-convertible securities:

Earlier as per Regulation 52(7), there was a requirement to submit along with half-yearly financial results, on a half-yearly basis, a statement indicating material deviations, if any, in the use of proceeds of issue of non-convertible debt securities and non-convertible redeemable preference shares from the objects stated in the offer document.

As per 5^th Amendment, the following changes are done in Regulation 52(7):-

Earlier although contents of Annual Report were prescribed, there was no timeline specified for submission of Annual Report to stock exchanges. Now as per 5^th Amendment, it is prescribed that listed entity which has listed its non-convertible security shall submit to the stock exchange and the debenture trustee and publish on its website

(a) a copy of the annual report sent to the shareholders along with the notice of the annual general meeting, not later than the date of commencement of dispatch to its shareholders and

(b) in the event of any changes to the annual report, the revised copy along with the details and explanation for the changes, not later than 48 hours after the annual general meeting.

4. Regulation 54 – Asset Cover

Amendments done in Regulation 54 are applicable to Non-convertible debt securities only.

Earlier the requirement was to maintain 100% asset cover sufficient to discharge the principal amount at all times for the non-convertible debt securities issued. As per an amendment dated October 8, 2020, it was to be read as “100% asset cover or asset cover as per the terms of offer document/Information Memorandum and/or Debenture Trust Deed”. This created an impression that if the asset cover mentioned in offer document/Information Memorandum and/or Debenture Trust Deed was lesser than 100%, then maintaining that lesser asset cover could suffice.

In order to avoid this ambiguity, the word “higher” has been inserted in this phrase, and hence going forward, debt listed entity will have to maintain 100% asset cover or higher asset cover as per the terms of offer document/Information Memorandum and/or Debenture Trust Deed, sufficient to discharge the principal amount at all times for the non-convertible debt securities issued, i.e., lower than 100% asset cover shall not suffice.

Also, disclosure in this regard is also required to be given to Debenture Trustee. Amendment to this effect has been done under Regulation 56(1)(d) of SEBI (LODR) Regulations. 

Till now information regarding the maintenance of asset cover was to be given under Regulation 52(4) inline items. With the 5^th Amendment, it has been deleted from line items and Regulation 54(3) has been inserted which states that that listed entity shall disclose the asset cover available in case of non-convertible debt securities along with its financial results in the format as specified by the Board. Accordingly, the format for disclosure of asset cover is also prescribed under SEBI Circular dated October 5, 2021.

5. Regulation 55 – Credit Rating:

Earlier as per Regulation 55, it was mandatory to review, at least once a year, the credit rating obtained for non-convertible debt securities only. As per 5^th Amendment, it will now be mandatory to review credit rating, at least once a year, for all non-convertible securities, and not only debt securities. 

6. Regulation 56 – Information to Debenture Trustee:

• Asset Cover Certificate: Earlier as per Regulation 56(1)(d), it was to be disclosed to debenture trustee on half-yearly basis with respect to asset cover maintained. As per the 5^th Amendment, if an entity has maintained a higher asset cover as per terms of offer document, debenture trust deed or information memorandum, then a certificate in that regard that such asset cover is also maintained also needs to be given to the debenture trustee.
• Financial results: As per proviso to Regulation 52(1), a copy of financial results submitted to stock exchanges shall also be sent to debenture trustee on the same day the information is submitted to stock exchanges. Earlier this proviso for submission of financial results on same day to debenture trustee gave reference to only such entities which had listed their equity shares and debt securities. For all debt listed entities (including those whose equity was listed), earlier the requirement was to submit a certificate signed by debenture trustee, to stock exchanges, within seven working days of submission of financial results and information to stock exchanges under Regulation 52(4), that debenture trustee has taken note of the contents of submission made under Regulation 52(4). [Post amendment status of this certificate is explained in below para 7(v)]. Hence, for debt listed entities (other than those whose equity was listed), the timeline for submission of financial results to debenture trustee was not specified, although the timeline for submission of certificate from debenture trustee that it had taken note of contents of financial results and other information given as notes was specified. As per 5^th Amendment, this requirement of submission of financial results and other disclosures given in notes to debenture trustee on the same day when it has been submitted to stock exchanges, has been made applicable to all entities which have listed their debt securities, irrespective of whether equity shares are listed or not.

• Information having bearing on performance/operation of listed entity and/or price sensitive information : As per Regulation 56(1A), a new requirement has been inserted as per the 5^th Amendment that listed entity will have to promptly disclose to debenture trustee all information having bearing on performance/operation of listed entity and/or price sensitive information as disclosed under regulation 51 to the stock exchanges, at the same time as it is intimated to the stock exchanges in so far as it relates to the interest, principal, issue and terms of non-convertible debt securities, rating, creation of charge on the assets, notices, resolutions and meetings of holders of non-convertible debt securities.

7. Regulation 50, 51, 57 – Intimations to stock exchanges:

In addition to financial results, there are amendments with regard to below intimations to be made to stock exchanges:

(i) Advance intimations about Board meetings:

A new provision has been inserted as Regulation 50(1) by the 5^th Amendment (in line with Regulation 29 for equity listed entities) prescribing at least 2 working days advance intimation, excluding the date of the intimation and the date of the meeting, about the Board meeting in which any of the following proposals is to be considered:

(a) an alteration in the form or nature of non-convertible securities that are listed on the stock exchange or in the rights or privileges of the holders thereof;
(this was earlier covered in similar manner under Regulation 50(3) which is deleted now)

(b) an alteration in the date of the interest/ dividend/ redemption payment of non-convertible securities;

(this was earlier covered in similar manner under Regulation 50(3) which is deleted now)

(c) financial results viz. quarterly or annual, as the case may be;

 (Earlier there was nothing mentioned about advance intimation of Board meeting date and the requirement was only to submit financial results within 45 days from end of half year)

(d) fund raising by way of issuance of non-convertible securities

(this was earlier covered under Regulation 50(2) but was applicable for only those non-convertible securities which were proposed to be listed. Now it shall be applicable irrespective of whether proposed securities are to be listed or not. Further number of days of advance intimation was not prescribed earlier); or

(e) any matter affecting the rights or interests of holders of non-convertible securities.

(this was earlier covered in similar manner under Regulation 50(3) which is deleted now)

(ii) Advance intimations about General meetings:

A new provision has been inserted as Regulation 50(2) by the 5^th Amendment prescribing intimation to stock exchanges not later than the date of commencement of dispatch of notices, in case of:

(a) any annual general meeting or extraordinary general meeting that is proposed to be held for obtaining shareholder approval for the proposals at clauses (c) and (d) under Regulation 50(1) mentioned above;

(b) any meeting of the holders of non-convertible securities in relation to the proposal at clause (e) of Regulation 50(1) mentioned above.

(iii) Intimation of information having bearing on performance/operation of listed entity and/or price sensitive information:

Regulation 51 provides listed entities to promptly inform the information having bearing on performance/operation of listed entity and/or price sensitive information to stock exchanges and also about the information mentioned in Part B of Schedule III. In this provision, the explanation about the expression “promptly inform” has been changed by the 5^th Amendment.

Earlier as per Explanation to Regulation 51(1) the expression ‘promptly inform’, implied that the stock exchange must be informed as soon as practically possible and without any delay and that the information shall be given first to the stock exchange(s) before providing the same to any third party.

As per the 5^th Amendment, the Explanation to Regulation 51(1) is amended and now “Promptly inform” shall imply that the stock exchange shall be informed as soon as reasonably possible but not later than twenty-four hours from the date of occurrence of the event or receipt of information. In case the disclosure is made after twenty-four hours of the date of occurrence of the event or receipt of information, the listed entity shall, along with such disclosures provide an explanation for the delay.

(iv) Interest / dividend and redemptions:

• Pre-event Intimation – Earlier under Regulation 50(1), prior intimation to the stock exchange(s) had to be given at least 11 working days before the date on and from which the interest on debentures and bonds, and redemption amount of redeemable shares or of debentures and bonds shall be payable. As per 5^th Amendment, this intimation requirement has been deleted. Instead, a new provision has been inserted as Regulation 57(4) that listed entities will now also have to disclose to within five working days prior to the beginning of the quarter details for all the non-convertible securities for which interest/dividend/principal obligations shall be payable during the quarter. There was no such requirement earlier.

• Post-event Intimation – Earlier as per Regulation 57(1),listed entities were required to submit certificate to stock exchange within two days of the interest or principal or both becoming due that it has made timely payment of interests or principal obligations or both in respect of the non-convertible debt securities. Now as per the 5^th Amendment the timeline for submission of this certificate has been reduced to within one working day from interest or dividend or principal becoming due regarding status on payments in case of non-convertible securities. Hence the time limit has been changed now and this certificate will have to be submitted for all non-convertible securities and not only for non-convertible debt securities as was prescribed earlier. Further, a new provision has been inserted as Regulation 57(5) that the listed entity shall within seven working days from the end of the quarter provide:
• a certificate confirming the payment of interest/dividend/principal obligations for non-convertible securities which were due in that quarter; and
• the details of all unpaid interest/dividend/principal obligations in relation to non-convertible securities at the end of the quarter.

There was no such requirement earlier.

(v) Certificate from Debenture Trustee – As mentioned in Para 6(ii) above, earlier as per Regulation 54(5), there was a requirement to submit a certificate signed by debenture trustee, to stock exchanges, within seven working days of submission of financial results and information under Regulation 52(4), that debenture trustee has taken note of the contents of the submission made under Regulation 52(4). As per the 5^th Amendment, Regulation 54(5) is deleted and the submission of this certificate from debenture trustee is not required henceforth.

(vi) Undertaking of submissions to debenture trustee – Earlier under Regulation 57(2), there was a requirement that the listed entity shall provide an undertaking to the stock exchange(s) on annual basis stating that all documents and intimations required to be submitted to Debenture Trustees in terms of Trust Deed and SEBI (Issue and Listing of Debt Securities) Regulations, 2008 have been complied with. As per the 5^th Amendment, Regulation 57(2) is deleted and the submission of this undertaking by listed entity is not required henceforth.

8. Regulation 58- Documents and information to holders of non – convertible securities:

Earlier there was a requirement that listed entities had to send a half-yearly communication to holders of non-convertible debt securities and non-convertible preference shares containing the half-yearly financial results, various line items prescribed in Regulation 52(4) and the certificate from debenture trustee as prescribed in Regulation 52(5) (explained in Para 7(v) above) that it has taken note of the contents of submission made under Regulation 52(4).

As per the 5^th Amendment, Regulation 58(1)(d) is deleted and the half-yearly communication to holders of non-convertible security holders is not required henceforth. Only annual communications will be required to be sent as provided under Regulation 58(1).

9. Regulation 59: Material modification to the structure of securities

Till now for material modification in structure of non-convertible debt securities and non-convertible redeemable preference shares, before applying for approval of stock exchange, in addition to approval of Board of Directors and debenture trustee (in case of non-convertible debentures), the prior approval of majority of the security holder was required to be taken. Also there was no express provision regarding applicability of e-voting for taking this approval.

Now as per 5^th amendment it is necessary to take prior approval of not less than three-fourths, by value of holders of that class of securities. Further it is mandatory on the part of listed entity to provide facility of e-voting [Regulation 59(2)(b) and proviso therein]

10. Regulation 61- Terms of non-convertible debt securities and non-convertible redeemable preference shares.

(i) Removal of relaxation:

As per­ proviso to Regulation 61(1), there is a restriction on listed entities that they cannot declare or distribute any dividend wherein it has defaulted in payment of interest on debt securities or redemption thereof or in creation of security as per the terms of the issue of debt securities. However, this restriction was not applicable for unsecured debt securities eligible issued by regulated financial sector entities for meeting capital requirementsas specified by respective regulators.

Now as per 5^th Amendment, this relaxation has been removed. So with effect from  September 7, 2021, regulated financial sector entities issuing unsecured debt securities for meeting capital requirements as specified by respective regulators and who defaulted in payment of interest on debt securities or redemption thereof or in creation of security as per the terms of the issue of debt securities cannot declare or distribute any dividend. It appears that ‘dividend’ here includes equity dividend and dividend on compulsorily or optionally convertible preference shares also and not only dividend on non-convertible redeemable preference shares dividend.

(ii) Unclaimed interest / dividend:

Earlier there was a provision in Regulation 61(2) that the listed entity shall not forfeit unclaimed interest/dividend and such unclaimed interest/dividend shall be transferred to the ‘Investor Education and Protection Fund’ (IEPF) set up as per Section 125 of the Companies Act, 2013. It created an ambiguity that for how many years the listed entity needs to wait before transfer the unclaimed amounts to IEPF and till that time how should the unclaimed amounts be dealt with?

As per 5^th Amendment, this provision is deleted. Instead, Regulation 61(1A) has been inserted which provides that

• Where the interest/dividend/redemption amount has not been claimed within thirty days from the due date of interest/ dividend / redemption payment, a listed entity shall within seven days from the date of expiry of the said period of thirty days, transfer the amount to an escrow account to be opened by the listed entity in any scheduled bank
• The interest/ dividend/ redemption amount that is unclaimed and outstanding for a period of less than seven years as on the date of notification of this sub-regulation shall be transferred to the escrow account within thirty days, where it shall remain for the intervening period up to seven years.
• Any amount transferred to the escrow account that remains unclaimed for seven years shall be transferred to the ‘Investor Education and Protection Fund’ constituted in terms of section 125 of the Companies Act, 2013.

11. Website Disclosures:

Regulation 62 provides for disclosures to be made by a listed entity that has listed its non-convertible securities. As per the 5th Amendment, the following additional disclosures need to be hosted on the website of such entities:

• Composition of the Board of Directors
• Notice of meeting of the Board of Directors where financial results shall be discussed
• Financial results, on the conclusion of the meeting of the Board of Directors where the financial reports were approved
• all credit ratings obtained by the entity for all its listed non-convertible securities, updated immediately upon any revision in the ratings;
• statements of deviation(s) or variation(s) as specified in sub-regulation (7) and sub-regulation (7A) of regulation 52 of these regulations;
• annual return as provided under section 92 of the Companies Act, 2013 and the rules made thereunder
• all such events or information which have been disclosed to the stock exchange(s) under Regulation 51, i.e., information having bearing on performance/operation of listed entity and/or price sensitive information and such disclosures shall be hosted on the website of the listed entity for a minimum period of five years and thereafter as per the archival policy of the listed entity, as disclosed on its website. This point is inserted by way of Regulation 51(3) by the 5^th Amendment.

Certain additional information is also to be hosted on the website of high-value debt-listed entities as per newly inserted Regulation 62(1A). However, all amendments relating to high-value debt-listed entities are covered by way of a separate newsletter. Hence, this item shall also be covered there.

As per the 5^th Amendment, the timeline within which any change in the content of the website of listed entity has also been prescribed by inserting Regulation 62(4), which lays the timeline of updation to be within two working days from the date of such change in content. This is in line with Regulation 46(3)(b) prescribed for equity listed entities

Reference to Amendment:

https://www.sebi.gov.in/legal/regulations/aug-2021/securities-and-exchange-board-of-india-listing-obligations-and-disclosure-requirements-fourth-amendment-regulations-2021_51885.html

https://www.sebi.gov.in/legal/regulations/sep-2021/securities-and-exchange-board-of-india-listing-obligations-and-disclosure-requirements-fifth-amendment-regulations-2021_52488.html

https://www.sebi.gov.in/legal/regulations/sep-2021/securities-and-exchange-board-of-india-listing-obligations-and-disclosure-requirements-fifth-amendment-regulations-2021_52488.html