Contents
Applicability………………………………………………………………………………………………1
Thresholds……………………………………………………………………………………………….2
Documentation…………………………………………………………………………………………..3
Rule of survivorship……………………………………………………………………………………..4
Procedural………………………………………………………………………………………………..5
Applicability
1. To which listed entities is the revised SEBI transmission framework applicable?
Answer: The circular dated 23rd July 2026 is addressed to “All Listed Companies”. The revised transmission framework applies to the transmission of all listed securities, and therefore applies to all listed entities, including:
- Entities having listed equity shares;
- Entities having listed non-convertible securities (debt-listed entities);
- Entities having listed non-convertible redeemable preference shares (NCRPS);
- Other listed entities whose securities are covered under the SEBI (LODR) Regulations, 2015.
2. When does the revised transmission framework come into force?
Answer: The revised framework comes into force 30 days from the date of issuance of the circular, i.e., 22nd August 2026. However, processing entities are encouraged to apply the simplified framework even to requests received before its effective date.
3. What are the categories of transmission claims under the revised framework?
Answer: The revised framework classifies transmission claims into three categories:
- Quick Transmission Processing (QTP);
- Simplified Documentation; and
- Above Simplified Documentation Threshold.
4. Does the revised SEBI transmission framework apply where there is a dispute or competing claim?
Answer No. The framework does not apply where there is any dispute or competing/contesting claim. In such cases, the claimants must resolve the matter through appropriate judicial or legal proceedings.
5. How is the value of securities determined for classifying a transmission claim under the revised framework?
Answer: The value of securities is determined by the claimant based on:
- For listed securities: the previous closing price of the security on any one of the recognised stock exchanges; and
- For units issued by Asset Management Companies (AMCs): the last available Net Asset Value (NAV).
The value so determined is used to ascertain whether the claim falls under Quick Transmission Processing (QTP), Simplified Documentation, or Above Simplified Documentation Threshold.
6. Is the value threshold calculated investor-wise or folio-wise?
Answer: The value threshold is calculated differently depending on the mode of holding and it is determined investor wise:
- Physical securities: Per listed entity (or per AMC for mutual fund units held in Statement of Account form).
- Dematerialised securities: Per beneficial owner (demat account).
Thresholds
7. What is the newly introduced “Quick Transmission Processing” (QTP)?
Answer: QTP is a new category designed for very low-value claims to expedite the process for small investors. Unlike other categories, QTP is strictly restricted to immediate relatives of the deceased, defined specifically as parents, spouse, children, and parents-in-law. If a claimant falls outside this specific relationship pool, they cannot use the QTP route regardless of the claim’s value.
8. What are the specific monetary thresholds that determine whether a claim follows QTP, Simplified, or Standard documentation?
Answer: The thresholds are split by the mode of holding:
- QTP: Claims up to ₹10,000 for physical securities (per listed entity/AMC) and up to ₹30,000 for dematerialized securities (per beneficial owner).
- Simplified Documentation: Claims up to ₹10 lakhs for physical securities and ₹30 lakhs for dematerialized securities.
- Above Threshold: Any claim exceeding the ₹10 lakh (physical) or ₹30 lakh (demat) limits.
- Listed Entity Discretion: Listed entities have the power to enhance the value threshold for physical securities beyond ₹10 lakhs at their own discretion.
9. Can a listed company prescribe a higher threshold for physical securities?
Answer: Yes. A listed entity may, at its discretion, enhance the threshold of ₹10 lakh prescribed for physical securities under the simplified documentation category.
Documentation
10. Is submission of a Client Master List (CML) mandatory?
Answer: Yes. The latest Client Master List (CML) of the claimant’s demat account forms part of the common documentation requirements for transmission claims.
11. Can transmission be effected in favour of a claimant who does not have a demat account?
Answer: No. Since securities held in physical form are required to be credited in dematerialised form after transmission, the claimant must have a demat account for receiving the securities.
12. Is a family settlement deed recognised under the revised framework?
Answer: Yes. Under the Simplified Documentation category, a family settlement deed executed by all legal heirs and duly authenticated in the prescribed manner may be submitted instead of an affidavit-cum-NOC.
13. Does a nominee become the absolute owner of the securities after transmission?
Answer: No. The circular clarifies that the nominee receives the securities as trustee on behalf of the legal heirs of the deceased holder.
14. How has SEBI redefined a “Verifiable Death Certificate” to include modern technology and international scenarios?
Answer: A verifiable death certificate now includes three distinct types:
- The original or a copy attested by the nominee/claimant (verified against the original).
- A copy duly attested by a Notary Public, Gazetted Officer, or Judicial Magistrate First Class (JMFC).
- Critically, a death certificate featuring a Quick Response (QR) Code is now accepted for ease of electronic verification.
15. If an investor dies outside of India, what are the five specific modes allowed for certifying the “proof of death”?
Answer: For deaths occurring in foreign jurisdictions, processing entities must accept a certified true copy of the death document through:
- Certification by a Court Magistrate, Judge, or Notary Public in that country.
- Consularisation by the Indian Embassy or Consulate General in that country.
- An Apostille certificate (for Hague Convention member countries).
- Certification by authorized officials of overseas branches of Indian Scheduled Commercial Banks.
- Certification by authorized officials of branches of foreign banks that have a correspondent banking relationship with Indian banks.
16. Whether will is required for transmission of securities?
Answer: Refer below table for understanding. Refer SEBI circular also for detailed documentation.
| Category of Claim | Is Will required? | If deceased died Testate | If deceased died Intestate | Is Probate mandatory? |
| QTP | No | Will is not prescribed as a required document. Claim is processed on the basis of prescribed documents as given in circular. | Will is not prescribed as a required document. Claim is processed on the basis of prescribed documents as given in circular. | No |
| Simplified Documentation | No | Will is not prescribed as a mandatory document. Claim can be processed through indemnity bond + affidavit-cum-NOC, or family settlement deed. | Same simplified documentation route applies. | No. Probate, if available, can be submitted and certain other documents are then dispensed with. |
| Above Simplified Documentation Threshold | Yes, as prescribed under circular | Where the claim is based on the Will, the Circular expressly permits copy of Will + notarised indemnity bond. Alternatively, an appropriate court-issued document such as Probate of Will / Letter of Administration / Court Decree may be relied upon. | Claimant may submit Legal Heirship Certificate + indemnity bond, or Succession Certificate / Letter of Administration / Court Decree. | No. Probate of Will is not made mandatory under the Circular. |
17. Has SEBI dispensed with the requirement of Probate altogether?
Answer: No. SEBI has only removed the mandatory requirement of Probate as a transmission document. This does not override the provisions of the Indian Succession Act, 1925. Therefore, where probate is mandatorily required under the applicable succession law, the claimant will still be required to obtain probate notwithstanding the SEBI circular. SEBI has expressly stated that the revised framework removes the mandatory requirement of Probate of Will for transmission purposes.
Rule of survivorship
18. What is the Rule of Survivorship in the context of transmission of securities?
Answer: The Rule of Survivorship applies where securities are held jointly and one or more joint holders die. In such cases, the securities are transmitted to the surviving joint holder(s) by operation of law, subject to there being no contrary provision in the Articles of Association of the company. SEBI has retained this principle under the revised transmission framework.
The revised SEBI framework provides that RTAs, listed entities, depositories, DPs and AMCs shall continue to comply with Clause 23 of Table F of Schedule I to the Companies Act, 2013, read with Sections 56(2) and 56(4)(c) of the Companies Act, 2013, while effecting transmission in favour of the surviving joint holder(s).
Further, under Paragraph 7 of the Circular, the processing entity cannot insist upon KYC documents, indemnities, undertakings or any other additional documentation from the surviving joint holder. It may seek only the copy of the death certificate of the deceased joint holder for effecting transmission.
19. Is the surviving joint holder required to submit an indemnity bond, affidavit or succession documents?
Answer: No. Where transmission is effected under the Rule of Survivorship, the revised SEBI framework specifically dispenses with the requirement of obtaining KYC documents, indemnities, undertakings or other succession-related documents from the surviving joint holder. Only the death certificate of the deceased joint holder may be required.
20. Does the Rule of Survivorship apply where the Articles of Association provide otherwise?
Answer: No. The Rule of Survivorship applies provided there is nothing contrary in the Articles of Association of the company. Where the Articles contain a contrary provision, the transmission would have to be effected in accordance with such Articles.
Procedural
21. Has SEBI prescribed standard forms for transmission?
Answer: Yes. The circular prescribes standardised formats for:
- Transmission Request Form;
- Transmission Request Form-cum-Undertaking (QTP);
- Indemnity Bond; and
- Affidavit-cum-NOC.
- Processing entities (listed companies, RTA, etc. as defined under circular) are required to make these forms available on their websites.
22. Within what time must a transmission request be processed?
Answer: A processing entity must process the transmission request within 21 calendar days from the date of receipt of all the required documents. If the claim is not settled within this period or is rejected, the reasons for the delay or rejection must be communicated to the claimant in writing.
23. Can a processing entity seek documents in addition to those prescribed by SEBI?
Answer: Generally, the documentation prescribed by SEBI should be followed. However, for claims above the simplified documentation threshold, a processing entity may seek additional documents, provided the reasons are recorded in writing and the approach is applied consistently for similar cases. [Paragraph 4.2.2.3, Note 3 of the SEBI Circular dated 23 July 2026.]
24. How are physical security certificates handled during the transmission process to ensure they never remain in physical form?
Answer: Even if the deceased held physical certificates, the transmission must be effected in dematerialized form. After verifying the claim, the RTA/Listed Entity initiates a demat conversion request for direct credit to the claimant’s demat account. The RTA must then deface the physical certificate with a stamp stating “Securities issued in dematerialised form” and retain it.
25. What happens if securities are subject to a lock-in period?
Answer: Where transmitted securities are under lock-in, the RTA must inform the depository of the lock-in and its period while crediting the securities to the claimant’s demat account.
26. Is a listed company/RTA required to report the death of a shareholder once it becomes aware of it?
Answer: Yes. The death is required to be reported through the centralized KRA mechanism in accordance with SEBI’s Circular dated 03rd October, 2023[i]. For physical securities, the listed company accesses the mechanism through its RTA.
For demat holdings, the relevant “concerned intermediary” would ordinarily be the Depository Participant (DP) with whom the deceased investor’s demat account is maintained, if the DP is the first intermediary to receive or infer information about the death. SEBI expressly includes DPs within the circular and defines the “concerned intermediary” as the intermediary that first receives or infers the information regarding demise.
[i] Centralized mechanism for reporting the demise of an investor through KRAs.