Integrated FilingIt has been decided to introduce Integrated Filing, in terms of regulation 10(1A) of the LODR Regulations, for the following Governance and Financial related periodic filings required under the LODR, which shall be applicable for the filings to be done for the quarter ending 31st December 2024 and thereafter:
Integrated Filing (Governance): within 30 days from the end of the quarter1. Reg 13(3) – Statement on redressal of investor grievances2. 27(2)(a) -Compliance Report on Corporate Governance
Integrated Filing (Financial): within 45 days from the end of the quarter, other than the last quarter, and 60 days from the end of the last quarter and the financial year.1. 23(9) – Disclosure of Related Party Transactions (RPTs) 2 Reg. 30 r/w section V-B of the Master Circular Quarterly disclosure of outstanding default on loans / debt securities3 32(1) – Statement of Deviation and Variation4. 33(3) Financial results
The following material events / information shall be disclosed on a quarterly basis in the format specified as part of the Integrated Filing (Governance): a. Acquisition of shares or voting rights by listed entities in an unlisted company, aggregating to 5% or any subsequent change in holding exceeding 2% in terms of the provisions of Para A(1) of Part A of Schedule III of LODR. b. Imposition of fine or penalty which are lower than the monetary thresholds specified under Para A(20) of Part A of Schedule III of LODR.c. Updates on ongoing tax litigations or disputes in terms of the provisions of Para B(8) of Part A of Schedule III of LODR read with the corresponding provisions of Annexure 18 of the Master Circular
Secretarial AuditorClause (a) of regulation 24A(1A) of the LODR Regulations inter-alia states that a person shall be eligible for appointment as a Secretarial Auditor of the listed entity only if such person is a Peer Reviewed Company Secretary and has not incurred any of the disqualifications as specified by the Board.
Further, as per regulation 24A(1B) of the LODR, a Secretarial Auditor appointed under the regulations shall provide to the listed entity only such other services as are approved by the board of directors but which shall not include any services as specified by SEBI in this behalf.
Guidelines for disclosure of Employee Benefit Scheme related documents
Regulation 46(2)(za) of the LODR requires listed entities to disclose Employee Benefit Scheme Documents, excluding commercial secrets and such other information that would affect competitive position, framed in terms of SEBI (SBEB) Regulations, 2021.
Single Filing System
The facility of single filing by listed entities has already been put in place by BSE and NSE w.e.f. October 1, 2024, beginning with the filing of statement on redressal of investor grievances under regulation 13(3) of the LODR Regulations and subsequently extended to corporate governance report under regulation 27(2), reconciliation of share capital audit report and disclosure of voting results under regulation 44(3). Details of other filings to be brought under the single filing system shall be communicated by Stock Exchanges from time to time.
System driven disclosure of certain filings
Stock Exchanges, in consultation with SEBI, shall specify the process, procedure and timelines for system driven disclosure of the following filing / disclosure requirements applicable to listed entities under the LODR Regulations:
1. Regulation 31(1)(b) of LODR -Shareholding Pattern
2. Regulation 30(6) r/w sub-para 3 of para A of part A of schedule III of LODR- New rating(s) or revision in ratings
About the Author
