Description

BSE extends single filing system for Integrated Filing (Financials) under Regulation 33 of SEBI LODR Regulations, effective January 3, 2026, with phased rollout for other disclosure types.

Summary

BSE has extended the single filing system through API-based integration between stock exchanges to include Integrated Filing (Financials) under Regulation 33 of SEBI (LODR) Regulations, 2015, effective January 3, 2026. This system allows listed entities to file disclosures once, which will be automatically shared across exchanges, eliminating the need for duplicate submissions. The rollout includes multiple disclosure types with staggered implementation dates.

Key Points

  • Single filing system extended to Integrated Filing (Financials) under Regulation 33 from January 3, 2026
  • System covers equity and equity+debt listed companies initially; REITs, InvITs, and exclusively debt companies to follow
  • Listed entities must avoid multiple filings of the same disclosure on both exchanges
  • If an exchange seeks clarification post-submission, entities must respond to that specific exchange
  • Builds upon previous notice 20240930-60 dated September 30, 2024

Regulatory Changes

The single filing system now covers the following disclosures with their respective effective dates:

  1. Integrated Filing (Financials) - Regulations 33(3), 23(9), 32(1) & Reg 30 r/w Section V-B of Master Circular - Effective January 3, 2026 (Equity and Equity+Debt)

  2. Annual Secretarial Compliance Report - Regulation 24A(2) - Effective September 15, 2025 (Equity and Equity+Debt)

  3. Integrated Filing (Governance) - Regulations 13(3), 27(2) & 30 - Effective March 1, 2025 (Equity and Equity+Debt)

  4. Meetings of Shareholders and Voting Results - Regulation 44(3) - Effective December 28, 2024 (Equity and Equity+Debt)

  5. Reconciliation of Share Capital Audit Report - Regulation 76 - Effective November 15, 2024 (Equity and Equity+Debt)

  6. Corporate Governance Report - Regulation 27(2) - Effective October 26, 2024 (Merged with Integrated Filing (Governance) pursuant to SEBI Circular dated December 31, 2024)

  7. Investor Grievance Report - Regulation 13(3) - Effective October 1, 2024 (Equity only)

Note: Implementation dates for REITs, InvITs, and exclusively debt companies will be communicated separately.

Compliance Requirements

  • Avoid Duplicate Filings: Listed entities must not file the same disclosure on multiple exchanges
  • Single Submission: File disclosures once through the API-based integration system
  • Respond to Clarifications: If any exchange requests clarification after submission, respond directly to that exchange
  • Applicable Entities: Currently applies to equity and equity+debt listed companies for financial disclosures
  • Process Adjustment: Update internal filing procedures to utilize the single filing system

Important Dates

  • January 3, 2026: Integrated Filing (Financials) under Regulation 33 goes live
  • September 15, 2025: Annual Secretarial Compliance Report integration
  • March 1, 2025: Integrated Filing (Governance) implementation
  • December 28, 2024: Meetings of Shareholders and Voting Results
  • November 15, 2024: Reconciliation of Share Capital Audit Report
  • October 26, 2024: Corporate Governance Report (merged with Integrated Filing (Governance))
  • October 1, 2024: Investor Grievance Report
  • Dates TBA: Implementation for REITs, InvITs, and exclusively debt companies

Impact Assessment

Operational Impact: High - All listed entities must modify their disclosure filing processes to use the single filing system, eliminating duplicate submissions across exchanges. This requires updates to internal workflows and potentially integration with the API-based system.

Efficiency Gains: The system streamlines compliance by reducing redundant work and ensuring consistency across exchanges. Companies filing on multiple exchanges will see significant time and resource savings.

Risk Considerations: Entities must ensure they understand the clarification response protocol - responding to the correct exchange when queries arise. Failure to adapt to the single filing system could result in non-compliance if entities continue duplicate filing practices.

Scope: Currently affects equity and equity+debt companies. REITs, InvITs, and exclusively debt listed entities should prepare for future implementation dates to be announced.

Support: BSE helpdesk available at 022-69158560 / 45720460 / 4570660 or bse.regulation30@bseindia.com for queries.

Impact Justification

Significant operational change affecting all listed entities' disclosure filing process across multiple regulations, requiring process adjustments to avoid duplicate filings.