Description

BSE reminds trading members to submit Action Taken Reports for non-compliances identified in internal audit reports for the half year ended September 30, 2025, by January 31, 2026, or face monetary penalties and disciplinary actions.

Summary

BSE has issued a reminder to trading members regarding the mandatory submission of Action Taken Reports (ATR) for non-compliances identified in internal audit reports for the half year ended September 30, 2025. Members must close all outstanding non-compliances and submit their compliance status through the BSE Electronic Filing System (BEFS) by January 31, 2026. Failure to comply will result in prescribed monetary penalties and disciplinary actions as per existing exchange regulations.

Key Points

  • Trading members must submit Action Taken Reports for internal audit non-compliances for H1 FY2025-26 (ending September 30, 2025)
  • Submission must be made through BEFS (BSE Electronic Filing System)
  • This is a reminder following earlier notices dated December 2, 2025 (No. 20251202-5) and December 12, 2025 (No. 20251212-10)
  • Non-compliance will attract monetary penalties and disciplinary actions as per Exchange notice No. 20251010-20 dated October 10, 2025
  • Penalties apply both for failure to close observations and failure to submit ATR within the deadline

Regulatory Changes

No new regulatory changes introduced. This circular reinforces existing compliance requirements for internal audit reporting and remediation.

Compliance Requirements

Applicable To: All BSE trading members

Required Actions:

  1. Review internal audit report for the half year ended September 30, 2025
  2. Close all non-compliances identified in the audit report
  3. Prepare and submit Action Taken Report documenting compliance status
  4. Submit ATR through BEFS portal
  5. Ensure submission before the January 31, 2026 deadline

Submission Method: BSE Electronic Filing System (BEFS)

Consequences of Non-Compliance:

  • Monetary penalties as prescribed in Exchange notice No. 20251010-20 (October 10, 2025)
  • Disciplinary actions
  • Penalties applicable for both incomplete closure of observations and late/non-submission of ATR

Important Dates

  • Audit Period: Half year ended September 30, 2025
  • Previous Notices: December 2, 2025 (Notice No. 20251202-5) and December 12, 2025 (Notice No. 20251212-10)
  • Submission Deadline: January 31, 2026
  • Notice Date: January 16, 2026
  • Notice Number: 20260116-14

Impact Assessment

Trading Members: High impact on members with outstanding internal audit observations. Immediate action required to avoid financial and regulatory consequences. Members need to allocate resources to review audit findings, implement corrective measures, and complete documentation within 15 days of this reminder.

Market Operations: No direct impact on market operations, but ensures continued compliance and governance standards among trading members.

Regulatory Oversight: Demonstrates BSE’s commitment to enforcing compliance standards and maintaining audit discipline. The reminder mechanism shows escalation of enforcement before penalty imposition.

Financial Impact: Trading members failing to comply face monetary penalties as per existing penalty framework, in addition to potential reputational and regulatory risks.

Impact Justification

High severity and impact due to mandatory compliance requirement with strict deadline and threat of monetary penalties and disciplinary actions for non-compliance. Affects all trading members with outstanding internal audit observations.