Description

BSE reminds trading members to submit Action Taken Reports closing non-compliances identified in internal audit reports for H1 FY2025-26 by January 31, 2026, or face monetary penalties and disciplinary actions.

Summary

BSE has issued a reminder to trading members regarding the submission of Action Taken Reports (ATR) for non-compliances identified in their Internal Audit Reports for the half year ended September 30, 2025. Members must close all reported non-compliances and submit their compliance status through BEFS by January 31, 2026. Failure to comply will result in monetary penalties and disciplinary actions as per existing Exchange guidelines.

Key Points

  • Reminder follows earlier Exchange notices dated December 2, 2025 (Notice No. 20251202-5) and December 12, 2025 (Notice No. 20251212-10)
  • Trading members must close non-compliances reported in Internal Audit Report for half year ended September 30, 2025
  • Submission must be made through BSE Electronic Filing System (BEFS)
  • Non-compliance or late submission will trigger monetary penalties and disciplinary actions
  • Penalties will be imposed in accordance with Exchange Notice No. 20251010-20 dated October 10, 2025

Regulatory Changes

No new regulatory changes introduced. This circular serves as a reminder of existing compliance obligations established in previous Exchange notices.

Compliance Requirements

Who Must Comply

  • All BSE trading members who have non-compliances reported in their Internal Audit Reports for H1 FY2025-26

Required Actions

  1. Review non-compliances identified in Internal Audit Report for half year ended September 30, 2025
  2. Close all outstanding non-compliance observations
  3. Prepare and submit Action Taken Report showing compliance status
  4. Submit ATR through BSE Electronic Filing System (BEFS) on or before the deadline

Submission Method

  • Electronic submission through BEFS (BSE Electronic Filing System)

Important Dates

  • Reference Period: Half year ended September 30, 2025
  • First Notice Date: December 2, 2025 (Notice No. 20251202-5)
  • Second Notice Date: December 12, 2025 (Notice No. 20251212-10)
  • Current Reminder Date: January 16, 2026
  • Submission Deadline: January 31, 2026

Impact Assessment

Operational Impact

  • Trading members with outstanding audit non-compliances must prioritize closure and reporting activities
  • Requires coordination between compliance, internal audit, and operational teams to address identified issues
  • Members must allocate resources to complete remediation within the 15-day window from reminder date

Financial Impact

  • Members failing to submit ATR or close observations by deadline will face monetary penalties
  • Penalty structure follows Exchange Notice No. 20251010-20 dated October 10, 2025
  • Potential disciplinary actions may affect member standing and operational permissions

Compliance Risk

  • High risk for members with unresolved audit findings
  • Non-submission triggers automatic penalty process
  • Repeated non-compliance may lead to escalated disciplinary measures
  • Members should prioritize this submission to maintain good standing with the Exchange

Impact Justification

High importance due to mandatory compliance deadline with explicit penalties for non-submission. Directly impacts all trading members with outstanding audit non-compliances.