Description
Trading members using SaaS-based solutions must submit half-yearly compliance reports through NSE Member Portal for the period July 01, 2025 to December 31, 2025 by January 31, 2026.
Summary
NSE requires all trading members utilizing Software as a Service (SaaS) based solutions/applications to submit half-yearly compliance reports through the Member Portal. This circular facilitates submission for the period July 01, 2025 to December 31, 2025, with a deadline of January 31, 2026. The requirement is based on SEBI Circular No. SEBI/HO/MIRSD2/DOR/CIR/P/2020/221 dated November 03, 2020. Members not using SaaS services must also submit a declaration selecting ‘NO’ option.
Key Points
- Half-yearly SaaS compliance reporting required for period July 01, 2025 to December 31, 2025
- Submission deadline: January 31, 2026
- Reports must be submitted through NSE Member Portal via path: Log in to Member Portal → Inspection → SaaS → Submit SaaS Report
- Members not utilizing SaaS services must select ‘NO’ option and provide appropriate comment
- User manual provided as Annexure-A with step-by-step submission guidelines
- NSE will share submissions with other exchanges (BSE/MSEI/MCX/NCDEX) where member is also registered
- Reference to SEBI Circular No. SEBI/HO/MIRSD2/DOR/CIR/P/2020/221 dated November 03, 2020
Regulatory Changes
No new regulatory changes introduced. This circular implements existing SEBI advisory on Software as a Service (SaaS) based solutions for financial sector organizations through a dedicated portal submission mechanism.
Compliance Requirements
For Trading Members Using SaaS:
- Submit detailed SaaS compliance report through Member Portal
- Follow submission path: Member Portal → Inspection → SaaS → Submit SaaS Report
- Select reporting period (July 01, 2025 to December 31, 2025)
- Click ‘Yes’ when asked about SaaS usage
- Add rows and fill required details for each SaaS solution/application used
- Submit on or before January 31, 2026
For Trading Members Not Using SaaS:
- Access same submission portal
- Select ‘NO’ option in SaaS report menu
- Provide appropriate comment or remark explaining non-usage
- Submit declaration by deadline
Data Sharing:
- Submissions will be shared with other exchanges (BSE/MSEI/MCX/NCDEX) where member is registered (as per NSE Circular Ref no- NSE/INSP/70505 dated September 29, 2025)
Important Dates
- Reporting Period: July 01, 2025 to December 31, 2025
- Submission Deadline: January 31, 2026
- Circular Issue Date: January 02, 2026
- Reference SEBI Circular Date: November 03, 2020
- Previous NSE Circular Date: September 29, 2025 (NSE/INSP/70505)
Impact Assessment
Operational Impact:
- Trading members using SaaS solutions must allocate resources for compliance reporting
- Members must maintain documentation regarding SaaS vendors and usage details
- Portal-based submission streamlines compliance process compared to manual submissions
Compliance Impact:
- Mandatory submission for all trading members (either affirmative report or negative declaration)
- Non-compliance may result in regulatory action from Inspection Department
- Enhanced visibility for exchanges and SEBI on SaaS usage in financial sector
Market Impact:
- No direct market impact
- Strengthens cybersecurity and operational risk oversight in trading ecosystem
- Aligns with SEBI’s focus on technology risk management in financial services
Contact Information: Members can contact NSE regional offices for clarifications:
- Ahmedabad: inspectionahm@nse.co.in, 079-49008632
- Chennai: inspection_cro@nse.co.in, 044-66309915/17
- Delhi: delhi_inspection@nse.co.in, 011-23459127/38/46
- Kolkata: inspection_kolkata@nse.co.in, 033-40400411/405
- Mumbai: compliance_wro@nse.co.in, 022-26598200/61928200
- Central Help Desk: compliance_assistance@nse.co.in
Impact Justification
Routine half-yearly compliance requirement for trading members using SaaS solutions. Mandatory submission with specific deadline but operational in nature with no market-wide impact.