Description

SEBI's High Level Committee has submitted its report on conflict of interest, disclosures, and related matters for SEBI Members and Officials after comprehensive review.

Summary

SEBI’s High Level Committee (HLC) on “Conflict of Interest, Disclosures and related matters in respect of Members and Officials of SEBI” has submitted its report on November 10, 2025. The committee was constituted following a Board decision on March 24, 2025, to undertake a comprehensive review of provisions relating to conflict of interest, disclosures pertaining to property, investments, liabilities, and related matters for SEBI Members and Officials.

Key Points

  • HLC constituted with 6 members led by Shri Pratyush Sinha (Former Chief Vigilance Commissioner) as Chairman
  • Committee included distinguished members from regulatory, banking, audit and academic backgrounds
  • Report submitted to SEBI Chairman at SEBI Bhavan, Mumbai on November 10, 2025
  • Focus on reviewing and strengthening conflict of interest frameworks and disclosure requirements

Committee Composition

Chairman: Shri Pratyush Sinha, IAS (Retd.), Former Chief Vigilance Commissioner

Vice Chairman: Shri Injeti Srinivas, IAS (Retd.), Former Secretary, Ministry of Corporate Affairs & Former Chairman, IFSCA

Members:

  • Shri Uday Kotak, Founder & Director, Kotak Mahindra Bank
  • Shri G Mahalingam, Former Executive Director, RBI and Former Whole Time Member, SEBI
  • Shri Sarit Jafa, IA&AS (Retd.), Former Deputy Comptroller and Auditor General
  • Prof. R Narayanaswamy, Former Professor, IIM, Bangalore

Terms of Reference

  1. Review existing frameworks: Identify gaps or ambiguities in current policies governing conflict of interest, disclosures and related matters

  2. Recommend robust framework: Develop comprehensive framework for preventing, mitigating and managing conflict of interest including:

    • Recusal policy
    • Disclosure requirements (public disclosures)
    • Restrictions on investments
    • Maintenance of digital records
    • Monitoring framework

  3. Public grievance mechanism: Recommend mechanism for public to raise concerns about conflict of interest and disclosures, including complaint examination process

  4. Other related matters: Address any other matters considered appropriate

Important Dates

  • March 24, 2025: Board decision to constitute HLC
  • November 10, 2025: HLC report submitted to SEBI Chairman

Impact Assessment

This initiative represents a significant governance reform for SEBI aimed at strengthening institutional integrity and transparency. The recommendations are expected to:

  • Enhance conflict of interest management for SEBI Members and Officials
  • Improve disclosure frameworks for property, investments, and liabilities
  • Establish clearer recusal policies and monitoring mechanisms
  • Provide public oversight mechanisms for governance concerns
  • Strengthen regulatory credibility and public trust in SEBI’s operations

The actual implementation timeline and specific recommendations will depend on SEBI Board’s consideration of the HLC report.

Impact Justification

High-level governance reform affecting SEBI's internal policies on conflict of interest and disclosures for Members and Officials, expected to strengthen regulatory integrity and transparency