Description
RTI appeal regarding SME IPO eligibility criteria dismissed as information is available in public domain under SEBI ICDR Regulations 2018.
Summary
The Appellate Authority dismissed RTI Appeal No. 6661 of 2026 filed by Krati Gupta regarding SME IPO eligibility criteria. The appellant sought clarification on the requirement for companies to have three full financial years of track record for listing on BSE SME or NSE Emerge. The CPIO had informed that eligibility norms are governed by Regulation 229 of Chapter IX of SEBI (ICDR) Regulations, 2018. The appeal was rejected as the requested information is already available in the public domain.
Key Points
- Appellant’s company incorporated on September 13, 2022, filed DRHP with BSE SME but was kept on hold due to incomplete three financial years
- RTI application filed on November 26, 2025, seeking official notification specifying three full financial years track record requirement
- CPIO responded on December 11, 2025, citing Regulation 229 of SEBI (ICDR) Regulations, 2018
- Appeal filed on December 17, 2025 (Reg. No. SEBIH/A/E/25/00332) claiming incomplete or misleading information
- Appellate Authority upheld CPIO’s response, noting information is publicly available
- Cited precedents: Registrar of Companies vs. Dharmendra Kumar Garg (Delhi High Court) and Shri K Lall vs. Shri M K Bagri (CIC order dated April 12, 2007)
Regulatory Changes
No regulatory changes introduced. The order reaffirms existing provisions under Regulation 229 of Chapter IX of SEBI (ICDR) Regulations, 2018 governing SME listing eligibility norms.
Compliance Requirements
No new compliance requirements. The order clarifies that:
- SME listing eligibility criteria are governed by Regulation 229 of SEBI (ICDR) Regulations, 2018
- Companies seeking SME listing must comply with publicly available regulatory requirements
- Stock exchanges (BSE SME, NSE Emerge) enforce eligibility criteria as per SEBI regulations
Important Dates
- November 26, 2025: RTI application filed by appellant
- December 11, 2025: CPIO response provided
- December 17, 2025: Appeal filed (Reg. No. SEBIH/A/E/25/00332)
- January 14, 2026: Appellate Authority order issued
Impact Assessment
Minimal market impact. This is an administrative order disposing of an RTI appeal with no changes to existing regulations. The order provides clarity that SME listing eligibility requirements under Regulation 229 of SEBI (ICDR) Regulations, 2018 are publicly accessible and transparent. Companies planning SME IPOs should refer to the published SEBI regulations for eligibility criteria rather than seeking information through RTI applications.
Impact Justification
Administrative RTI appeal order with no regulatory changes or market impact. Confirms existing eligibility norms under Regulation 229 of SEBI ICDR Regulations 2018 for SME listing are publicly available.