NSE’s Surveillance and Investigation Department has issued a consolidated master circular (NSE/SURV/74008, Circular Ref. No. 313/2026, dated April 30, 2026) combining all previously issued circulars into a single reference document. This supersedes and consolidates over 26 subject areas across surveillance policy and operational matters applicable to all NSE members.

Key Points

• All prior circulars from the Surveillance and Investigation Department are consolidated into this single document
• Covers both equity and derivatives segments including equity, commodity derivatives, and currency derivatives
• Applicable to all NSE trading members
• Contact for Surveillance queries: surveillance@nse.co.in
• Contact for Investigation queries: dl-invsg-all@nse.co.in
• Signed by Amit Shinde, Chief Manager, NSE

Regulatory Changes

This is a consolidation circular and does not introduce new regulations. It brings together the following key regulatory frameworks under one document:

• Periodic Call Auction Session for illiquid securities (NSE/CMTR/23063, March 26, 2013)
• Graded Surveillance Measure (GSM) with updates through September 2024 and July 2025 (NSE/SURV/38389 and subsequent)
• Enhanced Surveillance Measure (ESM) with multiple updates through September 2024 (NSE/SURV/42790 and subsequent)
• Long Term Additional Surveillance Measure (NSE/SURV/59425 and subsequent)
• Short Term Additional Surveillance Measure (NSE/SURV/64066 and subsequent)
• Trade for Trade periodic review framework (NSE/SURV/56948 and subsequent)
• Insolvency and Bankruptcy Code applicability (NSE/SURV/63361)
• High Promoter Encumbrance measures per SEBI SAST Regulation 2011 Reg. 28(3) (NSE/SURV/39265 and subsequent)
• High Promoter Pledge surveillance measures (NSE/SURV/46557 and subsequent)
• Low Non-Promoter Holding surveillance (NSE/SURV/33844 and subsequent)
• Inter Creditor Agreement framework (NSE/SURV/51189)
• Surveillance Indicator updates (NSE/SURV/52368, 54513, 55831, 57110)
• Deep Out-of-The-Money (OTM) Contracts surveillance (NSE/SURV/42382)
• Member Surveillance Dashboard (NSE/SURV/44477)
• Surveillance Obligation – Quarterly Reporting by trading members (NSE/SURV/48818, 49765)
• High Order to Trade Ratio (OTR) measures (NSE/SURV/45016 and subsequent, updated February 2026 and April 2026)
• Order Based Surveillance Measure – Persistent Noise Creators (NSE/SURV/52992)
• Monitoring of Foreign Investment Limits in listed Indian companies (NSE/SURV/37906 and subsequent)
• Unique Identifier for Algorithms (NSE/SURV/39958 and subsequent)
• Position Limits in Equity Index Derivatives (NSE/SURV/43915 and subsequent)
• Placing Orders at Fair Prices (NSE/SURV/55281)
• Additional Surveillance Margin for Order Spoofing (NSE/SURV/41107)
• Consolidated Penalty Structure for Surveillance (NSE/SURV/57315)

Compliance Requirements

• All NSE trading members must treat this consolidated circular as the definitive reference for Surveillance and Investigation department policy
• Members are required to comply with all embedded frameworks including quarterly surveillance obligation reporting, OTR thresholds, algorithm identifier registration, and position limit adherence
• Members must adhere to the updated High OTR framework including circulars as recently updated in February 2026 (NSE/SURV/72668) and April 2026 (NSE/SURV/73597)
• Members must observe fair price order placement requirements and avoid order spoofing practices
• Promoter pledge and encumbrance monitoring obligations remain in force per SEBI SAST Regulation 2011

Important Dates

• April 30, 2026: Date of this consolidated circular
• Most recent embedded update: April 2, 2026 (NSE/SURV/73597 – High OTR update)
• Second most recent embedded update: February 6, 2026 (NSE/SURV/72668 – High OTR update)
• September 5, 2025: GSM update (NSE/SURV/70074)
• All prior circulars referenced within remain effective as consolidated herein

Impact Assessment

This master circular has broad and significant impact on all NSE trading members. By consolidating 26+ subject areas into one authoritative document, NSE simplifies compliance reference while affirming that all prior surveillance obligations remain active. The inclusion of two 2026 updates (February and April) to the High OTR framework signals continued regulatory focus on algorithmic and high-frequency trading practices. Members involved in proprietary trading, algorithmic strategies, or holding securities under GSM/ESM should review the consolidated document thoroughly. No new obligations are introduced, but members should ensure their compliance programs reflect all embedded measures, particularly the most recently updated OTR and surveillance indicator frameworks.

BSE has issued Notice No. 20260429-17 introducing a standardised penalty structure for Registered Investment Advisers (IAs). The structure is designed to address non-compliances under the SEBI (Investment Advisers) Regulations, 2013, and related Exchange Notices. Detailed penalty schedules are provided in Annexure A attached to the notice.

Key Points

• BSE is standardising how non-compliances by Investment Advisers are handled through a defined penalty framework.
• Penalty details for identified non-compliances are outlined in Annexure A (Annexure_A-Penalty_Structure_for_IA).
• The structure applies to all non-compliances observed on or after May 1, 2026.
• Investment Advisers are urged to ensure compliance proactively to avoid penalties.
• The notice is issued by BSE’s Enforcement Department (DOSS).

Regulatory Changes

A formalised and standardised penalty structure has been introduced for Investment Advisers, replacing or supplementing any prior ad-hoc enforcement approach. The framework is aligned with SEBI (Investment Advisers) Regulations, 2013, and Exchange Notices governing IA conduct.

Compliance Requirements

• All Registered Investment Advisers must review the penalty schedule in Annexure A.
• IAs must ensure full compliance with SEBI (Investment Advisers) Regulations, 2013, and all applicable Exchange Notices to avoid penalties.
• For clarifications, IAs may contact BSE Enforcement at 022-22728466, 022-22725854, 022-69158540, 022-45720640, 022-45720440 or via email at membership.ops@bseindia.com / enforcement@bseindia.com.

Important Dates

• Notice Date: April 29, 2026
• Effective Date: May 1, 2026 — penalty structure applies to all non-compliances observed on or after this date.

Impact Assessment

This circular has high operational impact for all BSE-registered Investment Advisers. The introduction of a standardised penalty framework increases regulatory certainty but also heightens enforcement risk for non-compliant IAs. Firms and individuals operating as Investment Advisers on BSE must audit their compliance practices against the Annexure A schedule before May 1, 2026, to avoid financial penalties. The move signals increased scrutiny of the IA segment by BSE’s Enforcement Department.