NSE has granted a one-time relaxation extending the validity of Exchange In-Principle Approvals for listing on NSE Emerge. Approvals expiring between April 1, 2026 and September 30, 2026 are now extended to September 30, 2026. This follows SEBI Circular No. HO/49/11/11(123)2026-CFD-RAC-DIL2/I/8760/2026 dated April 07, 2026, which extended SEBI Observation letter validity under the same window.

Key Points

• NSE extends all Exchange In-Principle Approvals for NSE Emerge listings expiring between April 1, 2026 and September 30, 2026 to a uniform deadline of September 30, 2026.
• The extension is granted as a one-time relaxation; it is not a recurring policy change.
• The underlying SEBI circular cites ongoing geopolitical tensions in the Middle East as causing issuers difficulty in mobilizing resources and accessing capital markets.
• SEBI received representations from industry bodies about potential lapses in observation letter validity and duplication of regulatory processes.
• The NSE extension mirrors SEBI’s own relaxation of Observation letter validity under ICDR Regulations 44(1) and 59C.

Regulatory Changes

• Under normal ICDR Regulations, a public issue must open within 12 months (Regulation 44(1)) or 18 months (Regulation 59C) of SEBI issuing observations.
• SEBI’s circular provides a one-time extension of SEBI Observation letters expiring between April 1–September 30, 2026 to September 30, 2026.
• NSE correspondingly extends Exchange In-Principle Approvals for NSE Emerge listings under the same window and to the same end date.
• This circular is issued under Sections 11 and 11A of the SEBI Act, 1992.

Compliance Requirements

• Lead Managers (Merchant Bankers) must provide an undertaking confirming compliance with ICDR Regulations (and Schedule XVI thereof per the SEBI circular) when submitting the offer document to the Exchange.
• Issuers benefiting from the extension must ensure updated offer documents are submitted with the required undertaking from their Lead Manager.
• No additional filings or fees are mentioned; the extension is automatic for eligible approvals subject to the undertaking condition.

Important Dates

• Effective Date: Immediate (circular in force from April 08, 2026)
• Eligibility Window: Exchange In-Principle Approvals expiring between April 1, 2026 and September 30, 2026
• Extended Validity Deadline: September 30, 2026
• SEBI Circular Date: April 07, 2026 (HO/49/11/11(123)2026-CFD-RAC-DIL2/I/8760/2026)

Impact Assessment

This relaxation provides meaningful relief to SME issuers planning to list on NSE Emerge who were at risk of their Exchange In-Principle Approvals lapsing due to adverse market conditions driven by geopolitical tensions. By harmonizing the NSE extension with SEBI’s own observation letter extension, issuers avoid a scenario where SEBI’s timeline is extended but the Exchange’s approval has expired, which would have created regulatory gaps and necessitated fresh applications. Merchant bankers managing NSE Emerge mandates should review their pipeline and identify issuers who fall within the April 1–September 30, 2026 expiry window to take advantage of this relief. The market impact is confined to the SME/emerging company segment and does not affect mainboard listings.

BSE Limited has granted a one-time relaxation extending the validity of its Exchange In-Principle Approvals for listing on the BSE SME platform. Approvals that were set to expire between April 1, 2026 and September 30, 2026 are now extended uniformly to September 30, 2026. This move is in response to SEBI Circular No. HO/49/11/11(123)2026-CFD-RAC-DIL2/I/8760/2026 dated April 07, 2026, which granted a one-time relaxation on the validity of SEBI Observations.

Key Points

• BSE SME Exchange In-Principle Approvals expiring between April 1, 2026 and September 30, 2026 are extended to September 30, 2026.
• The relaxation is a one-time measure, mirroring SEBI’s corresponding relaxation on SEBI Observation validity.
• The Lead Manager to the issue must provide an undertaking confirming compliance with ICDR Regulations when submitting the offer document to the Exchange.
• The circular is effective immediately from April 08, 2026.
• Addressed to all Merchant Bankers and entities proposing to list specified securities on BSE SME.

Regulatory Changes

• BSE extends the validity of its In-Principle Approvals for BSE SME listings as a one-time relaxation, aligned with SEBI Circular No. HO/49/11/11(123)2026-CFD-RAC-DIL2/I/8760/2026 dated April 07, 2026.
• Normally, In-Principle Approvals have a fixed validity period; this circular overrides that for approvals expiring in the April–September 2026 window.

Compliance Requirements

• Lead Managers must submit an undertaking to BSE confirming compliance with ICDR (Issue of Capital and Disclosure Requirements) Regulations at the time of submitting the offer document.
• Entities with approvals expiring in the specified window must ensure their offer documents are filed within the extended deadline of September 30, 2026.

Important Dates

• Effective Date: April 08, 2026 (immediate effect)
• Relaxation Window: In-Principle Approvals expiring between April 1, 2026 and September 30, 2026
• Extended Validity Deadline: September 30, 2026
• SEBI Reference Circular Date: April 07, 2026

Impact Assessment

This circular provides meaningful relief to companies and merchant bankers who were planning SME IPOs or listings on BSE SME but faced the risk of their Exchange In-Principle Approvals lapsing. By extending the deadline to September 30, 2026, BSE ensures that eligible issuers have adequate time to complete regulatory and documentation requirements without needing fresh approvals. The impact is moderate and targeted — it benefits a specific set of SME listing aspirants rather than the broader market. The mandatory ICDR compliance undertaking from the Lead Manager ensures investor protection standards are maintained during the relaxation period.

SEBI has granted a one-time relaxation to extend the validity of its observation letters issued under the SEBI (Issue of Capital and Disclosure Requirements) Regulations, 2018 (ICDR Regulations). Observation letters expiring between April 1, 2026 and September 30, 2026 will now remain valid until September 30, 2026. This relief is in response to ongoing geopolitical tensions in the Middle East that have disrupted issuers’ ability to access capital markets.

Key Points

• Under Regulations 44(1) and 59C of ICDR Regulations, 2018, a public issue must be opened within 12 months and 18 months respectively from the date of SEBI’s observation letter.
• Industry bodies represented that geopolitical tensions in the Middle East have caused issuers to defer, recalibrate, or withdraw issuance plans.
• SEBI is granting a one-time extension: all observation letters expiring between April 1, 2026 and September 30, 2026 are extended till September 30, 2026.
• The relaxation is conditional on an undertaking from the Lead Manager confirming compliance with Schedule XVI of the ICDR Regulations when submitting the updated offer document.
• The circular comes into force with immediate effect from April 7, 2026.

Regulatory Changes

This circular provides a time-bound, one-time deviation from the standard validity periods prescribed under Regulations 44(1) and 59C of the ICDR Regulations, 2018. It does not permanently amend those regulations but provides administrative relief for a specific window of observation letters.

Compliance Requirements

• Lead Managers must submit an undertaking confirming compliance with Schedule XVI of the ICDR Regulations when filing the updated offer document with SEBI.
• Issuers whose observation letters fall within the April 1 – September 30, 2026 window must ensure the updated offer document is submitted before availing the extended validity.
• Merchant Bankers and Stock Exchanges are notified for awareness and necessary action.

Important Dates

• Effective Date: April 7, 2026 (immediate effect)
• Relaxation Window: Observation letters expiring between April 1, 2026 and September 30, 2026
• Extended Validity Deadline: September 30, 2026

Impact Assessment

This circular provides meaningful short-term relief to issuers who were at risk of losing the validity of their SEBI observation letters due to unfavourable market conditions driven by global geopolitical events. It reduces the risk of duplication of regulatory processes (i.e., re-filing and re-obtaining SEBI observations) and gives issuers additional runway to time their public issues more favourably. The impact is moderate and limited in scope — it applies only to the April–September 2026 expiry cohort and does not alter the underlying ICDR framework. Merchant bankers and lead managers carry the compliance responsibility through the required undertaking.