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The compliance officer's quarterly calendar

Ten filings and three certifications per quarter. This lesson walks the quarter-by-quarter calendar every listed-entity compliance officer runs, with the filing route (BSE Listing Centre or NSE Digital Portal), the deadline and the signatory.

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Legal basis
SEBI LODR + PIT primary-source stack current to 30 August 2026. Core: SEBI (LODR) Regulations 2015 consolidated 22 January 2026 (sebi.gov.in), SEBI (PIT) Regulations 2015 consolidated 12 March 2025 (sebi.gov.in). LODR amendments in the operating window: 2nd Amendment 2023 (14 June 2023 gazette, effective 14 July 2023, Reg 30 recast + Sch III Part A materiality); Amendment 2024 (17 May 2024, MPM-based rumour verification); 2nd Amendment 2024 (10 July 2024); 3rd Amendment 2024 (12 December 2024, Reg 24A + Reg 27 + Integrated Filing, operative 1 April 2025 / 31 December 2024); Amendment 2025 (27 March 2025, Chapter VA HVDLE + SME Reg 23); 2nd Amendment 2025 (29 April 2025, securitised debt); 3rd Amendment 2025 (mid-2025, gazette date to be re-verified); 4th Amendment 2025 (27 October 2025); 5th Amendment 2025 (18-19 November 2025, Reg 23 recast + Sch XII slab materiality, effective 18 December 2025); 6th Amendment 2025 (15-16 December 2025, terminology fix); Amendment 2026 (22 January 2026, HVDLE Rs 5,000 crore + LoC removal). PIT amendments in the operating window: Amendment 2018 (31 December 2018, SDD introduction, effective 1 April 2019); Amendment 2020 (17 July 2020, SDD internal + annual audit committee verification); Amendment 2024 (17 May 2024, Reg 2(1)(e) media clarification); 2nd Amendment 2024 (25 June 2024, Reg 5 trading plan overhaul, effective 23 September 2024); 3rd Amendment 2024 (4 December 2024, connected-person expansion + relative definition); Amendment 2025 (11 March 2025, UPSI 16-item + external-UPSI 2-day SDD + trading window carve-out, effective 10 June 2025). SEBI Master Circular on LODR dated 30 January 2026 (supersedes 11 November 2024 version). SEBI Circular on trading window closure automation dated 21 April 2025 (SEBI/HO/ISD/ISD-PoD-2/P/CIR/2025/55; top 500 from 1 July 2025, all listed from 1 October 2025). SEBI Industry Standards Note on Reg 30 dated 25 February 2025. SEBI ISF RPT Industry Standards dated 26 June 2025. SEBI BRSR Core Circular dated 12 July 2023 and Recalibration Circular dated 28 March 2025 (Data-and-Assessment-or-Assurance). SEBI Board Meetings 207th (30 September 2024, connected person), 208th (18 December 2024, UPSI alignment), 209th (24 March 2025, FPI + MII), 211th (12 September 2025, RPT revamp under Tuhin Kanta Pandey as Chairperson since 1 March 2025). Case law: Balram Garg v SEBI (SC 19 April 2022, 2022 SCC OnLine SC 496), FCRPL v SEBI (SAT February 2024), Kunal Ashok Kashyap v SEBI (SAT 20 January 2025), Linde India Ltd v SEBI (SAT 5 December 2025). SEBI Orders (case studies): RHFL / Anil Ambani (22 August 2024), Linde India / Praxair (24 July 2024), Paytm warning (2024), Zee Entertainment (January 2025), IndusInd Bank (28 May 2025), HDFC merger HUF (July 2025), Adani clean chit (18 September 2025), Nucleus Software (September 2025), Swan Corp (September 2025), IEX interim (15 October 2025), NDTV (May 2026), Reliance Industries administrative warning (24 June 2026), Adicorp Enterprises (September 2025). Related statutes: Companies Act 2013 Sec 149, 188, 204 for interaction with LODR Reg 17, Reg 23, Reg 24A; SEBI Act 1992 Sec 15G (Rs 25 crore or 3x profits penalty cap, unchanged since 2014); SEBI PFUTP Regulations 2003 Reg 4(2)(q) (front-running); SEBI (Mutual Funds) Regulations 1996 Reg 5A (PIT-lite for AMC scheme units, operative 1 April 2023). Institutional: ICSI Secretarial Standards SS-1 and SS-2 revised 1 April 2024 (approved under Sec 118(10) CA 2013); ICSI Compendium on PIT dated 27 June 2025; ICSI SDD Advisory dated 28 February 2024; NSE SDD SOP circular dated 18 October 2024 (quarterly SDD certificate); BSE FAQs on Reg 33 dated 17 November 2025; SCORES 2.0 launched 1 April 2024 (21-day resolution timeline); IiAS Voting Guidelines 2024-25 revised 31 July 2024. Items requiring ongoing verification and flagged inside the relevant lessons: LODR Third Amendment 2025 gazette date, LODR Fifth Amendment 2025 gazette (18 vs 19 November 2025), LODR Amendment 2026 gazette (20 vs 22 January 2026), HVDLE transition rules for entities dropping out after January 2026, SME LODR CG applicability beyond Reg 23, BRSR Core assessment-or-assurance provider ecosystem, 23 March 2026 SEBI Board Meeting decisions (not confirmed via WebFetch), any PIT amendment notified 12 March 2025 to 30 August 2026, SDD 8-year retention start point, SDD "quarterly" (exchange) vs "annual" (Reg) audit committee review distinction, SDD vendor list (InsiderQ, InsiderSDD, NOVUS Velox, Orion, Lexcomply, Ricago; NOT Sprinto or Rubix), contra-trade cross-PAN informal guidance, and SEBI adjudication order PDF verification for each named case study.

The best compliance officers at listed entities run their entire year off a single spreadsheet: the quarterly calendar. Every filing, every certification, every board meeting, every audit committee meeting, every deadline. If you cannot describe the whole thing in five minutes, you are not running your desk; the desk is running you. This lesson walks the calendar as it stands in FY 2026-27.

The quarter shape

The Indian financial year runs 1 April to 31 March. Quarter ends are 30 June (Q1), 30 September (Q2), 31 December (Q3), 31 March (Q4). Each quarter has the same shape:

  1. Quarter-end plus 1 to 45 days: Financial results filing under Reg 33 (45 days for Q1, Q2, Q3; 60 days for Q4 combined with annual)
  2. Quarter-end plus 1 to 30 days: Corporate Governance Report under Reg 27(2) (via Integrated Filing (Governance) since 1 March 2025)
  3. Quarter-end plus 1 to 21 days: Shareholding Pattern under Reg 31
  4. Quarter-end plus 1 to 15 days: Investor Complaints Statement under Reg 13(3) (via Integrated Filing (Governance))
  5. Quarter-end plus 1 to 30 days: Reconciliation of Share Capital Audit Report under Reg 76 SEBI DP Regulations
  6. During the quarter: Reg 30 material events on rolling basis (30 min / 12 hr / 24 hr)
  7. During the quarter: Reg 30(11) rumour verifications if MPM trigger (top 100 or top 250)
  8. During the quarter: Reg 29 promoter shareholding disclosures
  9. During the quarter: Continual PIT Reg 7 disclosures within 2 trading days of the Rs 10 lakh threshold breach
  10. Quarter-end: Trading window closure under PIT Sch B Cl 4 from quarter-end till 48 hours after results (automated PAN freeze at depository since 1 October 2025 for all listed entities)

Layered on top of the ten quarterly filings are three certifications: the quarterly SDD compliance certificate from Compliance Officer or PCS to NSE / BSE under the October 2024 NSE SDD SOP circular [L4-C1], the quarterly Investor Complaints Statement certification and the half-yearly PIT Sch B Cl 4A audit committee verification.

A worked quarter: Q2 FY 2026-27 (Jul-Sep 2026)

Here is what your calendar looks like as you enter Q2 FY 2026-27 on 1 July 2026.

DateItemRouteSignatory
1 Jul 2026Trading window closes (Q1 end)Automated PAN freeze at NSDL/CDSLN/A (system)
By 14 Aug 2026Q1 financial results (45 days from 30 Jun)BSE Listing Centre / NSE Digital PortalMD / CEO + CFO
Q1 results date + 2 hoursTrading window reopens (48 hr from results)Automated depository unfreezeN/A (system)
By 21 Jul 2026Q1 Shareholding Pattern (Reg 31)BSE / NSECompany Secretary
By 15 Jul 2026Q1 Investor Complaints (Reg 13(3))Integrated Filing (Governance)Compliance Officer
By 30 Jul 2026Q1 Corporate Governance Report (Reg 27(2))Integrated Filing (Governance)Compliance Officer
RollingReg 30 material eventsBSE / NSE within 30 min / 12 hr / 24 hrCompliance Officer / CS
RollingReg 30(11) rumour verificationsBSE / NSE within 24 hr of MPMCompliance Officer
RollingReg 29 promoter shareholdingBSE / NSE within 2 trading daysCompliance Officer
RollingPIT Reg 7 continual disclosuresBSE / NSE within 2 trading daysCompliance Officer
By 20 Jul 2026Quarterly SDD compliance certificateBSE / NSECompliance Officer or PCS
1 Oct 2026Trading window closes (Q2 end)Automated PAN freezeN/A (system)

Reg 33 financial results, the deadline arithmetic

Reg 33 sets quarterly and year-to-date standalone financial results within 45 days of end of each quarter, except the last quarter. Last quarter (Q4) and annual audited standalone plus consolidated results within 60 days of end of financial year. So:

  • Q1 (Apr-Jun): standalone + consolidated (if subsidiaries exist) within 45 days = by 14 August
  • Q2 (Jul-Sep): standalone + consolidated within 45 days = by 14 November
  • Q3 (Oct-Dec): standalone + consolidated within 45 days = by 14 February
  • Q4 (Jan-Mar) + annual: audited standalone + audited consolidated within 60 days of FY end = by 30 May

For entities without subsidiaries, only standalone is filed. For entities with subsidiaries, both standalone and consolidated are mandatory. SMEs may file half-yearly instead of quarterly. BSE FAQ circular dated 17 November 2025 [L4-C2] clarifies the applicability and timelines.

Reg 24A secretarial audit, the annual layer

Regulation 24A operative 1 April 2025 requires every listed entity plus every material unlisted Indian subsidiary to undergo secretarial audit by a Peer-Reviewed Practising Company Secretary. Tenure: individual PCS one term of 5 years; firm two terms of 5 years; 5-year cooling off. Annual Secretarial Compliance Report (ASCR) filed with stock exchanges within 60 days of FY end (by 30 May) in XBRL, signed by the Secretarial Auditor or a Peer-Reviewed PCS meeting Reg 24A(1A) / (1B) [L4-C3].

The engagement of the Peer-Reviewed PCS happens once a year (or once every 5 years if you are engaging for a new tenure). The report filing is annual. But the underlying compliance mapping happens continuously through the year. The ASCR checkilist covers LODR + ICDR + SAST + Buyback + SBEBSE + NCS + PIT + RPT approvals. If you have not been maintaining a compliance evidence pack quarter by quarter, the secretarial auditor will demand it in April.

Reg 34 annual report, the annual anchor

Regulation 34 sets the annual report obligation. Reg 34(1) requires the annual report to be submitted to the stock exchanges within 21 working days of the AGM. Reg 34(2)(f) requires the BRSR for top 1,000 listed entities. Reg 34(3) prescribes contents including balance sheet, profit and loss, cash flow, directors report, corporate governance report per Sch V, MDA, secretarial audit report.

The AGM must be held within 6 months of FY end (30 September for a March-year-end entity). Notice to shareholders 21 clear days before. E-voting compulsory for top 500 by market cap. Annual report to shareholders is despatched electronically per SEBI framework.

Half-yearly filings

Two obligations fall on a half-yearly rhythm rather than quarterly:

  • Reg 27(2) Annex IV half-yearly disclosure of loans, guarantees, comfort letters and security provided by the listed entity to persons in the promoter group or its subsidiaries, filed with the CG report
  • PIT Sch B Cl 4A annual audit committee verification of SDD internal controls

The "always on" obligations

Three obligations run continuously without a scheduled trigger:

  • Reg 30 material events. Any board decision, any credit rating change, any regulatory action, any promoter dispute, any material contract. The 30-min / 12-hr / 24-hr clock starts on the event, not on the quarter.
  • Reg 30(11) rumour verification. Any mainstream media report that causes a Material Price Movement in your scrip. The 24-hour clock starts on the MPM detection.
  • PIT trading discipline. Trading window closures at quarter end (automated). Pre-clearance decisions from designated persons. Contra-trade monitoring. SDD entries within 2 calendar days for external UPSI.

Building your own calendar

Take a blank sheet. Down the left column, list every LODR obligation your entity carries (varies by chapter and market cap band). Across the top, list the four quarters plus a "rolling" column. Put an X where each obligation intersects each quarter. Add signatory. Add filing route. Print it. Put it on your Company Secretary's desk. Update it every 1 April.

Next lesson: the five events that get listed companies into most SEBI trouble. Reg 30 lapses, Reg 23 unapproved RPTs, PIT UPSI breaches, SDD failures, secretarial audit gaps. What SEBI enforcement actually looks like, and how to build for it.

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Citations
NSE Circular, NSE SDD SOP 18 Oct 2024 (Quarterly SDD compliance certificate) L4-C1
NSE Circular dated 18 October 2024 formalising Standard Operating Process for SDD compliance. Requires listed entities to file a quarterly SDD compliance certificate from Compliance Officer or Practising Company Secretary. This is an exchange-level administrative requirement; the PIT Regulation itself requires audit committee verification annually (Sch B Cl 4A from 2020 amendment). Do not conflate.
SEBI LODR 2015, Reg 33 Financial Results timelines (Quarterly + annual financials) L4-C2
Reg 33 sets financial results timelines. Quarterly (and year-to-date) standalone results within 45 days of end of quarter, except last quarter. Last-quarter and annual audited standalone plus consolidated results within 60 days of end of financial year. Consolidated results mandatory where subsidiaries or associates exist. SMEs may file half-yearly results. BSE FAQ circular 17 November 2025 clarifies applicability and timelines.
SEBI LODR 2015, Reg 24A Secretarial Audit (Secretarial audit + ASCR post 3rd Amend 2024) L4-C3
Reg 24A revamped by LODR (Third Amendment) 2024 gazetted 12 December 2024, operative 1 April 2025. Secretarial audit mandatory for every listed entity and its material unlisted Indian subsidiaries. Secretarial Auditor must be a Peer-Reviewed Company Secretary holding a valid ICSI peer-review certificate. Individual PCS: one term of 5 consecutive years. Firm: two terms of 5 years each. Five-year cooling off. Annual Secretarial Compliance Report (ASCR) filed with stock exchanges within 60 days of FY end in XBRL, signed by the Secretarial Auditor or a Peer-Reviewed PCS meeting Reg 24A(1A) / (1B).
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Reading Module 1. Enrol to unlock the rest of the course.
Module 1: The listed-company operator's world
Module 2: Board composition, committees, independent directors
  • Reg 15 applicability, SME crossover and HVDLE
  • Reg 17 board composition and the chairperson-MD story
  • Regs 18-22 committees
  • Reg 25 Independent Directors and D&O
  • Reg 24 material subsidiary and the 10 / 20 test
Module 3: Reg 30 material events and rumour verification
  • Reg 30 recast after the Second Amendment 2023
  • Schedule III Part A materiality: the 2 / 2 / 5 test
  • Reg 30(11) rumour verification and the MPM trigger
  • Integrated Filing (Governance) from 1 March 2025
  • Building the internal materiality workflow
Module 4: Related Party Transactions after the Fifth Amendment 2025
  • Schedule XII slab materiality after the Fifth Amendment
  • Reg 23 audit committee and shareholder approval
  • Omnibus RPT approvals formalised in Reg 23
  • Subsidiary RPT jurisdiction and Linde India aggregation
  • The RPT operator's playbook
Module 5: PIT foundations
  • Insider, connected person, and relative
  • UPSI 16-item list after the March 2025 amendment
  • Reg 3 communication, Reg 4 trading and the six defences
  • Reg 5 trading plan after the June 2024 overhaul
  • Regs 6 and 7 disclosure obligations
Module 6: SDD, trading window, code of conduct
  • SDD Reg 3(5) and 3(6) in detail
  • SDD vendor landscape in India
  • Automated trading window closure
  • Pre-clearance, contra trade, and the IndusInd case
  • The PIT operator's playbook
Module 7: Reg 24A secretarial audit, Reg 27 CG report, Reg 33 financials, Reg 34 BRSR
  • Reg 24A Secretarial Audit revamp
  • Reg 27 CG report and ICSI Secretarial Standards
  • Reg 33 financial results timelines
  • Reg 34 BRSR and BRSR Core assurance
  • SCORES 2.0 and the investor complaint cycle
Module 8: Enforcement, settlement and the operator's playbook
  • The IEX Oct 2025 anatomy of a PIT interim
  • RHFL, DHFL, Zee and Adani case studies
  • PIT enforcement: HDFC, IndusInd, Nucleus, Reliance
  • Settlement Scheme and Section 15G math
  • The compliance officer's system and templates