Trading Window Closure
The regulated period during which Designated Persons of a listed entity are prohibited from trading in its securities, imposed by SEBI PIT Regulation 4(1).
Regulation 4(1) of the SEBI PIT Regulations 2015 requires every listed entity to maintain a Code of Conduct that specifies when Designated Persons (DPs) — and their immediate relatives — are prohibited from trading in the entity's securities. The window is closed for a period surrounding the publication of financial results, from the end of the quarter until 48 hours after publication, and around other events involving UPSI.
The 21 April 2025 SEBI circular introduced a system-level enforcement layer: the depositories (NSDL and CDSL) automatically freeze the demat accounts of DPs during closure windows notified by the listed entity. A DP who attempts to trade during closure has the order rejected at the depository level — enforcement is proactive, not reactive.
Operationally this places new requirements on the Compliance Officer: notifying the depositories in the correct format at least 48 hours before the window opens or closes, maintaining the DP list current (additions, removals, immediate-relative changes), and managing exceptions (pre-cleared trades, contra-trades forbidden by Regulation 9). The dcomply Academy SEBI LODR + PIT Practitioner Certification walks the closure-window operator's workflow.